These proposed changes are sudden, unexpected, and will have an incredibly large effect on service providers throughout the state as well as those who benefit from outpatient counseling.  Without supervisees and residents on staff to provide outpatient services, it will be difficult to find staff who are interested in providing services in these, often lower paying, positions.  Additionally, this seems to directly contradict the movement of the Virginia Board of Counseling who continues to press for residents to get experience doing masters level work (as opposed to QMHP level work), and yet DMAS limits the possibility for us to do such work.  It is disappointing that these regulatory bodies do not appear to communicate needs and expectations with one another in a way that is beneficial to providers and those whom we are trying to serve in our community.  This will amount to a number of residents and supervisees losing jobs and an even larger number of outpatient recipients losing much needed outpatient therapists with whom they work well and trust.