I would like to speak to the regulation change requiring for Assertive Community Treatment (ACT) Team Lead to be LMHP.  My programs are in a rural area in Southwest Virginia.  We have extreme difficulty in hiring LMHP's in our area.  I would ask that either a waiver process be put in place, for areas such as ours, to allow LMHP-E's to be considered for ACT Team Leads and other positions.  In order to draw the LMHP pool of applicants to our rural area, it is often necessary to open our positions for LMHP-E's with supervision for licensure provided.

Could we consider including LMHP-E's within this requirement or having a waiver process for situations such as we may face in rural areas?

Thank you for your consideration.