Sociology used to be an approved degree and I believe that sociology should still be an approved degree.   Sociology is as related to this field (if not more so) than other degrees that were included on the list of approved degrees.  Eliminating sociology as a approved degree substantially limits the pool of qualified available candidates for this credential.

The registration and supervision of qualified mental health professionals is certainly beneficial for the individuals receiving behavioral healthcare services.  However, it is a discouragement for those who work with both adults and children to have to register as both a QMHP-A and QMHP-C and pay the full fee for each of these credentials.  It would be helpful to have a reduced fee if registering as both a QMHP-A and QMHP-C.  This would serve as an incentive those with the most experience and knowledge in a wide range of ages.  As an alternative, consider extending the age range of QMHP-Cs to serve individuals up to 21 years of age.

I share the concerns that others have expressed about the delay we will experience in hiring providers.  this is bacuase applicants will need to be registered as QMHPs before we hire them in order that we can bill for their services.  Also; I would express concern about the expectation that Licensed or Licensed-Type individuals must supervise the day-to-day operations of services provided by QMHPs.  Licensed individuals are scarce, especially since CCC Plus has been implemented and MCOs have recruited many of our licensed staff.  In addition, many of the programs that are employing QMHPs are viewed as ‘non-clinical’ by both DMAS and the MCOs, but CCC Plus is requirning LMHP or LMHP-Types to sign all authorizations for CMHRS services..

I would like to echo concerns regarding the 8 hours of continuing education being narrowly defined regarding who can provide the training.  Many of the organizations providing behavioral health services in the communities in Virginia already have extensive continuing education requirements under the DBHDS Licensure regulations.  I believe that these organizations should be allowed to provide the required continuing education to their staff in accordance with their annual compliance with DBHDS Licensure regulations.  I would also request that the regulations clarify the nature and extent of supervision that LMHPs and LMHP-Types must provide to registered QMHP-A’s and C’s.  Must the LMHP, or LMHP-Type, be the direct supervisor of the QMHP?

Thank you in advance for your consideration of these comments when updating these regulations to better meet the needs of all individuals receiving behavioral healthcare services in Virginia.