I fully support the registration of QMHP's in Virginia, as a means of better verifying experience and education among professionals in our field.  I have the following comments regarding the process and the emergency regulations pertaining to the process:

1. Clarification of LMHP/Type supervision – TDT regulations require weekly individual/group supervision of staff providing TDT services.  Will this meet the requirement of a QMHP-Trainee, or will the LMHP/Type have to provide daily supervision?  Will the LMHP/Type have to be present at the location to provide constant supervision of the QMHP-Trainee?
2. The requirements for past experience indicate that the applicant has to have had experience under an LMHP/Type who is registered with the board – how will this impact applicants coming from out of state, from Residential Treatment Centers, from internships, etc?  Previously, these applicants met the minimum standard to be hired, based on confirmation of their experience, per the DBHDS and DMAS regulations. 
3. I echo the feedback that the age for QMHP-C should be extended to 22, as there are many individuals being served in public schools, and other settings identified as being for “children”, through the age of 22 due to their emotional and cognitive needs, Special Education Status, etc. 
4. I echo the feedback that there should be a discounted rate for someone registering as both a QMHP-C and QMHP-A.
5. I echo the need for clarification of supervised experience, and how that experience is to be documented when hiring new staff, as well as for staff hired as a QMHP-Trainee.
6. I echo the concern that Sociology has been removed as an approved degree area.  A professional with a degree and Sociology and the minimum experience as previously defined by DBHDS and DMAS should still be able to qualify as a QMHP- C or A.
7. It would be helpful for all forms pertaining to QMHP registration (for C, A or Trainee) to be available for download/review in a PDF format on the website, as the forms for licensure registration currently are, in order to ensure that all documentation and appropriate information is available when the employee is registering.  It will also help us as employers to prepare the employee/potential employee for the process.  I requested the forms from the Board of Counseling in January, and was told to review the Handbook, but the forms are not included in the Handbook.
8. I echo the comments and concerns regarding the requirement for CEU's for QMHP level staff, and hope that internal trainings can also be counted toward these CEU requirements.