3.3.3  There does not seem to be much substance to this section.  Delete?

4.2—What is the definition of a full time Clinical Director?  Can the clinical director only oversee CPST?  That is not a reasonable structure for many providers.  Large CSB’s often have several layers of managerial oversight before it reaches the Clinical Director. 

4.3  “All LMHPs shall have the ability to provide in-person services.”  What is the intent  in person services?

“A senior-level LMHP (may be the Clinical Director or another LMHP), with a minimum of two years experience working with individuals with a Serious Mental Illness (SMI) or Serious Emotional Disturbance (SED), trained in working with individuals with SMI or SED, shall be available to all staff 24 hours a day, seven days a week for consultation on an as needed basis”. Another example of increased administrative burden without compensation.