A summary of our member's feedback on this section follows:

Supervision Structure and LMHP Burden

• The nine-staff supervision cap is too restrictive, especially for small agencies with part-time staff; agencies should set ratios themselves.
• Requiring fully licensed LMHP Clinical Supervisors excludes residents and LMHP-types who are already allowed by DHP regulations to supervise, worsening workforce shortages.
• Mandating 24/7/365 LMHP availability is inappropriate for a non-crisis service; coverage during operating hours would be more realistic.
• Weekly in-person team meetings and requirements that half of supervision be in person create unnecessary barriers, especially in rural areas where telesupervision has been proven effective.
• Overlapping and contradictory expectations between DMAS, DBHDS, and professional boards can create compliance risks and confusion.

Caseload and Staffing Requirements

• Caseload caps and billing hour limits (e.g., 31.5 billable hours/week for non-licensed staff) are unnecessarily complex and punitive, making staffing and scheduling impractical.
• The “blended ratio” formulas are overly complicated and burdensome to track, especially for small agencies.
• Caps don’t distinguish between full-time and part-time staff, further restricting flexibility.
• These requirements force agencies to hire more licensed staff that are not available or affordable, threatening sustainability.

Workforce Sustainability and Access

• There are already severe LMHP shortages, and most fully licensed clinicians do not want to do community-based work given pay, safety, and travel demands.
• The new supervision restrictions will push providers out of the field and make it nearly impossible for small and mid-sized agencies to compete with large systems for licensed staff.
• Without higher reimbursement, agencies will struggle to meet these staffing mandates, risking closures and reduced access for vulnerable populations.

Documentation and Compliance

• Requirements around comprehensive assessments (CANS and others) are unclear, risk duplication, and add significant administrative burden.
• Lack of clarity around staff roles (QMHP, QMHP-T, BHT, residents) creates compliance risk. For example, QMHPs should be recognized as professional staff, not paraprofessionals, and residents should be recognized as distinct from QMHPs and be allowed to supervise.
• Expectations for annual CEP-VA submissions, staff employment across agencies, and senior LMHP availability need more guidance and feasibility review.