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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5/2/23  9:26 am
Commenter: Debra Riggs / NASWVA

QMHP licensing
 

The QMHP already has a  registration, and a certification can be a way of giving more credibility to these folks. However, to add an additional license level, to those who already are licensed, poses another issue.  Licensee's must take exams, some of which are national, and recognized by professional organizations, and other "trade organizations" For example, a Social Work Degree 'allows' one to be licensed, and work within a specific scope of practice.  In order to help streamline the process, and support the workforce, the QMHP should be limited to those who are not licensed, but have experiance  and specific scopes.  Those with Masters Degrees in Behavioral Health, should be exempt for the QMHP registation/licensing process, as they already are under the authority of one of the Board, under the Dept of Health Professions.

To require those with specific education and training, with a degree to also be licensed as a QMHP is an undue burden on the practicioner, causing more complications in the workforce "pipeline".

In summary, please do not add another level of licensure to those who are already licensed  and if not licensed, have them work under a licensee, and possibly be certified.

CommentID: 216812