Making it a requirement for ICT service providers to provide counseling by a LMHP or LMHP-type will make it difficult for teams to remain in compliance. LHMP and LMHP-type staff are difficult to recruit within the limited funds allotted to the programs for staffing. In addition, per 12VAC35-105-1370 the composition of the ICT Treatment Team includes only one LMHP Type (the psychiatrist).  Most of the providers on an ICT Team are QMHPs, not LMHPs and this requirement severely restricts the team’s ability to provide appropriate therapeutic interventions to individuals receiving ICT services.  If a team can provide the therapeutic counseling then it should be encouraged, but making it a requirement  is not realistic for all teams.