Requiring QMHP practitioners to have another team member present in-person on MCR dispatches will put a burden on an already-taxed workforce. Team-compositions should be allowed to to function in a hybrid in-person and telehealth capacity. 

In an already intense staffing shortage for licensed professional mental health providers requiring this level of professional licensure will burden a severely burdened system and reduce access to care. This is not a sustainable thought while good intentioned and figuring out alternative ways to enhance service delivery models should be considered. 

Separating the supplemental coding for TDO is an important step in ensuring that every service that is being provided to a PIC (person in crisis) is able to explore the billing needs to ensure that quality staffing can be hired is critical to service delivery which enhances the experience or the PIC and ensures support. TDO reimbursement rate being reduced to 4hours is not conducive to the workflow that occurs for TDO processes and due to amount of time spent when managing a critical need needs to be considered. It should remain that the 8hr supplement in order to provide the proper service delivery model of care.