In order to provide these services as described, our agency would be significantly diluting the quality and quality of client and clinician oversight and development. Interestingly, we are in favor of LMHP-types overseeing and writing the treatment plans, as long as the caseload is manageable. This is similar to the model for ABA programs. However, under the BH redesign draft model, there are simply too many clients for one LMHP to adequately supervise due to:
Of particular interest, this multiple-client model significantly reduces the ability of a residency-supervising LMHP to adequately prepare LMHP-types for independent practice through the development of counseling skills, self- and others- awareness, critical thinking, etc., due to limited time for discussing each client/family’s unique needs and observing and giving feedback on session recordings and treatment plans. Instead, the supervisor will be left to teach them to follow manualized models of care due to high caseloads.
Additionally, the requirement that LMHPs need to provide at least half of the supervision in person creates a significant barrier to dedicating time to the client and clinician care due to needed travel between agency offices/sites. Undoubtedly, this is an effort to deter providers from hiring contracted supervisors and, as such, is another example of solving problems with rules instead of accountability. The draft regulations do seem to cover this problem in 4.5 #1.
We ask that supervision allowances to follow the BOC guidelines, that supervision ratios are based on client numbers and not supervisee numbers, that DMAS aligns supervision allowances with the BOC, that LMHPs can provide remote supervision from another same-agency site, and that the supervisor can use weekly individual and group supervision to account for team meetings.