On behalf of the Virginia State Task Force for Music Therapy and as a board-certified music therapist, I would like to submit the following recommended revisions to the currently proposed regulations: https://docs.google.com/document/d/1E4zyT3W0gbd3GPzapiVo264_FYgZtTQWaYqwv_bX-GQ/edit?usp=sharing

Rationale is provided in the document for each revision. The most significant revision is to the continuing education requirements for renewal of a license. Our national certification, managed by the Certification Board for Music Therapists (CBMT), requires music therapists to obtain 100 continuing education hours every five years. The current proposed regulations would require 20 continuing education hours be obtained annually. This will not only create an administrative burden for the state to oversee, but will also create a greater financial burden and burden of time on practicing music therapists. This is because some continuing education opportunities grant music therapists more than 20 continuing education hours. An exhaustive list of continuing education opportunities and their assigned hours can be found on CBMT's website: https://www.cbmt.org/wp-content/uploads/2021/01/2020-Recertification-Credit-Chart.pdf

When speaking with Deputy Secretary, Leah Mills of Health and Human Resources in September 2024, she expressed concern on behalf of Secretary Janet Kelly that the proposed regulations are too restrictive on the workforce with regard to continuing education requirements. The Music Therapy Advisory Board recommended revising the proposed regulations during their meeting on August 18, 2023 in a similar manner that we have linked above, which is to align with the CBMT requirements so as to not be more restrictive on the workforce. The meeting minutes and recommendation to remove the requirement of 20 continuing education hours annually can be found here: https://townhall.virginia.gov/L/GetFile.cfm?File=meeting\32\38234\Minutes_DHP_38234_v2.pdf 

On a personal note, I spent 4 years writing an article and completing the publication process for a peer-reviewed professional publication, for which I can now receive 50 continuing education hours. This is a more than fair allotment of hours as I spent far more than 50 direct hours learning by reading relevant literature, engaging in supervision, and conducting my own hands-on research. My article was published in 2024. In 2024 I also established a university-affiliated music therapy internship for which I can claim 30 continuing education hours. Again, this is a more than fair estimate of the time I devoted to learning how to supervise an intern and honing my own clinical practice. This means I have acquired 80 hours for my five-year CBMT renewal cycle. In the event that the 80 continuing education hours that came to fruition for me in 2024 would only count toward one annual renewal, this would mean I would have had to engage in additional continuing education opportunities while simultaneously attempting to write and publish my research article. This is not only a burden of time, but also a financial burden as continuing education courses and supervision cost money. As you can imagine, I did not choose for both of these continuing education events to coincide in the same year, but ultimately had to abide by the timeline of the journal where my article was published, by the timeline of my workplace (who approved the internship), and by the timeline of the intern. I am very happy to share that I was able to focus my time and resources on my research article which for me created an experience that was deeply enriching and has contributed to the greater good of the music therapy profession. Requiring music therapists to obtain 20 continuing education hours annually will ultimately create an unnecessary burden on the workforce and deter music therapists from engaging in continuing education opportunities that span more than a year's time.