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]
Previous Comment     Next Comment     Back to List of Comments
5/8/23  3:01 pm
Commenter: Anonymous

Certification as means of demonstrating competence
 

If there are QMHPs with Masters degrees in an appropriate field, not occupational therapy or outside of clinical mental health, then these folks should seek independent licensure in the pathways that are appropriate to their Masters degree. Social Work, Counseling, Substance Abuse Treatment Provider, or Marriage and Family Therapy all have rigorous standards to meet for licensure, and are the prevailing graduate clinical mental health tracks in the US today. Licensure as a standard is the highest of competencies, and should not be watered down by allowing folks without at least a Masters degree, internship/practicum, and residency experiences to be seen as independent providers/practitioners. We are exceptionally honored to provide mental health services to those in need, and for ethical and competent practice, should hold graduate degrees and supervised clinical experiences to demonstrate we are worthy of working with those in need. As others have stated, I am in favor of a certification that requires at least a Masters degree, some form of supervised clinical practice, and requires them to be under regular supervision of someone licensed in a clinical mental health discipline. If folks have a Masters degree in an appropriate clinical mental health field, then they should go through the appropriate licensure track for their graduate discipline. I know there are gaps in what may have qualified someone based on their graduate program, CACREP- or other accrediting body approval, and I recognize that it may take greater effort, time, and money to complete the remaining gaps in education to complete internship and residency, but our impact on humans is too great to get wrong. Independent Licensure dictates competency, ethical practice, and ability to practice with little oversight. Folks with bachelors degrees would not have the appropriate education to do so. Licensure is and should be a different standard than certification, and should be respected as such. I am in opposition of what the original petitioner is suggesting and feel that it could be achieved through channels that already exist for Masters degree-holders.

CommentID: 216887