We share the concern expressed by others regarding the requirement that the work of a QMHP be supervised by an LMHP.  Licensed clinicians are needed to provide direct clinical services and recent increased requirements for their involvement in various services has already put a strain on resources for the behavioral health care system.  In addition, there is a shortage of LMHP's across the state, and recruitment of LMHP's in our region continues to be difficult.  Requiring this level of supervision will result in an increased cost of providing services, as well as a hardship on the CSB/BHA.  (C.1)

We are also concerned about the difference in the hour requirement for experience of those with a masters degree.  It appears that a Masters in human services and 500 internship hours meet the requirement (B.1), and a Masters in a human services field and 1500 hour of work experience meet the requirement (B.2).  This is concerning, as hours of work experience should provide a better learning experience than a brief 500 hours of an educational internship.  It is also concerning that experience gained requires the experience to be within the preceding 5 years prior to application for registration (B.2), yet it does not say this on the masters/internship section (B.1).  There should be a common number of hours of expeirence, which can include internship/practicum.  It is challenging to recruit individuals with 1500 hours of experience, especially recent graduates.  Therefore, the hour requirement should be lowered, and should be consistently applied.