In Chapter II of the Draft Manual, there seems to be some discrepency about the level of supervision required for certain services.  For PSR and MHSS, it appears that the language has been changed on pages 14 & 15 to indicate that services have to be supervised by LMHP-type individuals.  On page 15 of the manual, it states that, "DBHDS requires the supervision of services that are supportive in nature such as psychosocial rehabilitation or MHSS shall be provided an by a LMHP, LMHP-S, LMHP-R, LMHP-RP or QMHP-A."  As these programs are not inherently clinical in nature, there is a significant shortage of LMHP-types in many parts of the state and their level of compensation would not be feasible in a program such as PSR in which the reimbursement rate is so low, we support QMHP supervision of these programs.   These services are reviewed every six months by LMHP-types and LMHP-types are available to staff more clinical issues as they arise.  This should be sufficient for these services. 

Language in Chapter IV seems to state that LMHP-types can review services through a chart review for MHSS and PSR.  We would like some clarification around this making sure that we are understanding correctly that doing a documented chart review is sufficient for determining medical necessity. 

Thank you for your consideration of these comments.