Section: 4.4 Collaborative Behavioral Health Services/Supervision of team members

• Minimum face to face team meeting weekly- The updated policy further defined the requirements for the face-to-face weekly meetings and seemed to add more requirements versus relaxing.  The updated policy seems to include much of the same requirements as Assertive Community Treatment without the corresponding rate structure needed to sustain.

Section: 4.5 Supervision of Individual Staff

• Weekly supervision for all non-licensed staff.  This remains overly administratively burdensome and limits time available for direct service provision.

Section: 4.5.1 Supervision of LMHPs

• Added that clinical supervision for licensure only meets the supervision requirements if provided by an LMHP employed by the CPST agency.  Please reconsider this added restriction.

Section: 4.5.2 Supervision of LMHP-R, LMHP-RP or LMHP-S

• The updated draft indicates these provider types must receive a minimum of 2 hours of supervision with LMHP Clinical supervisor per month and a minimum of 4 hours a month in “supervision-related activities”.  Part-time with caseloads less than 10 shall receive minimum 1 hour of supervision and 2 hours in “supervision-related activities”.  This adds additional administrative burden, operational costs, and limits time available for direct service provision.

Section: 4.5.3 Supervision of QMHPs, QMHP-Ts, BHTs

• The number of supervision hours is excessive, particularly for the QMHPs

Section: 4.5 Staff Caseloads

• The staff caseloads outlined create an overly-complicated, fiscally-infeasible requirements which are a barrier to the ability to provide this service. 
• The requirement for “formal log of caseload” every six months as the compliance requirement increases administrative burden and is operationally difficult based on the fluid nature of staff caseloads.  Although a few words were changed in this section, it is unclear how the changes addressed the concerns expressed.
• Adds wording that we need to document and maintain documentation for audit which discloses if an employee works for another Medicaid outside employment.
• Billable units limit further restricts the provision of service and the flexibility to maintain successful program model.  The updated draft increased to 600 CPST unit limit but kept that this is across all/any agencies which a staff member works.  This limit is untenable as one agency cannot limit or restrict another agency’s staff caseload.
• LMHP prohibited from providing supervision/oversight to more than 120 cases in a month, but then goes on to provide wording of when 120 would not be appropriate.