Thank you for the opportunity to provide public comment.

QMHPs are essential to the behavioral health workforce responsible for arranging, coordinating, monitoring, evaluating, and advocating across systems to address clients' complex needs. They are most directly involved with helping clients complete the action steps on the ISP. Allowing seasoned QMHPs to provide supervision hours for QMHP-Ts benefits the BH system in two ways. First, it will improve workforce retention by creating career advancement opportunities. Second, many LMHPs have never worked solely within the QMHP scope of practice. Rather, LMHPs scope of practice focuses more narrowly on clinical assessment and intervention. The presumption that LMHPs are uniquely able to impart competency and professional identity to QMHPs simply by virtue of clinical training is misguided. LMHPs provide supervision that highlights the broader clinical and ethical context of client care. However, seasoned QMHPs speak more directly to the application of theory into practice in real-time. Seasoned QMHPs can better assess the QMHP -T within the scope of practice and promote professional identity unique to the QMHP role.  

Curricula in Criminal Justice and Sociology address human behavior, social psychology, societal issues, and the legal system - the major themes that human services agencies address in their mission. For many individuals graduating from undergraduate and graduate human service programs, there is a gap between theory and practice that on-the-job training fills. Quality assurance mechanisms are in place at the state level that defines professional development and training for QMHPs. The Board of Counseling outlines continuing education requirements, and the DBHDS Office of Licensure defines training standards to which all direct service employees at licensed facilities must adhere. With these factors in mind, individuals with degrees in Sociology and Criminal Justice are equipped and capable of holding the QMHP credential.