Under the prosed changes, for Therapeutic Behavioral Services an adverse impact will occur for children across the Commonwealth of Virginia. By allowing for fewer mental health services in the short term, and fewer qualified and credentialed counselors in the long term. The direct result will be a decrease in access to mental health services for populations served by DMAS. Today, children and families benefit enormously from quality, child-focused early intervention services to alleviate the life-long effects of adverse childhood events and/or early identification and treatment for mental illness. Removing access to these services will leave our most vulnerable populations more impaired for longer periods of time further impacting their opportunities for successful long-term outcomes. Please recondider Chapter II, Psychiatric Services page 15-16, DMAS requirements regarding provider qualifications for outpatient counseling.