To echo my colleagues and borrow from their language. I, too, am writing to request that DMAS’ proposed changes to provider qualifications as outlined in Chapter II, pages 15-16 be rejected. Such changes will substantially decrease children's access to mental health counseling in the state of Virginia, counseling that is critical to children's well-being.

I am a Counselor Educator and as such am aware that residents have been extensively trained in the assessment of mental health diagnoses and effective interventions from a wide-range of disciplines to treat such diagnoses. As such, the Board of Counseling has validated and asserted the resident's ability to provide outpatient therapy in the Commonwealth of Virginia.

There is an extroardinary amount of need for counseling and psychotherapy for children and disadvantaged individuals - mental illness knows no privilege, in fact we know that low-income individuals, those that require Medicaid assistance for their health needs, are particularly vulnerable to developing mental illness, or to have a preexisting mental health diagnosis. The proposed changed regulations would needlessly and severely limit access to robust mental health care to the most most vulnerable citizens of the Commonwealth. They should be amended to allow that residents-in-counseling and supervisees in social work can provide outpatient psychiatric services, as the pool of qualified providers is already critically small.

Please reconsider promoting and implementing a policy that will surely result in a detrimental outcome for those in critical need of mental health services.