In this proposal, the amount of additional requirements placed on LMHP-types would be unrealistic and would, more than likely, have a negative impact on LMHP staff retention.  Agencies would be required to be able to pay LMHP-types suitably and in a way that would attract experienced LMHP-type staff.  LMHP-type staff requirements, such as ISP development, would be able to be completed by QMHPs with the assistance of an LMHP, which would be more cost-effective.  Regarding peer services, I do not feel that this should be made a requirement and should be left to the discretion of the agency.  If peer services are made a requirement, this could be difficult to adhere to due to the limited availability of qualified peer recovery specialists and turnover rates in rural areas.