My main concern is the level of responsibility placed on LMHP staff. Putting them in charge of Assessments, ISPs, and Quarterlies in addition to running counseling groups and providing program and staff supervision will require the need for additional LMHPs to be hired, which will cost more for the agency. This will be tricky with the current workforce shortage.

        There is also some concern about potential ethical violations If a practitioner is working outside of their area of expertise. For example, with the vocational specific requirements, that is not something that the average LCSW is trained on, but a Licensed Rehabilitative Counselor is. We would need to have both on staff, which again would be difficult with the current workforce shortage and budget constraints.

It also seems as though it is reducing the workload of the QMHPs who are currently writing ISPs and Quarterlies on their own with approval from the LMHP. Some of the listed wording in the document is confusing, as it states that a QMHP should be able to make crisis plans and assist with writing assessments, but cannot assist or write ISPs. Is there a reason why QMHP’s can’t write ISPs?

             The other major concern I have is related to service limits and caseload limits. Currently, I run a psychosocial rehabilitation program that services the SMI population. Individuals with SMI often have long term needs and it can take many years to show real progress in their recovery. The document mentioning caseload limits is concerning. “The expectation is that recovery will be achieved over time.” Does this mean that there will have to be a waitlist instated and does it mean that there will be a hard cut off of service limits? This will also put a huge constraint on program budgets and either require more staff, or put individuals at risk for hospitalization if they are unable to receive long term care.

         Also, the hiring of Behavioral Techs, while nice in principle, according to the responsibilities listed in the document, seem to be taking on responsibilities previously handled by QMHP staff. But the document also states that they will require 2 years of experience. How will they get that experience and how will they be able to work with the SMI population with out it? Currently, the requirement is one year for QMHPs to work in PSR. Will the reimbursement rate be increased to reflect the need for all of these new staff? Are there any program modalities that will be recommended to assist with these changes? What is listed in the document are therapeutic modalities, not program models.