These regulations do not align with current DMAS regulations, which allow for QMHP-As, QMHP-Cs, or QMHP-Es to complete, sign and date ISPs within 30 days of most non-emergent completed intakes.  These same individuals are also allowed to review, evaluate and update the ISP every three months.

These regulations are a bit unclear.  These new regulations state in one place that "the assessment and development of a service plan must be completed and directed by a licensed mental health professional, but the QMHP can implement the plan."  Within the same paragraph, it also states that "DBHDS regulations indicate that the service plan can be signed by the person implementing the plan - which could be a QMHP if the services recommended by the licensed protessional are rehabilitative support services."

This is extraordinarily confusing and apparently conflictual language.  If only licensed or license-eligible professionals can complete ISPs, then the shortage of these individuals in the Commonwealth will force many programs to close and individuals to go unserved or underserved.  If the requirement is to allow QMHPs to complete the plan but have licensed (or eligible) staff sign the plan, this language does not accomplish that aim.

As healthcare, including behavioral healthcare, moves to recovery-oriented and community-based models, a move to unnecessarily restrict the work of QMHPs appears designed to restrict access to care by limiting the number of eligible providers.  I encourage the Commonwealth to recognize the knowledge base that exists in the QMHP workforce - which will be in great demand in coming years.