Requiring LMHP supervision of QMHP's places an undue burden on an already taxed workforce with limited resources. Rural areas lack LMHP's in their areas and typically have to contract out at a high rate for support in these areas. These requirements deter individuals from seeking LMHP or QMHP positions because the salary does not equal the stringent requirements associated. 

Health professions such as nurses are not subjected to this level of supervision, scrutiny and oversight. It's difficult to justify these requirements for supervision and hours of work experience. 

Work experience from other states and other positions must be easier to manage. We cannot continue to turn away qualified applicants because of Virginia's process. Virginia is not attractive to applicants for these reasons. They are made to feel their experience is not valuable and that the State is not friendly to workforce. 

Our CSB highly disagrees with the requirements positioned for QMHP and has not experienced evidence of how these guidelines are beneficial to the people we serve, the employees who work for us or applicants considering employment with us.