Good Afternoon,

I would like to recommend if applicable, adding a definition for the Clinical Director position in the opening definition section of the document. Within that section, clearly defining requirements, specific duties, and or what would be expected if an agency were to be audited for compliance as it relates to the Clinical Director position from an oversight agency. There is language in the workflow section of this document for the Clinical Director position that may allow for opposing interpretations and misalignment with the Departments intent.

For example, if an agency has an LMHP Clinical Supervisor who oversees the program and executes the duties of a Clinical Director however does not have the title of Clinical Director, would that agency be in compliance? 

For example, if an agency has a part/full-time Clinical Director and no Clinical Supervisors and fully operates remotely through telehealth, would that agency be in compliance?

For example, if an agency were to contract with a Clinical Director who contracts with several other agencies, would that agency be in compliance? 

In my experience/observations smaller agencies for various reasons (mainly financial) often hire differently from larger private and public agencies. I'm not sure if there is a small business impact study being done, however it may help guide some of the requirements and or the structuring of those requirements as we transition in June.