The following summarizes feedback regarding the "Required Service Oversight and Supervision" section received from our members since the draft policy was released:

Supervision Intensity and Feasibility

• The required four hours of monthly supervision for LMHP-Rs, LMHP-RPs, and LMHP-Ss is viewed as excessive.
• Weekly supervision for non-licensed staff and monthly documentation reviews add heavy administrative burden.
• The 1:9 supervision ratio restricts staffing flexibility, especially for agencies relying on part-time or relief staff.
• Smaller agencies question how a single LMHP who also serves as Clinical Director/Supervisor can receive required supervision.
• The combined supervision and documentation expectations make it difficult for agencies to remain compliant and operational.

Workforce Shortages and Structural Strain

• There is a statewide shortage of LMHPs, particularly in rural and school-based settings, making compliance nearly impossible as proposed.
• The requirements could intensify competition for LMHPs, increasing costs and destabilizing the provider network.
• The rules disregard the established supervisory capabilities of LMHP-types and QMHPs, creating barriers for licensed-eligible staff to advance.
• Agencies report current hiring pressure across regions as organizations compete for the limited pool of licensed clinicians.

Tele-Supervision Limitations

• The requirement that 50% of supervision be in-person (face-to-face) is impractical given travel distances and dispersed service areas.
• Restricting tele-supervision contradicts current DMAS definitions of “face-to-face” and ignores proven telehealth effectiveness.
• Agencies conducting services across large geographic regions (1,000–2,000+ square miles) say travel demands make these requirements unworkable.
• Concerns about confidentiality protocols for tele-supervision documentation remain unresolved.

Regulatory and Policy Conflicts

• The proposed standards conflict with Board of Counseling regulations that permit LMHP-types and some QMHPs to supervise others.
• Supervision and oversight requirements diverge from state licensing board standards and recognized national tele-supervision certifications.
• Unclear definitions of “clinical director” and “supervision” create confusion about roles and responsibilities.
• The requirement for licensed practitioner oversight undermines existing regulatory structures and workforce development pathways.

Operational Burdens and Compliance Risks

• Agencies question the evidence base for the in-person supervision mandate.
• Staff unit limits (504/month) constrain scheduling flexibility and coverage for school-based programs.
• 24/7 crisis coverage expectations are incompatible with labor law and lack compensation mechanisms.
• Overlapping roles (LMHPs required to provide both administrative and clinical oversight) add to workload strain.