Action | Initial regulations for registration of Qualified Mental Health Professionals |
Stage | Emergency/NOIRA |
Comment Period | Ended on 2/7/2018 |
1. Sociology should continue to be an approved degree . Sociology is very much related to the field . Removing Sociology from the approved list of degrees has reduced our pool of possible applicants for QMHP positions, positions that are already difficult to fill.
2. The BOC description of the QMHP role and scope of practice / types of services on the recent FAQs do not match the DMAS regulations- so which description/regulation will agencies follow? It would be most helpful if the BOC ; DMAS and DBHDS regulations and expectations were in sync.
3. Clarification of the Supervision component of the regulations is needed:
4. QMHP- Trainees registration
5. The requirement for QMHP Credential or QMHP-Trainee registration before a provider can bill for services using the employee( that require this level of credential) puts a great financial burden on Providers . It essentially means that we will have staff on board for whom we cannot use to provide a service until we receive confirmation from the BOC. Even if the BOC can meet their intended 30 day turn around period , it is still a great burden. This can potentially and very likely reduce our ability to serve individuals already in service and/or take on new clients in need of the service when a position is vacated. This is particularly a concern for services working with high risk individuals such as a residential Crisis Stabilization Program.
6. Requiring separate Credentials for Adults vs Children/Adolescents sounds good until you get into the details of how services are provided. The ages of 18 thru 21 are somewhat blurry when it comes to whether these individuals are considered Adolescents or Adults. DMAS considers them Adolescents, Our agency, in most cases, view an 18 to 21 year old as adolescents only if they are still in the educational system, and receive services through our Children’s Programs. So, would a QMHP-C credential be sufficient for a staff person providing a service to an 18 – 21 year old who is in school and is receiving an agency defined child level service?....Or would this person require both the QMHP –A and QMHP –C credential.
7. I would like to echo concerns regarding the 8 hours of continuing education being too narrowly defined regarding who can provide the training as mentioned in other comments submitted.