I am revising the comments made by my colleuge, Jeff Lown, because he accurately summarizes my sentiments and im short on time. 

I am a Resident-in-Counseling with 4 years in the community mental health field. I have, as most all of my fellow residents-in-counseling have in CACREP-accredited counseling programs, been extensively trained in the assessment of mental health diagnoses and effective interventions from a wide-range of disciplines to treat such diagnoses. As such, the Board of Counseling has validated and asserted the resident's ability to provide outpatient therapy in the Commonwealth of Virginia.

There is an extroardinary amount of need for counseling and psychotherapy for children and disadvantaged individuals - mental illness knows no privilege, in fact we know that low-income individuals, those that require Medicaid assistance for their health needs, are particularly vulnerable to developing mental illness, or to have a preexisting mental health diagnosis. The proposed changed regulations would needlessly and severely limit access to robust mental health care to the most most vulnerable citizens of the Commonwealth. They should be amended to allow that residents-in-counseling and supervisees in social work can provide outpatient psychiatric services, as the pool of qualified providers is already critically small.