I am a student at James Madison University in the Clinical Mental Health Counseling program. This is a second career for me. I am also a lawyer and served as a public defender in Virginia for 5 years. In that role I represented many indigent clients who suffered from mental illness and/or substance abuse. I witnessed the lack of services available to them and the taxpayer dollars wasted on detaining, jailing and imprisoning these adults and children who would have been much better and inexpensively served through outpatient psychiatric services. Many of those adults and children might have become contributing members of society rather than a constant drain on our budget.

Part of the challenge in providing services for low income families and individuals is access. The proposed changes to "Psychiatric Services" Chapter II eliminates the Medicaid reimbursement of Counselors-In-Residency providing ?supervised ?services to those in need. In my CACREP-accredited counseling program at JMU we receive 3 full years of training and education including 1 year of internship before we become Residents. As a Resident, I will spend 4000 hours counseling under supervision before I can take my exam to become an LPC. Our training is rigorous and comprehensive, as are all CACREP-accredited programs. Perhaps instead of eliminating all Residents, a recommendation would be to include that all Residents must be from CACREP-accredited programs.

If all Residents are eliminated it will sever on-going counseling relationships, reduce the number of people served, and inevitably cost all of us more through the court and prison system. I am capable and I am driven to serve this population. I made this career change precisely for that reason. As a public defender and court-appointed attorney, I realized a better and cheaper way to provide long-lasting help for this population was through treatment. Please do not hinder our ability to serve in this way. We may all disagree about policy matters surrounding low income populations, but we can all agree that jail and prison are expensive. Preventative treatment, counseling, and substance abuse treatment work. These changes would further frustrate access to effective services. Please reconsider.