Registration of QMHPs was meant to ensure appropriate service delivery in Virginia and ensure appropriate review, training and supervision of QMHPs.  The regulations, as written, place unnecessary restrictions on services and do not improve service delivery quality.  There was not response to comments posted during the review process. Below are some examples of concerns.

1. Why is direct supervision of services by a LMHP required?  The LMHP does not perform the same role and responsibilities as a QMHP.  What evidence is there that a LMHP supervisor improves the supervision for QMHPs?  Agree, a LMHP is overseeing the clinical plans and to be available for consultation; however, QMHPs with several years of experience are better equipped to provide the supervision and insight for how to perform the work.  Were there discussions and observations of QMHP staff and inclusion of current QMHPs in the development?  I completely disagree with the Boards decision and question if having a Board responsible for licensing LMHPs created a bias in the creation of the regulations.
2. There has been no evidence provided indicating why a person with a Sociology degree cannot perform QMHP responsibilities as those with the other human service degrees.  What data and evidence was utilized in making this determination?  Additionally, there was a request for a study about the current QMHP workforce to determine the effects on service delivery by eliminating workforce with this degree.  No information has been provided.
3. The regulations impose unreasonably high hours of supervision requirements. 
4. For experience, QMHP type work is most often about years of experience, not measured in hours.  Indicating the years of full time experience required rather than hours required is more reasonable for QMHP work.   required to be a QMHP and also Requiring hours high and unreasonable hours

 The regulations as written impose impractical restrictions without evidence indicating the requirements provide better supervision and service delivery.