MST Services and the research that backs the model of MST is based on services provided by Master's level clinicians and some highly skilled bachelor's level clinicians.

MST will not only be regulated by the state, but also involves external consultants and MST Services to provide oversight of each team.  Why do we feel it is necessary to require LMHP-E and LMHPs to do this work? Who can convince DHP that this model does not require that level of staffing.  Who can convince DHP that this level of workforce is not viable?

Virginia may have over 13k licensed individuals in behavioral health and substance abuse, but it is 2021 and many are opting to provide outpatient telehealth services from home, open their own practice, work for an MCO, work for the Govt in a Supervisory capacity, work in hospitals or residential facilities, etc.  Most have done their time in a boots on the ground position, and DHP folks should understand that....... they too have been there. What gives?
The level of supervision and oversight to maintain the fidelity of the model should be enough. 

Please reconsider the wording of the qualifications, by not fitting MST staffing into the QMHP box.  Or, atleast consider allowing Master's level clinicians to count for more than a simple QMHP.  MST.......and FFT will not be successful or viable in Virginia if this is not considered.