We support the Commonwealth's goal of ensuring that providers are well-trained, competent, and equipped to deliver high-quality behavioral health services. However, we are concerned that several provisions in the proposed manual require participation in proprietary training programs, specific credentialing processes, accreditation organizations, and administrative systems that rely on outside entities rather than establishing competency through objective standards.

The cumulative effect of these requirements creates unnecessary costs for providers while directing significant financial resources to third-party organizations without clear evidence that these expenditures improve clinical outcomes beyond existing professional licensing, credentialing, and accreditation requirements.

Examples include mandatory MAP credentialing, required participation in the DBHDS Behavioral Health Technician Academy rather than recognizing other state-approved credentialing pathways, ongoing reporting through CEP-VA, and references to specific accreditation requirements that may require providers to engage with particular accrediting organizations. Individually, these requirements increase costs; collectively, they create a substantial unfunded administrative infrastructure that providers must support in addition to delivering direct clinical care.

Many of these requirements also create unnecessary dependence on organizations outside of providers' control. Training availability, consultation schedules, portfolio reviews, credentialing timelines, system access, recertification requirements, and reporting processes are all subject to the policies, capacity, and timelines of third-party organizations. Providers may experience implementation delays or compliance challenges that are unrelated to the quality of services they provide but instead stem from the availability or administrative processes of external entities.

From a fiscal perspective, these requirements represent ongoing operational costs that extend well beyond initial implementation. Agencies must budget for registration fees, consultation costs, staff time away from billable services, travel when applicable, credential maintenance, multiple reporting systems, and ongoing administrative oversight. These costs are particularly concerning given that the proposed reimbursement rate does not account for the expanded administrative infrastructure required to maintain compliance.

The proposal also limits provider flexibility by prescribing specific methods of demonstrating competency rather than recognizing equivalent qualifications. In many cases, providers already employ licensed professionals, nationally certified staff, accredited quality management systems, and robust internal learning management systems that meet or exceed the intended objectives of the proposed requirements. Requiring participation in specific programs instead of recognizing equivalent credentials or documentation creates duplication without improving accountability or quality.

These provisions also create barriers to workforce recruitment and retention. Qualified clinicians and paraprofessionals who already meet Virginia licensing or credentialing requirements may nevertheless be ineligible to provide services until they complete additional organization-specific training or credentialing processes. This narrows the available workforce at a time when behavioral health providers across the Commonwealth continue to experience significant staffing shortages.

A more sustainable approach would establish performance and competency standards while allowing providers flexibility in how those standards are achieved. Rather than requiring participation in specific proprietary programs or administrative systems, DMAS should recognize equivalent training, credentials, certifications, accreditation, and documentation that demonstrate compliance with the underlying competency requirements.

Specifically, we recommend that DMAS:

• Recognize equivalent training, certifications, and professional credentials rather than requiring participation in named proprietary programs.
• Accept any credential recognized by the Commonwealth or an appropriate professional licensing or credentialing body that demonstrates equivalent competency.
• Eliminate duplicate reporting requirements when providers already maintain documentation that can be reviewed during audits.
• Allow providers to submit training and qualification documentation directly to DMAS upon request rather than maintaining information in multiple external reporting systems.
• Avoid incorporating requirements that effectively require providers to purchase services, consultation, credentialing, or subscriptions from specific outside organizations unless those requirements are clearly supported by evidence and adequately funded through reimbursement.

Publicly funded behavioral health services should prioritize investment in direct patient care rather than creating ongoing financial obligations to third-party organizations. Standards should focus on outcomes, competency, and accountability—not on requiring providers to utilize specific proprietary systems or vendors. A more flexible, performance-based approach would maintain quality while reducing unnecessary administrative costs, preserving provider choice, and strengthening the behavioral health workforce.