Page 8, 4.3 – LMHP Oversight

• It is recommended that the requirement of 24/7 availability of LMHP for consultation be reconsidered.  The 24/7/365 component of the service requires on-call or differential pay, consequently, adds cost that was not factored into the rate.  Please reconsider.

Page 9, 4.4  Collaborative BH Svc – The requirement of weekly team meetings adds additional administrative burden for the LMHP supervisor.  Recommend removing this requirement as CSBs have standards for supervision to include meeting 1-2 times per month in addition to a monthly team meeting. 

Page 9,  4.5 Supervision of individual staff – The requirement of weekly supervision for non-licensed staff interferes with the clinical supervision that LMHP-eligible staff must receive as required by the DHP.  They are already receiving weekly clinical supervision in preparation to obtain their license.  Additionally, they have been deemed to have the ability to practice with some level of independence.  Also, QMHP staff do not require weekly supervision.  It is recommended that this requirement be removed as it adds administrative burden.

Page 10, Supervision of QMHP and T and BHT – weekly supervision of QMHPs does not align with DHP requirements.  Please remove this requirement.  Also, the requirement that QMHPs must be supervised by LMHP does not align with new DHP changes.  Please consider removal.

Page 11 4.5 Supervision Matrix –LMHP-types don’t need the same level of weekly supervision as QMHP-T and BHTs.  Additionally, QMHP do not need weekly supervision as stated by DHP.  Please remove these requirements as this is heavy administrative burden.