Concern #1:

QMHPs are more than qualified to write the ISPs for community-based services including MHSS.  Additionally, they are actually more suited to do so since they are most informed of the clinical concerns/needs and strengths of the client. By requiring LMHPs to complete ISPs, there will not only be an undue burden on providers to employ more LMHPs which is already difficult to do so, but the ISPs will be less individualized and person-centered as the LMHPs are not in contact with the client nearly as much as the QMHPs are.

Concern #2:

Having ISPs specify weekly time frames to show an average typical frequency of delivery of service is reasonable.  However, having those time frames be inflexible and not based on the need of the client is not consistent with best practice or person-centered treatment.

Concern #3:

Crisis stabilization by nature of the service will be effective if it requires an authorization.  This is counter intuitive to the purpose of the service.