A summary of our member feedback on this section follows:

Assessment and Accreditation

• Need clarity on whether the CANS assessment will be uniformly approved by both DMAS and DBHDS to avoid conflicting audit requirements, as seen in prior years.
• Clarify whether national accreditation will be required for all services or only for CPST.

Definitions and Staffing

• Current definitions for staffing and team composition are generally clear, but there are gaps—no definitions for QMHP, QMHP-Trainee, or BHT.
• Concern that supervision language (“in person with individual/caregiver”) could be interpreted as direct client intervention, not staff supervision.
• Separating LMHP-types (residents/supervisees) reduces flexibility and creates bottlenecks.
• Removing QMHP authority to supervise other QMHPs/QMHP-Ts eliminates a practical workforce tool previously allowed.

Telehealth and Supervision

• Request that simultaneous visual interactions via telehealth be recognized as “in-person” for supervision and client care.
• In rural areas, requiring physical presence is impractical and undermines quality. Agencies have proven for nearly a decade that telesupervision is effective, ethical, and essential.
• Clear definitions are needed for terms like “clinically appropriate” and “simultaneous interactions.”