Action | Initial regulations for registration of Qualified Mental Health Professionals |
Stage | Emergency/NOIRA |
Comment Period | Ended on 2/7/2018 |
In a recent QMHP Application, we noted the following on the application form: “due to the volume of applications, the processing time can take up to 60 business days.” This is equivalent to 3 months, not the 30 days we were informed it would take when the regulations first came out. This is both a hardship for agencies as well as our consumers. For the agency, this is huge financial burden. For consumers, it may mean the agency does not have the capacity to service all those in need or may need to provide level of service needed. For crisis services such as a residential Crisis stabilization program, It becomes a safety risk when an agency cannot fill positon vacancies quickly. There needs to be some type of interim status during the application process in which the applicant can provide services until the BOC has been able to determine the applicants level of credential.
The other concern I have is the Verification of Supervised Experience form that must be signed by the Supervisor under which the experience occurred. This is a state wide new requirement. I wonder how well institutions of higher education have been informed/educated of these new regulations so that students are well informed when they choose a practicum. They should know to provide the Practicum Supervisor the Verification form at the start of their practicum to have accurate information at the finish of the practicum and the Licensed/Licensed-Type signature.
Also I am very concerned that QMHP Applicants may not be able to obtain the required information and signature form previous employees for any number of reasons and obtain it in a timely manner, once again adding to the financial hardship to employers.