As a mental health professional who has only recently obtained licensure in the Commonwealth of Virginia, I find the proposed regulation changes concerning ISPs being completed by a licensed professional and Crisis Stabilization requiring prior-authorization to be deeply concerning.  These proposed changes will severely limit the ability of trained QMHP clinicians to effectively serve their clients and meet the needs of both the client and the community we all serve.  Additionally, it will significantly increase the workload on an already overtaxed and numerically limited Licensed Professional population.  In order to provide appropriate clinical guidance and maximize the money spent on services, it is imperative that QMHPs who have been properly trained and supervised be utilized to provide these services.  In addition, proposing an additional 2-5 day wait on a service that by design is intended to meet an immediate crisis needI can only compound an already critical situation, potentially resulting in a more costly service and a higher level of care needed for the client.  These proposed changes, as far as I can see, offer little to no benefit to either the professionals providing service or the clients which we serve.  Please do not limit us further by implementing these changes. 

Thank you for your consideration.

Julia Johnson MA, LPC