QMHP/Ts are professional staff. This is the highest credential for this level of degree, and they are labeled “Qualified Mental Health Professionals”. Identifying them throughout as paraprofessionals is confusing, and that language should be adapted.

LMHP-Es should be able to function as LMHPs for all roles accept the clinical director role to include supervision, crisis consultation, assessment, etc. This is consistent with legacy service regulations and LMHP-Es are under supervision in order to be able to learn the skills to operate as full LMHPs upon licensure. This is an opportunity to ensure that they are receiving weekly guidance, and it is consistent with the supervision requirements by the DHP. At the proposed rates of services, hiring enough fully licensed staff to offer these services will be nearly impossible providing significant barriers to access to CPST services.

There is inconsistency is section 4.2.1 regarding supervision. In bullet #1 it is mentioned that QMHP types and LMHP-Es must have weekly supervision. However, in bullet #5 it is outlined differently. LMHP-Es should be permitted to provide supervision to QMHP/Ts and BHTs and it should be a monthly requirement as this is consistent with DHP regulations.

Assessments should be, at the very least, permissible as telemedicine-assisted, but ideally through Telehealth. Barriers in rural communities mean that it is often difficult for individuals to access care and virtual options should be allowable. This also supports the significant concern with availability of LMHP-type individuals in the workforce.

90-day face-to-face team meetings for ISP review as well as quarterly progress review requirements are excessive. One or the other makes sense, but requiring both is excessively burdensome to both agencies and the client’s families.

Access to other crisis services should be permitted for safety concerns BUT also should be permitted in geographies with significant geographic spread when the in-person on-call staff cannot get to the client in-person as quickly as mobile crisis response or alternative referrals. While this appears to be more permissible in the crisis mitigation section, it is contradicted in the initial language of 5.3 bullet #5 Additionally, it should be notated how billing works when CPST remains engaged simultaneously with other crisis services.

One barrier under the current services is the requirement that services must be initiated within 31 days. This is consistent in these draft regulations to begin services within 30 days. Language to outline exceptions would reduce burdens for reassessments when/if services are not initiated for reasons outside of provider/client control (i.e., MCOs not providing approvals in a substantial amount of time, client hospitalization, etc.). Audio-only collaboration with client/guardians during this time, should be permissible to provide more flexible service initiation when clinically indicated.

In section 9, #2.b.i. – it restates that providers are not permitted to provide crisis services to someone who is receiving CPST services. MCR specifically is dispatched via geolocation by 988 hubs and declining dispatches to individuals seeking this support would be clinically inappropriate and administratively burdensome on MCR teams to determine. This is also disruptive to smaller communities with limited providers offering multiple services (including CSBs).