Hello. I am writing a comment in order to ask if anyone can point me in the direction to find if a QPPMH or paraprofessional individual will still be able to provide and bill any community mental health services (MHSB, PSR, Crisis Stab,etc.?) I haven't seen any information on this, just the the information stating what a QMHP will have to do to register. Does this mean that QPPMH individuals can no longer bill CMH services? Thank you in advance.

These regulations do not align with current DMAS regulations, which allow for QMHP-As, QMHP-Cs, or QMHP-Es to complete, sign and date ISPs within 30 days of most non-emergent completed intakes.  These same individuals are also allowed to review, evaluate and update the ISP every three months.

These regulations are a bit unclear.  These new regulations state in one place that "the assessment and development of a service plan must be completed and directed by a licensed mental health professional, but the QMHP can implement the plan."  Within the same paragraph, it also states that "DBHDS regulations indicate that the service plan can be signed by the person implementing the plan - which could be a QMHP if the services recommended by the licensed protessional are rehabilitative support services."

This is extraordinarily confusing and apparently conflictual language.  If only licensed or license-eligible professionals can complete ISPs, then the shortage of these individuals in the Commonwealth will force many programs to close and individuals to go unserved or underserved.  If the requirement is to allow QMHPs to complete the plan but have licensed (or eligible) staff sign the plan, this language does not accomplish that aim.

As healthcare, including behavioral healthcare, moves to recovery-oriented and community-based models, a move to unnecessarily restrict the work of QMHPs appears designed to restrict access to care by limiting the number of eligible providers.  I encourage the Commonwealth to recognize the knowledge base that exists in the QMHP workforce - which will be in great demand in coming years. 

As a professional Nationally Certified Counselor it bothers me that my identity as a qualified mental health professional is being called into question. I worked diligently on my education, from an accredited program, to be allowed to serve others in my community. I choose to work with returning citizens in the Common Wealth to help with the navigation of mental illness and criminal behavior. After my graduation I applied for residency which I actively engage in on a weekly basis, I have completed the 'process' that the Common Wealth has required to begin working in my chosen profession and now I am being told that I am not qualified? I have as much training as any QMHP working in the Department of Behavioral Health Services and DBHS Licensed Units, I deserve to be called a qualified mental health professional. We have a QMHP shortage in the Common Wealth and a greater shortage of individuals who are willing and able to work with the offender population I do not see where it benefits the Common Wealth to make it more difficult for us to do our jobs.

I am a City of Alexandria (CoA) employee falling under the purview of The Virginia State Department of Behavioral Health and Developmental  Services (DBHDS) and the Licesing Board. I am delighted that existing QMHPs' will be Grandfathered in.

What I do not agree with is that: The QMHP-A Emergency Regulation, sponsored and requested by (DBHDS) wishes to saddle The City of Alexandria Community Service Board(s) employees with all fees.

This regulation goes out of its way to obfuscate the regulation disregarding the purpose of the Law and or regulation. It is not clear at all by what is meant by QMHP-A shall only operate under the supervision of DBHDS as an independent contractor or an employee of The City of Alexandria that is a under The DBHDS. If  The State or City owns the license then they should pay the fees.

Is the QMHP-A license the property of the individual or not? 

If not then why burden the individual with the cost that does not provide any benefit except to work for or under DBHDS or C0A? It seems like indentured servitude. It is very much like the general store in a company town.

The rule seems very much like the Obama Health Care rule requiring the young to buy health insurance or be fined.

 

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The CMHRS Manual states that only one QMHP eligible staff (QMHP Trainee) is allowed for each full time licensed staff and the number of QMHP Trainees cannot exceed 5% of total clinical adult staff within an agency. These limitations significantly impact our ability to fill our vacant positions. I recommend that these limitations be removed and that each organization be allowed to manage their own capacity for supervising QMHP-Trainees. If the training guidelines, including the requirement for 8 hours of continuing education and the QMHP and QMHP-Trainee roles are clearly defined, along with scope of practice and types of services each role can provide, then allow each agency to determine their own capacity for number of QMHP-Trainees and number supervised by each LMHP.