I agree with previous comments posted that the limitations of the QMHP certification should be expanded.  At a time when mental health beds are at an all time low and a significant proportion of mentally ill individuals end up in the justice system, we should not be creating an artificial bottleneck concerning access to treatment providers as well.  Therefore I concur with the following  recommendations:

There should not be two QMHP credentials.

 Any and every mental health professional who meets the education, experience, and training requirements should be eligible to register and KEEP the QMHP title.

Furthermore, the mandate in the reg that every person who seeks services of a QMHP would need a formal "service plan" is problematic. An organization's clinical supervisors can make those decisions based on the population and particular cases served.

Lastly, clinical supervisors should decide the QMHP's services and roles within an organization and its structure, based on professional standards of practice, agency policies, existing laws and regs, and the QMHP's individual skills, experience, and training.