In reviewing this document several times, it seems that a tremendous amount of responsibility is being placed on the LMHP. There seems to be specifics in relation to treatment planning, overseeing of the ISP and the overall requirements of a LMHP. There is a real concern as this is an unrealistic expectation due to several factors:

1. Staff shortages – When speaking with and attending trainings throughout the state, there is no denial of staff shortages – this has been a concern in every area of Virginia. There would need to be additional staff hired to meet these requirements and that is a challenge currently without the additional requirements.
2. Time – with the current requirement of LMHP’s, time is a true concern. LMHP’s currently provide same day access and the required paperwork that accompanies intake, individual therapy, group therapy, reassessments, the list goes on and on – this is not to mention the requirements to remain licensed yearly.
3. I recommend the ISP development, monitoring, and adjustment needs to remain with the assigned provider regardless if the provider is a LMHP.  This appears to be more person-centered as the everyday provider knows the client and the clients need the best.