SUPPORT Consistency of Minimum Age Requirements for Unlicensed Behavioral Health Staff

MHA AZ and other behavioral health advocates ask that you SUPPORT the minimum age of unlicensed behavioral health staff working in AzDHS licensed Health Care Institutions be consistent with the minimum age requirements of u nlicensed staff in all other AzDHS licensed Health Care Institutions, Community Service Agencies, and DD Group Homes.

Arizona Health Facility Licensure rules require all Behavioral Health staff to be at least 21 years of age or older.  No other licensed setting in AZ require unlicensed health facility staff to be 21; in all other licensed facilities unlicensed staff may be age 18 or the Licensee is given discretion to determine staff qualifications.  This differential standard is a barrier to entry into the profession, has inadvertently restricted access to Young Adult Peer Support, and can contribute to the stigma surrounding behavioral health services.
Except for Behavioral Health services in Health Care Institutions, virtually all other AZ settings allow unlicensed staff to be age 18 or allow the licensee to determine the appropriate qualifications for staff, which could be age 18.  We have found no law, data, or research to support a higher age for unlicensed behavioral health staff than for other unlicensed health or human service staff.
To fully integrate behavioral health with physical health, differential standards and barriers to entry into the profession should be removed when there is no basis in law or research to support a standard. The staff age requirements in behavioral health facility licensing rules and skilled nursing facility rules should be amended to be consistent with other health care licensing standards and should no longer require unlicensed behavioral health staff to be 21. 

Mental Health America of Arizona