1. Sociology should continue to be an approved  degree . Sociology is very much related to the field . Removing Sociology from the approved list of degrees has reduced our pool of possible applicants for QMHP positions, positions that are already difficult to fill.

2. The BOC description of the QMHP role and scope of practice / types of services on the recent FAQs do not match the DMAS regulations- so which description/regulation will agencies follow?  It would be most helpful if the BOC ; DMAS and DBHDS regulations and expectations were in sync.

 3. Clarification of  the Supervision component of the regulations is needed:

• Does the LMHP/LMHP-Type level of Supervision that is required have to be provided by the Supervisor of the Program?
• Are all  registered QMHPs required to be Supervised by an LMHP/Type or is this just for the registered QMHP-Trainees?
• If someone is grandfathered in as a QMHP and then works in a program that does not require QMHP level of credential to bill for the service (i.e. MH Case Management) and the program is not Supervised by an LMHP/Type – will these employees no longer meet the requirements for continued QMHP credentialed status at the time of renewal?
• Does the LMHP/Type have to be present with the QMHP and/or QMHP-Trainee when the QMHP and/or QMHP-trainee is in the community working with a client, providing a service ? …
• What does the Supervision documentation need to include?

4. QMHP- Trainees registration

• Additional clarification of this status is needed ....what is required of the provider to make sure the provider has everything in place to hire a potential QMHP-Trainee .  As mentioned above, clarification of the Supervision requirements  for a QMHP-Trainee is needed.
• It would be most helpful if  the BOC , DBHDS and DMAS were all on the same page regarding the requirements for the QMHP –Trainee  status.  DMAS has a limit to the # of Trainees per agency and per LMHP/Type Supervision .It is concern if a QMHP applicant is not credentialed due to insufficient experience , they could potentially be considered a QMHP-Trainee level . The DMAS restrictions to the  # of QMHP-Trainees could very well impact our ability to fill positions and serve our clients. In addition, it is my understandings that DBHDS needs to approve a QMHP-Trainee Training program before a provider can even consider using a QMHP-Trainee but as an agency, we have been waiting since June for an approval  for a submitted QMHP-Eligible Training program and recently received an e-mail  from a DBHDS representative that this now falls under the BOC .  Clarification is very much needed.

5. The requirement for QMHP Credential or QMHP-Trainee registration before a provider can bill for services using the employee( that require this level of credential) puts a great financial burden on Providers . It essentially means that we will have staff on board for whom we cannot use to provide a service until we receive confirmation from the BOC. Even if the BOC can meet their intended 30 day turn around period , it is still a great burden. This can potentially and very likely reduce our ability to serve individuals already in service and/or take on new clients in need of the service when a position is vacated.  This is particularly a concern for services working with high risk individuals such as a residential Crisis Stabilization Program.

 6. Requiring separate Credentials for Adults vs Children/Adolescents  sounds good until you get into the details of how services are provided. The ages of 18 thru 21 are somewhat blurry when it comes to whether these individuals are considered Adolescents or Adults. DMAS considers them Adolescents,   Our agency, in most cases, view an 18 to 21 year old  as adolescents only if they are still in the educational system,  and receive services through our Children’s Programs. So, would a QMHP-C credential be sufficient for a staff person providing a service to an 18 – 21 year old who is in school and is receiving an agency defined child  level service?....Or would this person require both the QMHP –A and QMHP –C credential.

 7. I would like to echo concerns regarding the 8 hours of continuing education being too narrowly defined regarding who can provide the training as mentioned in other comments submitted.