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]
Action Initial regulations for registration of Qualified Mental Health Professionals
Stage Final
Comment Period Ended on 11/13/2019
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11/13/19  3:46 pm
Commenter: Community Provider

Where is the workforce going to come from?
 

This regulation is another example of a regulatory restriction on the available pool of applicants for our workforce.  Please reconsider any changes which further restricts the workforce for positions where it is already difficult to fill with out necessarily improving service delivery quality.  The following are additional examples of impractical burdens to workforce specific to these regulations.

Work experience from other states and other positions must be accepted.  This is critical statewide, but especially in localities that border other states and rely on them for workforce.

Please reconsider the number of hours for the supervision requirements or provided data to support why such a high number of hours is needed.

Please add Sociology degree to the list of acceptable degrees.  Not allowing this type of degree further restricts the workforce pool of qualified and quality applicants.

QMHPs with an established amount of experience should be able to provide supervision in addition/in place of an LMHP. 

 

CommentID: 76876