I am concerned that the new regulations would require crisis treatment to be provided by a LMHP or LMHP type for ICT services. We have a certified preadmission screener on our ICT team that is not an LMHP or LMHP type. Certainly this individual would be qualified to provide crisis intervention despite not being an LMHP or LMHP type. Also we have a mix of QMHPs and LMHPS. The definition of crisis treatment is so broad it could include a variety of services that a QMHP might be perfectly qualified to handle, especially under the supervision of the team lead. The severity of illnesses for individuals receiving ICT services is such that crisis occur on a regular basis. To have the number of LMHP and LMHP types on the team that would allow for only LMHP and LMHPs would require more recruitment of LMHP and LMHP tyes. This would only be financially feasible if reimbursement rates were increased.

I am also wondering why LPNs are not listed as being able to assist with medication management. It would seem to be that LPNs would be as qualified if not more qualifed than LMHPs to assist with medication management.