PCPA has learned that the Office of Mental Health and Substance Abuse Services (OMHSAS) will no longer approve registered nurses (RNs) as mental health professionals or facility directors in Long Term Structured Residences (LTSR). RNs approved as mental health professionals or program directors prior to November 1, 2002 are "grandfathered" in and may continue to be counted in the staffing ratios and as program directors. After that date, RNs will not be approved as mental health professionals or program directors for LTSRs.
OMHSAS recognizes that this is a change in policy interpretation and is citing the LTSR regulations in Chapter 5320.43 as the basis for this decision.
Chapter 5320.43 Program director and direct-care staff qualifications.
"(a) The program director shall:(1) Have a Master's degree in a generally recognized clinical discipline and 2 years of mental health clinical experience...
(b) A mental health professional shall:
(1) Have a Master's degree or higher in a generally recognized clinical discipline and 1 year of mental health clinical experience..."
Providers should expect a similar policy regarding RNs to be applied to outpatient and partial hospitalization services in the next year. At this time, however, no such policy interpretation has been made regarding outpatient and partial hospitalization services.
This interpretation is reportedly creating difficulties for the effective delivery of service. PCPA is researching this issue and will provide more information as it becomes available. Members may contact Rebecca May Cole at the Association.