The proposed changes would severely impact the mental health residential program.  There are currently no LMHP staff for these programs.   These changes would require a program-specific clinical director and one additional LMHP for every 9 staff members.  RACSB would need to add 1 Licensed Program Specific Clinical Director and 2 additional LMHPs to support MH Residential alone.  There will be additional costs of increased training requirements, significantly increased supervision requirements, significantly increased administrative burden/documentation/complex authorization, etc. 

If we assume the maximum reimbursement rate and maximum number of hours per month are received per individual served and use last fiscal year’s expenses, these changes would result in a $1M deficit across the impacted programs.  The three FTEs necessary would add another $350K in costs with no increase in quality of services.  Further, this estimate does not calculate the costs of the requirement to have 24/7/365 coverage provided by an LMHP (Licensed provider).  Thus, we are looking at a reduction of $1.5M to our existing effective and efficient programs.