The proposed changes compromises public safety. 2 years experience as a QMHP is not sufficient to act in a supervisory capacity nor substitutes the clinical guidance and skillset of a LMHP for whom the clinical oversight is intended for.

Secondly, a criminal justice degree prepares an individual for a career path in law enforcement. The curriculum does not provide an adequate foundation in the etiology and treatment of behavioral disorders, which is needed given the SMI population that QMHPs are tasked to work with.

Perhaps the CSB needs to explore their staffing and retention concerns through other methods but this proposal is certainly not the ideal solution.