Through CPST, a single LMHP can supervise up to 9 non licensed staff.  However, the proposed regulations require that each of the staff receive and hour of supervision a week.  Despite Board of Counseling and DBHDS providing standards for QMHP to actually supervise QMHP-T/BHT, CPST would require the same QMHP to receive weekly supervision.  CPST makes the assumption that by being a LMHP, the staff is more experienced than non licensed staff. (page 1)  This statement is not an absolute truth simply based on qualifications.  The supervision requirement on LMHP staff would equate to nearly 25% of their time based on having 9 non licensed staff.  In order to lighten the time commitment, a program would have to have more fully licensed staff, experienced a significant increase in cost.

CPST under values QMHP staff and equates, in division of duties, them to BHT who have less education and experience.  Current legacy services are primarily staffed by QMHP.  Transition to CPST will lose a valued workforce.