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

Reimbursement Rates and Service Parity

• It’s unclear if QMHPs, QMHP-Ts, and BHTs can provide the same services and whether they’ll be reimbursed at the same or different rates.
• Concern that if higher-level staff (e.g., LMHPs) deliver lower-level tasks (e.g., rehabilitative skills), they’ll be reimbursed at the lower rate, undervaluing their expertise.

Complexity and Administrative Burden

• The billing system is overly complicated, with multiple staff-level modifiers (HO, HN, HM, etc.) and service-type modifiers creating risk for billing errors and denials.
• Tracking staff hours against the 504-unit monthly cap across all agencies is unrealistic, especially when staff work for multiple providers.
• Excessive administrative oversight will fall on agencies, stretching resources already under strain.

Unit Limits and Service Restrictions

• Tier 1 capped at 32 units/month (~8 hrs) and Tier 2 capped at 112 units/month (~28 hrs) are insufficient for client needs.
• No clear guidance on what happens if unit caps are exceeded in a crisis situation—will overrides be allowed?
• Non-licensed staff capped at 31.5 hrs/wk (504 units/month) reduces workforce flexibility.

Misalignment Between Workload and Rates

• The clinical and administrative workload (CANS, treatment planning, 24/7 LMHP availability, note co-signatures, supervision) far exceeds the anticipated reimbursement.
• Current structure risks creating a financially unsustainable model, especially for small and mid-sized agencies.

Non-Billable but Required Tasks

• Large portions of required work (documentation without client present, scheduling, team meetings, coordination) are not billable, shifting cost burdens to providers while still mandating completion.