The new design significantly undermines the role of the QMHP and their licenses and puts all the weight on LMHPs.  Also the rates are dropping for payback, yet we have to hire LMHPs in the roles of QMHPs  ( who make a higher pay grade)... ?   How is this sustainable budget- wise?  None of it makes sense.   Also, with the new regs for Residential services, so many of our most vulnerable individuals are going to lose services and will be put back on society's shoulders, mostly cycling back in and out of hospitals and jails.