It is my understanding that this document proposes removing reimbursement for telephone based telemental health services.   I am a licensed professional counselor in the Richmond are and have been working the safety net for the past nine years.  Additionally, I am board-certified in telemental health service delivery and have been providing telemental health services for the past two and a half years with a private telemental health agency.  It has been my experience that telephone based telemental health services increases access to care in the safety net population by eliminating barriers to care such as transportation and limited internet access, while also providing a means for service utilization for those who lack the technological literacy required to use an electronic device such as smartphone, tablet, or computer.  It is also useful to be able to offer telephone only services in the event of a technology failure, i.e. loss of internet connection, loss of power, etc.  It is my belief that individuals should be offered as many service modalities as possible so that they are able to meet their mental health needs in such a way that works for them.  Further there is a substantial body of evidence that demonstrates the effectiveness of telephone based mental health services for the treatment of various mental health concerns.  Therefore, I strongly advocate that telephone based telemental health services continue to be reimbursable. My concern is that if this service were to be nonreimbursable, then access to telemental health care in the safety net could decrease due to the inability to sustain these services without reimbursement.