Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Counseling
 
chapter
Regulations Governing the Registration of Qualified Mental Health Professionals [18 VAC 115 ‑ 80]
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7/19/22  10:25 am
Commenter: Cynthia Miller, Ph.D., LPC

Oppose
 

Removing the requirement for a college degree in order to be a QMHP would be a mistake.  While I appreciate the role of experience in helping to educate someone in a profession, experience alone is not enough.  Experience might help me learn what to do through repetition and modeling, but it won't help me understand why I'm doing it.  Additionally, experience won't necessarily teach me about the underlying professional and ethical foundations of a field.  Experience will tell me what general norms are in my particular workplace but it won't tell me whether those norms are generally accepted in the wider field or not.  Finally, removing the requirement for a college degree moves QMHPs further into the realm of paraprofessional rather than professionals.  Clients receiving services from QMHPs are more vulnerable than the average population and they need helpers with the appropriate education in human development, psychopathology, and behavior to serve them well.

CommentID: 122767