The following summarizes feedback regarding the "Additional Documentation Requirements and Utilization Review" section received from our members since the draft policy was released:

Excessive LMHP Documentation Requirements

• LMHPs must review and sign off on all client documentation across the agency, including progress notes and treatment records, which is viewed as excessive and unmanageable.
• The expectation that LMHPs handle both supervision and documentation review for every client drastically increases workload and limits their availability for direct care and oversight.

High Administrative and Non-Billable Burden

• The draft requires extensive administrative tasks, including detailed progress notes for every service, monthly LMHP reviews of all non-licensed staff documentation, ISP signatures from youth/guardian, the entire CPST team, and the LMHP Supervisor, and 90-day face-to-face ISP reviews and annual CEP-VA reporting. These expectations create a significant amount of non-billable time that many agencies cannot absorb.

Workforce Utilization Constraints

• By requiring LMHPs to review and sign all documentation, the policy eliminates the ability to delegate routine paperwork review to trained QMHPs.
• This restriction reduces efficiency and undermines the role of QMHPs and other paraprofessionals in team-based care.

Practical Implementation Challenges

• School schedules make it difficult to coordinate required synchronous ISP meetings and signature collection.
• The overall documentation and review process is unclear and likely to create compliance risks due to unrealistic expectations.