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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5/15/23  3:40 pm
Commenter: William Moncure; M. A. in Mental Health Counseling, Doctoral Candidate

Support Underlying Goal; Needs Improved Execution
 

I believe I see this issue through a different lens than many here. I find that there is a lot to like in the petitioner's intentions. In fact I encourage those commenting here to read the actual petition if possible rather than only the summary given by the Board. I just wish the petition had more specific requirements for how a QMHP could become a licensed QMHP. I believe the petition would be more likely to be successful if it were more specific and firm about requirements. 

My own background is in Clinical Mental Health Counseling and Addiction Counseling. However, I am concerned that ever since the Board of Counseling stopped allowing individuals with Counseling Psychology degrees to become LPCs (regardless of specific coursework or other training) there has been an issue where we have hundreds of individuals in Virginia who have 60 hour Master's degrees, but who are unable to ever practice independently. Generally they practice at the QMHP level.

I think this measure should be specifically limited to QMHP's with a certain level of experience, who have a Master's Degree, and have completed at least 60 credit hours at the graduate level. The Board seems to be firm in not allowing individuals with Counseling Psychology degrees to become LPCs, but if the issue is the title of Licensed Professional Counselor, perhaps this could be a reasonable compromise. I think ensuring that individuals with significant training and educational background can practice independently is in the best interest of the public given the significant lack of mental health professionals in many parts of the Commonwealth and the ongoing opioid and other epidemics.

I suggest a title like "Master Qualified Mental Health Professional" to indicate the requirement for a Master's degree. Perhaps with 3-5 years of active practice at the QMHP level under appropriate supervision.

Several Psychology master's programs in Virginia shut down after the Board of Counseling decided to not allow their graduates to become LPCs, a phenomena which in part has contributed to the APA finally embracing Master's level accreditation (and presumably licensure of some sort). If the Board of Counseling does not provide a pathway to independent practice for those with Counseling Psychology Master's degrees, the Board of Psychology likely will in the near future. If the Board does not allow this change, those here who are in that boat might consider checking out what the Board of Psychology offers in the future. In my opinion, the question is whether the Board of Counseling wants to have these individuals under their Board, or let the Board of Psychology step in instead.

Essentially I would ask the Board to approve a modified version of the petitioner's request along the lines of requiring a Master's degree in Mental Health Counseling, Applied Psychology, Clinical Psychology, or Counseling Psychology; a total of 60 credit hours at the graduate level; and 3-5 years of experience under supervision.

CommentID: 217003