I would like to start my commentary on a positive note; I am for the proposed change of non residential crisis stabilization services being utilized as a higher level of care. This will allow for more individuals in need of MHSS to be able to receive needed skills training services and/or remain in  services, building on gains made to date. It is great that you all recognize the same services are being provided, albeit in a different setting.

As far as the other proposed changes identified; LMHP, LMHP-supervisee's or LMHP- residents completing ISPs and incurring a 2-5 day wait for a crisis approval, I cannot support either of these plans. First, LMHPs are hard to come by, especially in rural areas. If an agency can hire an LMHP or multiple LMHPs, with the mindset that a constant component of his/her job will be writing ISPs for clients they do not know or have minimal interaction with, then we lose a large part of the case conceptualization piece of providing services. Clinicians who work with their clients daily, work with clients on identifying training needs and with the client's input, there is more of a buy in. Quality clinicians write quality treatment plans that their clients are vested in. I am a supervisor who works with both clinicians and LMHPs. We are all well trained in the ability to write a treatment plan, but the difference is the clinician and client build a trust and execute objectives identified on the treatment plan daily. Clinicians also better understand and follow through on case conceptualization when they create the treatment plan rather than inherit one to work off of from someone who has a very different and isolated role in a client's world. The LMHPs I work with keep the ship afloat, but they are already wearing multiple hats and adding this unnecessary component to their workload makes little sense.

As far as  it taking from 2-5 days to receive an approval for crisis stabilization services, doesn't that just sound peculiar when you read it? Again, does not make sense. Crisis, means there is a presenting crisis. The way I see it, we are just waiting for increased hospitalizations. $$$$ lost and more importantly, a client could go without needed services which could lead to hospitalization, incarceration or even death. 

I know whoever is reading this values the feedback of those working in the  mental health frontline daily, more specially, MHSS. These services have made real and lasting change in many clients. I see it happen. I am proud to be part of that change, but honestly, every time we start making real gains, it seems like the rug is pulled out from under us in the form of the regulation change. Change is not a bad thing and is necessary for improvements, but if you are going to make changes, please talk to those doing the work daily so you get authentic feedback about how those changes would impact the ones who need services most. I think if anyone reading this, who is in a position to elicit change, would actually do the work of any MHSS team member for a week, he/she would better understand what is needed and not needed. Thanks for reading my comments today.

Roseann Kolosine, BA, QMHP-A