My concern over the proposed changes to the provider qualifications is not only that so many fewer clients will have access to needed mental health services but in the longer view, how many fewer avenues to licensure we are providing new professionals. The professional requirements of clinical supervision while providing services will not change but how will these services be provided? There are few opportunities for clinicians to see clients in an out-patient setting that will allow these clincians a full range of client issues and diagnoses. The obvious result of these changes is decreased access due to long wait lists which will multiply as fewer professionals are able to meet the requirements of licensure AND those who are will surely have little or no experience with the wide range of clients that are now seen through these services. Fewer services in the short term, fewer qualified counselors and fewer credentialed counselors in the long term will result in such a decrease in accessibility of these needed services that it will leave our most vulnerable populations more impaired for longer periods of time further impacting their opportunities for successful outcomes. While these changes may serve to decrease expenditures for mental health services by limiting access, the costs associated with these changes would seem obvious to any professional working in the field. You can expect higher rates of psychiatric in patient stays, higher number of calls for crisis services, higher utilization of licensed childrens services such as intensive in home and therapeutic day treatment, and higher rates of judicial involvement due to unmet mental health needs. These costs would seem to negate any savings created by lower expenditures in the communities for out patient counseling. Please reconsider these changes. 

Karen Pillis, MS