From Definitions: 

"Qualified developmental disabilities professional" or "QDDP" means a professional who (i) possesses at least one year of documented experience working directly with individuals who have developmental disabilities; (ii) is one of the following: a doctor of medicine or osteopathy, a registered nurse, a provider holding at least a bachelor's degree in a human service field including sociology, social work, special education, rehabilitation engineering, counseling, or psychology; and (iii) possesses the required Virginia or national license, registration, or certification in accordance with his profession, if applicable. 

Comment: Consider an option for experience in lieu of bachelor’s degree as with QIDP (5 years experience in lieu of degree).  If QIDP is included in this definition -  if the roles have been combined we need to ensure that the QIDP allowance for experience is included - particularly for those who have been doing the work.  The ability to have experience in lieu of a degree has been a huge motivator for people who have not completed a 4 year degree to make ID services a career.    

It is also not clear in the Regs if the supervisor of the staff providing services needs to be a QIDP (QDDP).  Again, if the degree is required and the supervisor must be a Q, providers are going to lose some of their best, most loyal leaders.