A summary of feedback provided by our members on this section follows:

LMHP Documentation Review Burden

• Requirement for LMHPs to review all non-licensed staff documentation every 30 days is unclear and potentially excessive. Is a monthly progress note/co-signature sufficient, or must every individual note be signed? Can EHR system sign-offs (e.g., ICANotes) meet the requirement?
• This expectation could overwhelm LMHPs, especially in larger agencies, and risks creating delays, burnout, and inefficiencies.

Oversight vs. Practicality

• While oversight and quality assurance are supported, the draft requirements are administratively burdensome and undermine a team-based approach.
• Restrictions on telesupervision (must be in person at least half the time) ignore clinicians with Board Certified Telemental Health credentials and harm rural agencies where telesupervision is essential.

ISP and Review Requirements

• ISPs must be updated every 90 days in person with LMHP, team, and consumer.
• Concern: if a client misses or refuses, will services be denied? Agencies need flexibility to document “good faith effort.”

Reimbursement Concerns

• It’s unclear if QMHPs and BHTs will be reimbursed the same for the same services.
• Current reimbursement levels do not match the increased administrative and clinical oversight demands being placed on LMHPs and agencies.

Workforce Sustainability

• The additional workload makes CPST less appealing to LMHPs, who already face shortages and can find better-paying, less burdensome opportunities in outpatient therapy.
• Without rate adjustments and incentives, agencies will struggle to recruit and retain LMHPs needed to sustain these requirements.