EIDBI QSP requirements are set in Minn. Stat. § 256B.0949, subd. 15. A qualified supervising professional (QSP) for Early Intensive Developmental and Behavioral Intervention (EIDBI) must be an employee of an EIDBI agency and must be either a licensed mental health professional or a licensed behavior analyst, or a developmental or behavioral pediatrician, with at least 2,000 hours of supervised clinical experience or training with autism spectrum disorder (ASD) or a related condition, or equivalent graduate coursework.
The QSP is the person the whole benefit is built around. Subd. 2 defines the role as the professional with overall responsibility for the control and direction of EIDBI service delivery, including individual treatment planning, staff supervision, and progress monitoring. Every EIDBI claim is billed under a QSP, and the Department of Human Services (DHS) form every QSP signs says an agency cannot be reimbursed for services provided without one.
Two changes took effect on January 1, 2026: the QSP must be an agency employee, and the agency must meet statutory supervision minimums. This guide covers qualifications, duties, those minimums, the DHS-7120C form, training, documentation, common failures, and the QSP shortage, as of September 2026. For the other roles, see the EIDBI provider requirements guide.
Who can be an EIDBI QSP under subd. 15
The statute gives two pathways. Both require the same 2,000-hour or coursework threshold and both require employment by an agency.
| Pathway | License or credential | Experience requirement |
|---|---|---|
| (a)(1) | Licensed mental health professional (DHS-7120C cites § 245.4871, subd. 27, clauses (1) to (6)) or licensed behavior analyst under §§ 148.9981 to 148.9995 | At least 2,000 hours of supervised clinical experience or training in examining or treating people with ASD or a related condition, or equivalent documented graduate coursework from an accredited university in ASD diagnostics, ASD developmental and behavioral treatment strategies, and typical child development |
| (a)(2) | Developmental or behavioral pediatrician | The same 2,000-hour or graduate coursework requirement |
Three details matter for the personnel file. The behavior analyst pathway requires a Minnesota license, not only board certification; DHS-7120C asks for the license number. The graduate coursework alternative must cover all three named content areas. And DHS-recognized advanced certifications in ABA, DIR/Floortime, ESDM, or RDI can be recorded on the form but, in the form's words, do not by themselves qualify a person as a QSP.
What a QSP does
The statute spreads the QSP's duties across several subdivisions; with the DHS-7120C assurance statement, they are:
| Duty | Source |
|---|---|
| Develop the ITP, or review and complete an ITP developed with Level I or Level II input, and supervise its implementation | Subd. 6(a) and (d); subd. 13(h) |
| Submit the ITP and each six-month progress monitoring for authorization and reauthorization | Subd. 6(e); subd. 7 |
| Deliver or direct EIDBI intervention observation and direction of Level I, II, and III providers | Subd. 13(f) |
| Provide family caregiver training and counseling and take part in coordinated care conferences | Subd. 13(i) and (j) |
| Assume full professional responsibility for all services billed by Level I, II, or III providers under their supervision | DHS-7120C |
| Adapt the evaluation, treatment recommendations, and ITP to the person's and family's culture, values, and language, with the CMDE provider | Subd. 3a |
| Direct all intervention services, and direct higher provider ratio intervention with a Level I provider | Subd. 13(g) |
The QSP does not have to deliver every observation and direction session; subd. 13(f) lets a Level I or Level II provider deliver it. What the QSP cannot delegate is responsibility: the ITP carries the QSP's name under subd. 6(c), and the claim carries the QSP as supervising provider.
Supervision minimums effective January 1, 2026
Laws of Minnesota 2025, 1st Special Session, chapter 9, article 6 amended subd. 16 effective January 1, 2026 to set two minimums that every agency, and therefore every QSP, has to meet:
- Clinical supervision of at least one hour for every 16 hours of direct treatment per person, unless the person's ITP authorizes otherwise.
- Required EIDBI intervention observation and direction at least once per month. It may be delivered via telehealth, but no more than two consecutive monthly required sessions may be by telehealth.
Level-specific rules layer on top. A Level I provider still working toward 2,000 hours under the master's pathway needs observation and direction from the QSP at least monthly. Some Level II pathways require observation and direction from the QSP or a Level I provider at least twice per month, or weekly, until 1,000 hours. The EIDBI documentation guide covers how to log those hours.
Observation and direction is also a billed service, CPT 97155. DHS expects it to be about 20% of total intervention time on 97153, 97154, and 0373T unless the ITP justifies more, and since January 1, 2026 every 97155 request needs individual clinical justification; see the EIDBI billing codes guide.
The January 1, 2026 QSP employee rule
Subd. 15(a) now opens with the words "A QSP must be an employee of an agency." DHS provider news dated December 23, 2025 explained how it reads that phrase:
| Counts as an employee | Does not count |
|---|---|
| A person employed temporarily, part time, or full time by the agency that submits claims for the work | Independent contractors who file a 1099 |
| Billing agencies and consultants who do not provide EIDBI services | |
| People who perform work for fewer than 80 hours in a 12-month period |
The rule ended the model in which one contracted QSP was listed on several agencies' enrollments. The QSP attests to employment on DHS-7120C, and the agency should keep the signed form, the payroll record, and the hours worked in the personnel file.
Compliance note: the 80-hour floor is measured over 12 months, so a QSP who is on payroll but rarely works can fall below it. Track QSP hours the same way you track supervised hours for Level I and II staff, and review the total each quarter.
Enrolling and staying enrolled: the DHS-7120C form
DHS-7120C, revised in February 2026, is an addendum to the MHCP provider agreement (DHS-4138). The QSP initials the license pathway, initials the 2,000-hour or coursework attestation, attaches the current license, and signs an assurance that all services billed under their supervision will be provided by qualified staff in compliance with the EIDBI Benefit Policy Manual. For initial enrollment the form is uploaded with the individual provider application (DHS-4016) through the Minnesota Provider Screening and Enrollment (MPSE) portal.
The form also carries two operational rules. Agencies cannot be reimbursed for services provided without a QSP, and a QSP who leaves must update their affiliation immediately by submitting the Individual Provider Profile Change form, DHS-3535. A claim dated after a QSP's separation that still lists that QSP is a recoupment risk for the agency.
Required trainings for QSPs
DHS's March 2026 Required Staff Training Policy Guidance, written for the provisional license under § 245A.142, lists three required EIDBI trainings for agency staff: Cultural Responsiveness in ASD Services, the DHS Vulnerable Adults Mandated Reporting training, and the Minnesota Child Welfare Training Academy mandated reporting training. It lists ASD Strategies in Action and EIDBI 101 as required for Level III providers or providers enrolled under certain qualifications, and points to the Individual EIDBI Provider Trainings page for additional recommended courses. Older DHS pages refer to the cultural training as Multicultural 101, so check the current course name before recording it.
Subd. 16(a)(11) separately requires the agency to train all staff on the Maltreatment of Minors Act and the Vulnerable Adult Protection Act, including the agency's reporting policy. For a QSP, the training file should also show the continuing education that keeps the underlying license active, since the license is the qualification.
Documenting supervision
Reviewers ask for the supervision record before they ask for anything else about a QSP. A log that will survive a DHS site visit or a pre-payment review shows, for each entry:
- The date, start and stop time, and duration.
- Whether it was clinical supervision or observation and direction, and whether observation and direction was in person or via telehealth.
- The QSP or other qualified provider who delivered it and the Level I, II, or III provider who received it.
- The person served, so the one-hour-per-16-hours ratio can be computed per person.
- What was reviewed or directed, including any protocol change that feeds back into the ITP.
- Signature and credentials.
Keep the log with the session notes and the ITP so the ratio, the monthly minimum, and the telehealth limit can be produced for any person and date range.
Common QSP compliance failures
These are the failures that turn a qualified QSP into a denied claim:
- A QSP listed on the enrollment who was a 1099 contractor, or worked fewer than 80 hours in the year, after January 1, 2026.
- Observation and direction billed without prior authorization, or requested at a level equal to or above direct treatment hours.
- Supervision logs that show total hours but not hours per person, so the 16:1 ratio cannot be verified.
- Three or more consecutive monthly observation and direction sessions delivered by telehealth.
- A QSP name on the ITP that does not match the supervising provider on the claim, or a separation without a DHS-3535 filing.
What a QSP shortage means for an agency
DHS's January 2025 legislative report on EIDBI licensing states that each provider agency must employ at least one QSP, that the number of QSPs working in the state is not growing at nearly the same rate as the number of provider agencies, and that the workforce is being stretched over a larger number of agencies. The report counted 24 QSPs with out-of-state addresses as of November 2024 and questioned how well a QSP who is never physically present can supervise.
For an agency, a QSP vacancy is a billing stoppage. Subd. 17 lets the commissioner grant exceptions to provider qualifications where a documented shortage delays access, if the exception would not compromise safety or treatment effectiveness. An exception must be granted in writing with its expiration date and kept in the personnel file. Agencies without one should plan QSP capacity against authorized intervention hours before adding people to the caseload; the What is EIDBI guide explains how those hours are authorized.
How Trustora helps
Trustora stores each QSP's license and number, supervised-hour or coursework record, DHS-7120C attestation, employment start date, and hours worked in the staff record, and flags a session when the supervising QSP was not an active employee on the date of service. Supervision and observation and direction sessions are logged per person with delivery mode, so the one-hour-per-16-hours ratio, the monthly minimum, and the two-consecutive-telehealth limit are visible for any date range.
The ITP carries the QSP's name as a required field, the claim builder populates the supervising QSP from the staff record, and the pre-claim compliance gate stops a line when the QSP, the provider level, or the 97155 authorization does not match. The one-click DHS audit binder assembles personnel qualifications and supervision logs for a site visit or revalidation request. See the platform overview for the EIDBI module.