As a Virginia community behavioral health provider with experience delivering Intensive In-Home (IIH), Adult Mental Health Skill Building Services (MHSS), and Therapeutic Day Treatment (TDT), I appreciate the Commonwealth's commitment to strengthening behavioral health services through evidence-based practices, standardized competencies, and quality oversight. Community providers share these goals and have consistently demonstrated their willingness to invest in workforce development, quality improvement, and regulatory compliance.
My concern is not with the intent of the proposed regulations, but with the cumulative effect of overlapping training expectations, fragmented workforce requirements, layered oversight, and duplicative compliance obligations across multiple state agencies. While many of the individual requirements have merit, together they create implementation complexity that may unintentionally reduce provider capacity, delay onboarding, increase workforce challenges, and ultimately affect timely access to care for Virginia's Medicaid members.
Over the past several years, community providers have adapted to significant changes, including revised Qualified Mental Health Professional (QMHP and QMHP-T) requirements, expanded Medicaid documentation standards, electronic health record implementation, quality assurance systems, and enhanced supervision expectations. These investments demonstrate the provider community's commitment to quality care.
One opportunity to improve implementation would be to better align the Virginia Board of Counseling's QMHP and QMHP-T training requirements with the proposed CPST workforce requirements. Under the Board's current policy, applicants for QMHP-T registration must complete 60 hours of approved didactic education, while QMHP applicants must complete 80 hours unless those requirements are satisfied through an approved educational pathway or Board-recognized program. The Board also permits colleges and universities to verify qualifying coursework through a Verification of Human Services Coursework form.
In practice, however, many providers experience significant delays because colleges and universities are unfamiliar with the verification process or are unable to complete the required documentation in a timely manner. As a result, agencies often provide all or part of the required didactic education themselves so qualified applicants can obtain registration and begin serving individuals—even when those individuals already possess degrees in human services or related disciplines. Therefore, staff are waiting weeks to months to get approval to start working after onboarding agencies, then due to waiting for this status, and being unable to start services, they are forced to look for other more sustainable employment.
At the same time, the proposed CPST regulations introduce additional statewide workforce requirements through the MAP credential, Foundational Skills Curriculum, Intermediate Skills Curriculum, competency verification, and ongoing training expectations. Many of these topics—including ethics, professional boundaries, documentation, confidentiality, cultural responsiveness, and core behavioral health practice—closely align with the competencies already required for QMHP and QMHP-T qualification.
Rather than creating two parallel training systems with overlapping content, I encourage DMAS, DBHDS, and the Virginia Board of Counseling to work collaboratively to align these workforce requirements wherever competencies substantially overlap. Completion of one state-approved training pathway should be recognized toward equivalent requirements in another when appropriate. This would maintain high standards while reducing duplication, simplifying implementation, and creating a more coordinated workforce development model. It is unclear of the cost of the MAP training and whether paying for this training for all staff will be sustainable.
In addition, the proposed CPST regulations require providers to implement and monitor multiple new training, supervision, competency verification, documentation, and reporting processes. While each requirement individually may be reasonable, the cumulative effect requires significant administrative infrastructure and financial investment. Community behavioral health providers must balance these implementation requirements with workforce recruitment, staff retention, supervision, and the ongoing responsibility of providing timely, high-quality services to individuals and families. National research has consistently found that increasing administrative complexity contributes to clinician burnout, workforce shortages, and reduced provider capacity, underscoring the importance of balancing accountability with practical implementation.
As these regulations are finalized, I respectfully encourage consideration of the following recommendations:
* Coordinate workforce development efforts across DMAS, DBHDS, and the Virginia Board of Counseling by aligning equivalent training and competency requirements wherever possible.
* Recognize existing provider training programs and equivalent education that already satisfy required competencies, reducing unnecessary duplication.
* Streamline overlapping documentation, reporting, and competency verification processes to reduce implementation complexity while maintaining accountability.
* Continue collaborating with community providers throughout implementation to ensure the regulations strengthen quality without unintentionally reducing provider capacity or access to care.
Community behavioral health providers are not asking for fewer quality standards or less accountability. Rather, we encourage greater coordination among state agencies so that high standards can be achieved through a unified and efficient workforce development system. The success of the CPST model will depend not only on strong clinical expectations, but also on thoughtful implementation that recognizes existing provider infrastructure, reduces regulatory duplication, supports workforce sustainability, and preserves timely access to behavioral health services for Virginia's Medicaid members.
Thank you for your consideration of these comments and for your continued commitment to improving behavioral health services throughout the Commonwealth.