Comment #3 - Practical Feedback

Residents Serving as Clinical Directors

We want to acknowledge the improvement in the policy of allowing LMHP - Residents who are more than halfway through their hours to serve as clinical supervisors for a time! There is great potential in this policy to genuinely improve the quality of services while also supporting agencies with staffing and competitive hiring in the field. Here are a few thoughts on and recommendations for this policy:

• The provision to temporarily allow LMHP-Types to serve as Clinical Supervisors is a tremendous support for smaller and/or more rural agencies who will face a challenge in staffing enough licensed people to meet the requirements of the previous drafts! We agree that there is a need for a licensed person to serve as the Clinical Director of the program; all clinical programs should have a licensed individual supervising, and we believe that the provision for allowing LMHP-Types to serve in that role should end in 2029. 

• One request is to extend the allowance for LMHP-Types who are more than 50% done with their hours and who have a certain amount of experience with CPST or related populations to serve as CPST Clinical Supervisors under the direction of a licensed CPST Clinical Director. There is justification for this under the definition of Collaborative Behavioral Health Services (§ 54.1-3500). Additionally, LMHP-Types will still be required to complete 4 hours of supervision-related activities including at least 2 hours of supervision with the licensed Clinical Director.

• Extending this provision will 

1) Increase the available workforce for community-based services 

2) Provide career advancement opportunities for residents to allow smaller, rural agencies to remain competitive in the job market and 

3) Increase the likelihood of LMHP-Types continuing in community-based roles once they have acquired their license.

• I do appreciate and agree with the desire for licensed people to supervise and direct the CPST program. However, there need to be reasonable ways for agencies to fill these roles when licensed people may not be available -OR- when a very capable resident is ready for career advancement. There are sufficient ways to hold agencies accountable for supervision of residents. Examples include maintaining requirements for oversight by licensed individuals including signatures on documents like the CANS assessments and Treatment Plans; consistent supervision; and availability of an LMHP for consultation at all times. These elements are already required for CPST and are sufficient means of accountability that would allow LMHP-Types to effectively serve as Clinical Supervisors.

Level of Oversight and Requirements on Providers

There seems to be great efforts for collaboration between different agencies such as DMAS, DBHDS, the MCOs, CEP-VA, and PracticeWise! However, we have some concerns that so many agencies will have oversight and that the administrative burden needs additional scrutiny. Here are some specific examples:

• Section 7.4 - CEP-VA CPST Finder - Having to maintain and update individual staff’s information in a 3rd party portal as part of the regulations is cumbersome and potentially leads to issues with MCO enforcement. What if an MCO looks up a staff’s info into the CEP-VA CPST Finder but CEP-VA hasn’t updated their portal? How often does the portal need to be updated? What are the potential consequences of not updating the portal? Can MCOs use that requirement to deny services or to recoup funding? 

  • Recommendation: Please change the requirement so that the CEP-VA Finder tool only requires registering programs and locations as opposed to specific staff. This is more feasible and allows for less chance of admin errors. Only require providers update their Programs and Locations within the Look Up Tool as opposed to individual staff (especially since QMHPs have a high level of turnover which will cause extra work on CEP-VA and Providers since providers are constantly updating their staffing rosters).