The only way to provide this service and make money is to be dishonest and not follow the regulations as written.  You cannot adequately pay the LMHP to do the things that you are asking them to do.  We are living in a world where telehealth has taken many of our LMHPs out of the field doing direct services, particularly in services outside of the office.  This is unrealistic.  Please listen to the feedback and make meaningful changes or the individuals that need these services will be the ones to sufffer when no services exist in the community for them.