18 VAC115-80-40

B1/B2

All Human Service master's degrees (including psychology, sociology, social work, counseling, substance abuse, marriage and family therapy, etc.) should require the same number of experience hours, 500 hours.  Given the scope of QMHP-A work and requirement of working within a DBHDS licensed program, the requirement of 1,500 hours is overly limiting and restrictive.

B2

Human Service Degrees must be defined to include sociology.  Based on the grandfathering period and first year of registrations, what are the degrees those who have registered have?  This information is needed to ensure there appropriate degrees are included in the regulations.   Note that individuals with varying degrees have the abilities to perform the QMHP-A scope of work based on having experience and the supervision within a DBHDS licensed program.

C1

The requirement for supervision to be by a licensed mental health professional:
1. Devalues the experience and registration of a QMHP-A. 
2.  Places another supervision burden on LMHP's, when there is a known shortage of LMHPs in Virginia.  Those providing the services, QMHP-A's, have the hands-on-experience of providing service, which is invaluable for those working towards registration. 
3.  Has potential consequences of costs for services increasing; and
4.  Has lasting impact on Virginia's ability to ensure development of QMHP-As; thus, assuring the availability of services to Virginias for years to come.
 

Therefore, the requirement of who must supervise a QMHP-A, with the degrees listed in B1, B2, B3, B4, B5 should be changed to be a supervisor who is: 
1. A registered QMHP-A with at least 4 years of experience post qualification as a QMHP-A (note requirement for 4 years of experience as this ensures seasoned QMHP-A's have opportunity impart knowledge, skills and abilities);
2.  A Licensed mental health professional in Virginia or other jurisdiction; or
3.  Registered as a resident or licensed eligible mental health professional in Virginia. 
 

This change is required to ensure sustainability for providing (and individuals receiving) quality, direct mental health service in Virginia.

C2

It is not clear how this is should be documented or will be able to be monitored.  This seems like something that belongs in the DMAS or DBHDS regulations about how services are delivered rather than something needed for registration as a QMHP-A.

18 VAC 115-80-50

B1/B2

All qualifying Human Service master's degrees (including psychology, sociology, social work, counseling, substance abuse, marriage and family therapy, etc.) should require the same number of experience hours, 500 hours, with the ability to include internship/practicum hours.  Given the scope of QMHP-C work and requirement of working within a DBHDS licensed program, the requirement of 1,500 hours is overly limiting and restrictive.

B2

Human Service Degrees must be defined to include sociology.  Based on the grandfathering period and first year of registrations, what are the degrees those who have registered have?  This information is needed to ensure there is appropriate degrees are included in the regulations.   Note that individuals with varying degrees have the abilities to perform the QMHP-C scope of work based on having experience and the supervision within a DBHDS licensed program.

C1

The requirement for supervision to be by a licensed mental health professional:
1. Devalues the experience of a QMHP-C's. 
2.  Places another supervision burden on LMHP's, when there is a known shortage of LMHPs in Virginia.  Those providing the services, QMHP-C's, have the hands-on-experience of providing service, which is invaluable for those working towards registration. 
3.  Has potential consequences of costs for services increasing; and
4.  Has lasting impact on Virginia's ability to ensure development of QMHP-Cs; thus, assuring the availability of services to Virginias for years to come.
 

Therefore, the requirement of who must supervise a QMHP-C, with the degrees listed in B1, B2, B3 and B4 should change to be a supervisor who is: 
1. A registered QMHP-C with at least 4 years of experience post qualification as a QMHP-C (note requirement for 4 years of experience as this ensures seasoned QMHP-C's have opportunity to impart knowledge, skills and abilities);
2.  A Licensed mental health professional in Virginia or other jurisdiction; or
3.  Registered as a resident or licensed eligible mental health professional in Virginia. 

This change is required to ensure sustainability for providing (and children receiving) quality, direct mental health service in Virginia.

C2

It is not clear how this is should be documented or will be able to be monitored.  This seems like something that belongs in the DMAS or DBHDS regulations about how services are delivered rather than something needed for registration as a QMHP-C.