The proposed regulations would demonstrably increase barriers to access mental health services for children of low-income.  While the regulatory goal of increased quality of care is laudable, the proposed regulations will simply axe programs without licensed professionals with no regard for the quality of services, whether licensed or unlicensed.  

For social workers and other allied professions who provide mental health services to children, this regulation would prevent anyone seeking licensure from developing the necessary experience in child mental health to attain licensure.  Education, licensing, and supervision costs are already high in Virginia.  If we want to have enough social workers to meet the needs of our children, we need to make sure we can nurture a sustainable workforce.  These regulations would do a great deal of damage in that effort.