I agree with all comments that have been posted prior to mine pertaining to the many irregularities in the proposed regulations. 

However, as a Human Resources Director, many of the proposed regulations have a tremendously adverse impact on employees and the clients we service.  In efforts to develop compassionate, caring, and clinical staff, the regulations continue to make it virtually impossible to identify and employ qualified mental health professionals.  Many candidates invest in their education with degrees that "qualify" them as a QMHP, IF they have 1 year clinical experience.  Many programs do not require internships or practicuums as a part of completion of the program.  Therefore, many candidates seek out their own clinical experiences in hopes of becoming a qualified mental health professional.  The language in the proposed regulations indicates that "unsupervised" internships, practicums, or field experiences do not meet the requirements.  This industry overall is extremely competitive.  Since the regulation changes in 2010, it has become even more challenging to hire and retain quality staff.  Often, there are compassionate, caring, and knowledgeable staff who are unable to succeed in the industry due to strict regulations.  Unfortunately, the industry is also saturated with many "qualified" professionals who do not provide quality service and still make it through the doors of many agencies that are desparately plagued with vacancies.  With millenials entering the workforce, it is unfair to disqualify an individual who took a risk and creatively sought opportunities to develop their clinical experience  on the premise that the experience was not "supervised."  Supervising interns is a hardship on any behavioral health services agency.  We must comply with supervision requirements for our paid employees while "contemporaneously" providing gainful clinical experience to our interns.  What documentation is available or expected of the employer to determine if clinical experience was supervised vs. unsupervised if the potential employees' educational program does not require it for the degree completion?  Why would DBHDS list certain degrees as acceptable in the document entitled Human Services and Related Fields Approved Degrees/Experience if the degree program does not require supervised practicums, internships, or field experiences?  This seems like a flawed regulation that should be revisited to realistically classify an individual as QMHP-A, QMHP-C, or QMHP-E based on education and experience of programs that are REQUIRED to have clinical experiences as a graduation requirement. Human capital is the essence of service provision, so hiring people who fit the culture of the agency and the clients we serve will only become more challenging with the current and proposed regulations.  Hiring a QMHP-E is often a hardship for many agencies if they do not have a triennial license or DMAS-approved Supervision Training Program.  How would a newer agency meet compliance with trying to develop a workforce? 

Another HR concern with the proposed regulations is the shift in requiring that Crisis Intervention services are provided by LMHP, LMHP-Supervisee, LMHP-Resident, or LMHP-RP.  Implementation of this regulation would pose hardship and loss of employment to many QMHPs who are currently providing the service.  This could potentially create a negative impact on service provision (meaning clients without a much needed service) and gainful employment (similar to what  the 2010 regulations did on for so many). 

Respectfully Submitted

Ryshonna Stith, MA