As significant as credentials are, they serve as a process indicator, not an outcome indicator. In the absence of solid outcome measures, certain process measures – used as proxies for outcomes – are useful and necessary. This is the case with credentialing.

One way to address the process vs. outcome argument is not to eliminate all process indicators, but to acknowledge their limited role while developing good outcome indicators. Having refinanced behavioral health care through Medicaid waivers or other means, many states see regulatory change as part of the second generation of reform. They have turned their attention to an overhaul of state certification of behavioral health services and providers, with an eye toward replacing process requirements with outcome requirements.

For example, the Ohio Departments of Mental Health and Alcohol and Drug Addiction Services are in the process of revamping their respective certification standards to focus on service outcomes. The State of Washington Department of Social and Health Services, which has a similar regional authority structure, has issued a special protocol on County-Designated Health Professionals, focusing on practice guidelines.⁹ To that end, state rules and regulation ought to be reexamined every few years, especially those within the purview of state regulators. Both payers and regulators of behavioral health services need to understand that what worked in the past may not work in the present or the future.