I am a Ph.D. candidate in Counselor Education and Supervision at James Madision University, an Instructor in Eastern Mennonite University's MA in Counseling program, and a Resident in Counseling in Virginia. I have participated in training counselors at EMU and JMU, both of which are CACREP accredited Clinical Mental Health Counseling programs. The students who graduate from these programs have provided a minumum of 700 hours of closely supervised clinical service to members of our communites, many of whom live in rural or medically underserved areas and would otherwise likey not recieve any behavioral health services. These students have also recieved high quality classroom experinces through our CACREP accredited programs. Upon graduation, these students are ready to carry out the work of professional counselors under the guidence of a supervisor. For that task, the majority of our students register to become Residents in Counseling, a period (3,400 hours over about 2 years) of closely supervised work. I strongly believe that Residents in Counseling are qualified to provide outpaitent clinical mental helath services and should qualify for reimbursment through Medicaid.

Further, there is an extroardinary amount of need for counseling and psychotherapy for our low-income neighbors and community members, many of whom live in rural and medically underserved communities. As you know well, our behavioral health provdiders are already overburdened by a large and growing need for counseling and psychotherapuetic services. Residents in Counseling assist a great deal in meeting that need. By preventing Residents and Counseling and Supervisees in Social Work from providing outpatitent services through Medicaid, you would drastically reduce the availability behavioral health services in our communities. Please do not do that. 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. The pool of qualified providers is already critically small. 

Thank you for your careful consideration of this vital topic.