I have several concerns with the proposed changes:

1. Considering the need for Crisis Intervention services across the state, it seems unrealistic to ONLY have an LMHP, LMHP-supervisee, LMHP-resident, LMHP-RP, or certified prescreener to provide services to individuals that may need Crisis Intervention services. A trained QMHP can provide quality services to an individual and/or family that is need of Crisis Intervention services. Additionally, if the proposed changes are adopted there will not be enough qualified people to meet the needs of the community.

2. Case Management activities are an integral component of IIH services and should not be removed based on the importance of ensuring services are provided from an holistic approach.

3. There seems to be a conflict with the proposed changes for TDT services, on page 603 #4 it states that the intake shall be conducted by the LMHP, however on page 603 #13 it states that the intake can be conducted by an LMHP, LMHP-supervisee, LMHP-resident, or LMHP-RP. Please clarify.

4. It is not always possible to have documentation of repeated interventions at the time of assessment.  It is not realistic to expect the provider to obtain documentation of repeated interventions at the of assessment, especially since often times individuals in need of mental health services are poor historians and do not keep accurate records/documentation. If this becomes a requirement, what type of documentation will be acceptable and how should the provider attempt to obtain this document at the time of assessment and remain in compliance with regulations as it pertains to completing the assessment. Will documentation of repeated interventions be required at the time of the VICAP assessment prior to the recommendation of services?

Respectfully Submitted,

Chartrice Thorne