Board of Counseling,

Thank you for taking the time to read my comment. When evaluating the request of the petitioner, the board should take two things into consideration. First, you should consider the public safety. Second, you should consider the statutory language.

I am wholeheartedly in disagreement with this petition. Here is my reasoning:

First, the Virginia legislature set the standards that the board is required to follow under statutory law. Mental Health Professional is defined in the Code of Virginia § 54.1-2400.1. Mental health service providers; duty to protect third parties; immunity. It says it "means a person who by education and experience..."

The law requires both education and professional experience to be a QMHP. Virginia is vary gracious in giving those with a bachelor's or a masters or even some without a degree in the medical field the ability to qualify. 

Experience teaches you how to practice. Education teaches you the theories you need to know for safe practice. The State of Virginia already gives great latitude by expanding the opportunity. 

There are many pathways to the QMHP. I would not be opposed to adding additional licenses or certifications by accredited organizations to the qualifying list to be a QMHP but removing the education requirement without adding 3rd party accountability would hurt the community. I think adding addiction counselors, behavior technicians, special education teachers, speech and language pathologists, certified employment assistance professional, and certified pastoral counselor.

Further, I think that Virginia should recognize members of the military, law enforcement, first responders, and QMHP's from other states that are in a field similar to be able to gain the credential by reciprocity or endorsement.

Finally, I think the board should change the degree requirement from degree in xyz ... to degree at assoc. bach. mast. level with x number of hours in content area.

If anyone can be a QMHP without any accountability then the field suffers. But let make it more accessible while protecting the public.

Thank you,

Prof. Michael Moates, MA, LP, LCMHC, LBA

Adjunct College Professor

Licensed Psychologist - Master (Out of State)

Licensed Clinical Mental Health Counselor (Out of State)

Licensed Behavior Analyst - Virginia