Virginia Regulatory Town Hall
Agency
Department of Behavioral Health and Developmental Services
 
Board
State Board of Behavioral Health and Developmental Services
 
chapter
Rules and Regulations For Licensing Providers by the Department of Behavioral Health and Developmental Services [12 VAC 35 ‑ 105]
Action Add OTs, OTAs, and editing definitions of QMHP, QMRP, Paraprofessionals per Ch 136 and 418 (2017)
Stage Emergency/NOIRA
Comment Period Ended on 2/7/2018
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2/5/18  2:24 pm
Commenter: Ruben Quiles

QMHP-A
 

I am a City of Alexandria (CoA) employee falling under the purview of The Virginia State Department of Behavioral Health and Developmental  Services (DBHDS) and the Licesing Board. I am delighted that existing QMHPs' will be Grandfathered in.

What I do not agree with is that: The QMHP-A Emergency Regulation, sponsored and requested by (DBHDS) wishes to saddle The City of Alexandria Community Service Board(s) employees with all fees.

This regulation goes out of its way to obfuscate the regulation disregarding the purpose of the Law and or regulation. It is not clear at all by what is meant by QMHP-A shall only operate under the supervision of DBHDS as an independent contractor or an employee of The City of Alexandria that is a under The DBHDS. If  The State or City owns the license then they should pay the fees.

Is the QMHP-A license the property of the individual or not? 

If not then why burden the individual with the cost that does not provide any benefit except to work for or under DBHDS or C0A? It seems like indentured servitude. It is very much like the general store in a company town.

The rule seems very much like the Obama Health Care rule requiring the young to buy health insurance or be fined.

 

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CommentID: 63408