The following provides a summary of the top concerns shared by our members:

LMHP Requirements and Workforce Impact

• Overly burdensome LMHP expectations (on-call, supervision, documentation, and training) will make staffing unsustainable, particularly with LMHP-types excluded from supervisory roles.
• The shortage of licensed staff will limit access, drive up costs, and reduce the ability to meet community needs.
• Training access, cost, and timeline (especially MAP) remain unclear and unrealistic.

Lack of Clarity and Transparency

• Providers need clear, consistent guidance on service tiers, authorization processes, IEP integration, and crisis expectations.
• Ambiguity invites inconsistent MCO interpretation and compliance risk.

Service Design and Practicality

• 24/7 crisis coverage and other in-school service expectations are not feasible in school-based settings.
• Low unit caps and strict ratios hinder service flexibility and access.
• Policies must better align with school operations and coordination protocols to ensure realistic implementation.