Please do not remove educational requirements.   The requirements keep getting reduced.  It is not beneficial for the clientele these professionals are serving to continue to lower the standards.  

Board of Counseling,

Thank you for taking the time to read my comment. When evaluating the request of the petitioner, the board should take two things into consideration. First, you should consider the public safety. Second, you should consider the statutory language.

I am wholeheartedly in disagreement with this petition. Here is my reasoning:

First, the Virginia legislature set the standards that the board is required to follow under statutory law. Mental Health Professional is defined in the Code of Virginia § 54.1-2400.1. Mental health service providers; duty to protect third parties; immunity. It says it "means a person who by education and experience..."

The law requires both education and professional experience to be a QMHP. Virginia is vary gracious in giving those with a bachelor's or a masters or even some without a degree in the medical field the ability to qualify. 

Experience teaches you how to practice. Education teaches you the theories you need to know for safe practice. The State of Virginia already gives great latitude by expanding the opportunity. 

There are many pathways to the QMHP. I would not be opposed to adding additional licenses or certifications by accredited organizations to the qualifying list to be a QMHP but removing the education requirement without adding 3rd party accountability would hurt the community. I think adding addiction counselors, behavior technicians, special education teachers, speech and language pathologists, certified employment assistance professional, and certified pastoral counselor.

Further, I think that Virginia should recognize members of the military, law enforcement, first responders, and QMHP's from other states that are in a field similar to be able to gain the credential by reciprocity or endorsement.

Finally, I think the board should change the degree requirement from degree in xyz ... to degree at assoc. bach. mast. level with x number of hours in content area.

If anyone can be a QMHP without any accountability then the field suffers. But let make it more accessible while protecting the public.

Thank you,

Prof. Michael Moates, MA, LP, LCMHC, LBA

Adjunct College Professor

Licensed Psychologist - Master (Out of State)

Licensed Clinical Mental Health Counselor (Out of State)

Licensed Behavior Analyst - Virginia

I am not in favor of eliminating the educational requirements for the QMHP. In the past few years the requirements for obtaining this certification have increased, creating a new level of professionalism for this role. While it has created barriers for some, it has not been a hurdle that agencies have not been able to work with. 

It does make sense to open the degrees that can be approved for the QMHP to be wider, with hours required for the certification in mental health or related field. 

Elimination of the educational requirement diminishes the current status of the certification. 

Thank you, 

 Elizabeth Engelhorn

Hello Board of Regulatory Town Hall/Department of Health Profession, Board of Social Work, Therapy…

I believe that lowering the requirements to practice would put the field of Behavioral Science and Psychology in a very vulnerable position. I do not believe allowing just anyone with a claim to experience should be able to receive certification. However, I do believe that there may need to be an active (with the intent to change/revise) discussion, about establishing certifications for those who have completed their Bachelors degree, to be able to support licensed providers in a support role. 

I am not in agreement with removing the educational requirement to obtain QMHP registration. QMHP degree requirements already expand beyond the human services fields to allow for nurses, occupational therapists, and other fields to obtain registration with appropriate experience. The approved fields of study should be reviewed for possible expansion. The list of approved human service degrees should be reviewed and expanded. While experience allows people to gain knowledge of how to provide appropriate services, education prepares them for the field within which they will gain that experience. Removing the requirement will leave the field, which is already vulnerable, increasingly vulnerable. The Board needs to consider ethical and legal considerations to removing the education degree and allowing registration for anyone with claimed experience, which may be of questionable validity.

I am not in agreement with removing the educational requirement to obtain QMHP registration. QMHP degree requirements already expand beyond the human services fields to allow for nurses, occupational therapists, and other fields to obtain registration with appropriate experience. The approved fields of study should be reviewed for possible expansion. The list of approved human service degrees should be reviewed and expanded. While experience allows people to gain knowledge of how to provide appropriate services, education prepares them for the field within which they will gain that experience. Removing the requirement will leave the field, which is already vulnerable, increasingly vulnerable. The Board needs to consider ethical and legal considerations to removing the education degree and allowing registration for anyone with claimed experience, which may be of questionable validity.

I am not in agreement with removing the educational requirement to obtain QMHP registration. QMHP degree requirements already expand beyond the human services fields to allow for nurses, occupational therapists, and other fields to obtain registration with appropriate experience. The approved fields of study should be reviewed for possible expansion. The list of approved human service degrees should be reviewed and expanded. While experience allows people to gain knowledge of how to provide appropriate services, education prepares them for the field within which they will gain that experience. Removing the requirement will leave the field, which is already vulnerable, increasingly vulnerable. The Board needs to consider ethical and legal considerations to removing the education degree and allowing registration for anyone with claimed experience, which may be of questionable validity.

As an active QMHP, I am not in agreement with removing the educational requirement to obtain QMHP registration. QMHP degree requirements already expand beyond the human services fields to allow for nurses, occupational therapists, and other fields to obtain registration with appropriate experience. The approved fields of study should be reviewed for possible expansion. The list of approved human service degrees should be reviewed and expanded. While experience allows people to gain knowledge of how to provide appropriate services, education prepares them for the field within which they will gain that experience. Removing the requirement will leave the field, which is already vulnerable, increasingly vulnerable. The Board needs to consider ethical and legal considerations to removing the education degree and allowing registration for anyone with claimed experience, which may be of questionable validity.

I am not in agreement with removing the educational requirement to obtain QMHP registration. QMHP degree requirements already expand beyond the human services fields to allow for nurses, occupational therapists, and other fields to obtain registration with appropriate experience. The approved fields of study should be reviewed for possible expansion. The list of approved human service degrees should be reviewed and expanded. While experience allows people to gain knowledge of how to provide appropriate services, education prepares them for the field within which they will gain that experience. Removing the requirement will leave the field, which is already vulnerable, increasingly vulnerable. The Board needs to consider ethical and legal considerations to removing the education degree and allowing registration for anyone with claimed experience, which may be of questionable validity.

I am not in agreement with removing the educational requirement to obtain QMHP registration. QMHP degree requirements already expand beyond the human services fields to allow for nurses, occupational therapists, and other fields to obtain registration with appropriate experience. The approved fields of study should be reviewed for possible expansion. The list of approved human service degrees should be reviewed and expanded. While experience allows people to gain knowledge of how to provide appropriate services, education prepares them for the field within which they will gain that experience. Removing the requirement will leave the field, which is already vulnerable, increasingly vulnerable. The Board needs to consider ethical and legal considerations to removing the education degree and allowing registration for anyone with claimed experience, which may be of questionable validity.

I am not in agreement with removing the educational requirement to obtain QMHP registration. QMHP degree requirements already expand beyond the human services fields to allow for nurses, occupational therapists, and other fields to obtain registration with appropriate experience. The approved fields of study should be reviewed for possible expansion. The list of approved human service degrees should be reviewed and expanded. While experience allows people to gain knowledge of how to provide appropriate services, education prepares them for the field within which they will gain that experience. Removing the requirement will leave the field, which is already vulnerable, increasingly vulnerable. The Board needs to consider ethical and legal considerations to removing the education degree and allowing registration for anyone with claimed experience, which may be of questionable validity.

I am not in agreement with removing the educational requirement to obtain QMHP registration. QMHP degree requirements already expand beyond the human services fields to allow for nurses, occupational therapists, and other fields to obtain registration with appropriate experience. The approved fields of study should be reviewed for possible expansion. The list of approved human service degrees should be reviewed and expanded. While experience allows people to gain knowledge of how to provide appropriate services, education prepares them for the field within which they will gain that experience. Removing the requirement will leave the field, which is already vulnerable, increasingly vulnerable. The Board needs to consider ethical and legal considerations to removing the education degree and allowing registration for anyone with claimed experience, which may be of questionable validity.

I am not in agreement with removing the educational requirement to obtain QMHP registration. QMHP degree requirements already expand beyond the human services fields to allow for nurses, occupational therapists, and other fields to obtain registration with appropriate experience. The approved fields of study should be reviewed for possible expansion. The list of approved human service degrees should be reviewed and expanded. While experience allows people to gain knowledge of how to provide appropriate services, education prepares them for the field within which they will gain that experience. Removing the requirement will leave the field, which is already vulnerable, increasingly vulnerable. The Board needs to consider ethical and legal considerations to removing the education degree and allowing registration for anyone with claimed experience, which may be of questionable validity.

I am not in agreement with removing the educational requirement to obtain QMHP registration. QMHP degree requirements already expand beyond the human services fields to allow for nurses, occupational therapists, and other fields to obtain registration with appropriate experience. The approved fields of study should be reviewed for possible expansion. The list of approved human service degrees should be reviewed and expanded. While experience allows people to gain knowledge of how to provide appropriate services, education prepares them for the field within which they will gain that experience. Removing the requirement will leave the field, which is already vulnerable, increasingly vulnerable. The Board needs to consider ethical and legal considerations to removing the education degree and allowing registration for anyone with claimed experience, which may be of questionable validity.

I am not in agreement with removing the educational requirement to obtain QMHP registration. QMHP degree requirements already expand beyond the human services fields to allow for nurses, occupational therapists, and other fields to obtain registration with appropriate experience. The approved fields of study should be reviewed for possible expansion. The list of approved human service degrees should be reviewed and expanded. While experience allows people to gain knowledge of how to provide appropriate services, education prepares them for the field within which they will gain that experience. Removing the requirement will leave the field, which is already vulnerable, increasingly vulnerable. The Board needs to consider ethical and legal considerations to removing the education degree and allowing registration for anyone with claimed experience, which may be of questionable validity.

I am not in agreement with removing the educational requirement to obtain QMHP registration. QMHP degree requirements already expand beyond the human services fields to allow for nurses, occupational therapists, and other fields to obtain registration with appropriate experience. The approved fields of study should be reviewed for possible expansion. The list of approved human service degrees should be reviewed and expanded. While experience allows people to gain knowledge of how to provide appropriate services, education prepares them for the field within which they will gain that experience. Removing the requirement will leave the field, which is already vulnerable, increasingly vulnerable. The Board needs to consider ethical and legal considerations to removing the education degree and allowing registration for anyone with claimed experience, which may be of questionable validity.

I am wholeheartedly opposed to eliminating the educational requirements for the QMHP. While experience is important, education is also. Eliminating these requirements leaves the field vulnerable to inconsistencies in ability to successfully complete job related tasks. Education is where the foundation of ethical boundaries is formed and without this, our individuals are at risk of being served in a manner that would be deemed unethical. It does not benefit anyone for these educational requirements to be removed. Just as someone who wants to be a doctor, a lawyer, a teacher, or a CDL driver has to have certain educational requirements, the individuals we serve deserve to have providers who have education to properly serve them. Without the educational component, we are doing our individuals a disservice. 

I am not in agreement with removing the educational requirement to obtain QMHP registration. QMHP degree requirements already expand beyond the human services fields to allow for nurses, occupational therapists, and other fields to obtain registration with appropriate experience. The approved fields of study should be reviewed for possible expansion. The list of approved human service degrees should be reviewed and expanded. While experience allows people to gain knowledge of how to provide appropriate services, education prepares them for the field within which they will gain that experience. Removing the requirement will leave the field, which is already vulnerable, increasingly vulnerable. The Board needs to consider ethical and legal considerations to removing the education degree and allowing registration for anyone with claimed experience, which may be of questionable validity.

I am not in agreement with removing the educational requirement to obtain QMHP registration. QMHP degree requirements already expand beyond the human services fields to allow for nurses, occupational therapists, and other fields to obtain registration with appropriate experience. The approved fields of study should be reviewed for possible expansion. The list of approved human service degrees should be reviewed and expanded. While experience allows people to gain knowledge of how to provide appropriate services, education prepares them for the field within which they will gain that experience. Removing the requirement will leave the field, which is already vulnerable, increasingly vulnerable. The Board needs to consider ethical and legal considerations to removing the education degree and allowing registration for anyone with claimed experience, which may be of questionable validity.

I do not agree with removing the educational requirement to obtain QMHP registration. The approved fields of study should be reviewed for possible expansion but not taken completely away. Education in combination with experience prepares someone in this field to provide effective, and proper treatment to the individuals they serve.  Removing the requirement will be a disservice the individuals we serve as well as create a risk of ethical and possible legal ramifications. 

I am not in agreement with removing the educational requirement to obtain QMHP registration. QMHP degree requirements already expand beyond the human services fields to allow for nurses, occupational therapists, and other fields to obtain registration with appropriate experience. The approved fields of study should be reviewed for possible expansion. The list of approved human service degrees should be reviewed and expanded. While experience allows people to gain knowledge of how to provide appropriate services, education prepares them for the field within which they will gain that experience. Removing the requirement will leave the field, which is already vulnerable, increasingly vulnerable. The Board needs to consider ethical and legal considerations to removing the education degree and allowing registration for anyone with claimed experience, which may be of questionable validity.

Something else got me thinking. I would feel comfortable with any bachelor degree even outside of human services if the individual had 1 year of experience or qualified for clinical licensure under DHP in the State of Virginia.

I am not in agreement with removing the educational requirement to obtain QMHP registration. QMHP degree requirements already expand beyond the human services fields to allow for nurses, occupational therapists, and other fields to obtain registration with appropriate experience. The approved fields of study should be reviewed for possible expansion. The list of approved human service degrees should be reviewed and expanded. While experience allows people to gain knowledge of how to provide appropriate services, education prepares them for the field within which they will gain that experience. Removing the requirement will leave the field, which is already vulnerable, increasingly vulnerable. The Board needs to consider ethical and legal considerations to removing the education degree and allowing registration for anyone with claimed experience, which may be of questionable validity.

I am not in agreement with removing the educational requirement to obtain QMHP registration. QMHP degree requirements already expand beyond the human services fields to allow for nurses, occupational therapists, and other fields to obtain registration with appropriate experience. The approved fields of study should be reviewed for possible expansion. The list of approved human service degrees should be reviewed and expanded. While experience allows people to gain knowledge of how to provide appropriate services, education prepares them for the field within which they will gain that experience. Removing the requirement will leave the field, which is already vulnerable, increasingly vulnerable. The Board needs to consider ethical and legal considerations to removing the education degree and allowing registration for anyone with claimed experience, which may be of questionable validity.

Removing the requirement for a college degree in order to be a QMHP would be a mistake.  While I appreciate the role of experience in helping to educate someone in a profession, experience alone is not enough.  Experience might help me learn what to do through repetition and modeling, but it won't help me understand why I'm doing it.  Additionally, experience won't necessarily teach me about the underlying professional and ethical foundations of a field.  Experience will tell me what general norms are in my particular workplace but it won't tell me whether those norms are generally accepted in the wider field or not.  Finally, removing the requirement for a college degree moves QMHPs further into the realm of paraprofessional rather than professionals.  Clients receiving services from QMHPs are more vulnerable than the average population and they need helpers with the appropriate education in human development, psychopathology, and behavior to serve them well.

As an individual who has worked in a mental health setting without a graduate degree and as an individual who is currently pursuing one; a graduate degree is needed in this field of work. Before my time at Virginia Tech I worked in a children's home in SC, Connie Maxwell Children’s Ministries. I have been in situations where I have helped many but I wondered what more knowledge I could give. A lot of what I said was based off my own experience, not factual information. I have only been pursuing my Masters for three weeks and I can already look back and see mistakes I made. Qualified Mental Health Providers are qualified for a reason, they went through the necessary training to be able to aid people. Without the necessary training then people could be misleading people and it could make them worse. Being able to help others is based off a common philosophy among many professions. Therefore that studying and practice is required to be truly successful at being able to help others. As an individual who has experienced both sides of this, I hope that this does not pass. Without graduate school, people are not properly qualified to work with others professionally. 

Mental healthcare is a complex mix of science and art. It requires a basic understanding to practice competently, even under supervision. Frankly, as a QMHP myself working on a Master's Degree, the requirements for QMHPs are already very low. There are many degrees that are accepted as "related" degrees, and with enough hours of experience any college degree meets this requirement.

I think we should be moving in the other direction. I agree with having related degrees count, but I have concerns that unrelated degrees allow entry into this field. I think we should at least require certain classes like Abnormal Psychology and some kind of undergrad Psychology research class within the context of a Bachelor's degree.

I'm not saying that nobody with a GED or high school diploma can be helpful, but there are just certain things you learn with a Bachelor's degree with classes in related fields that you need in order to understand the issues people are dealing with when you work with them.

I am not in agreement with removing the educational requirement to obtain QMHP registration. QMHP degree requirements already expand beyond the human services fields to allow for nurses, occupational therapists, and other fields to obtain registration with appropriate experience. The approved fields of study should be reviewed for possible expansion. The list of approved human service degrees should be reviewed and expanded. While experience allows people to gain knowledge of how to provide appropriate services, education prepares them for the field within which they will gain that experience. Removing the requirement will leave the field, which is already vulnerable, increasingly vulnerable. The Board needs to consider ethical and legal considerations to removing the education degree and allowing registration for anyone with claimed experience, which may be of questionable validity.

I am not in support of removing the education requirements for the QMHP registration. While experience is a valid credential in mental health evidenced by peer supports, the opportunity to be grandfathered in for experience was available prior to the start date of Jan. 3, 2018. 

Opposed. This would be going backward. I get that college is expensive now, but there are plenty of college graduates who could fill these roles and the clients/patients deserve helpers with both educational background and practical experience. There are other peer support roles for those who have only personal experience.

Hello,

We’re Alexandra Krens and Chloe Billy, two graduate students in the Virginia Tech counselor education program. We’re commenting on this as part of a project focused on advocacy and legislation in the counseling profession.

We saw this petition to alter the educational requirements for Qualified Mental Health Professionals (QMHPs) and we have some concerns.

In preparation for this comment, we spoke with a former QMHP-t, and she talked about often feeling unprepared to provide clients the care they needed, and that many QMHPs that she knew felt the same. Specifically, she talked about feeling ill-equipped to handle crisis situations. If a person like her, who has an undergraduate degree in psychology, feels she doesn’t have the education or knowledge to provide adequate care to clients, we should be increasing educational requirements, not decreasing them.

There are already several ways a person can become a QMHP, including being an occupational therapist or a nurse, which doesn’t require an educational background in mental health specifically, and provides a good way to allow people whose expertise comes mainly from experience, but still contains an educational component, to enter the field. We’re open to the idea of similar professions which still contain a mental health education component coming into the field, but don’t think that those without a background should be let in.

We are aware that part of the motivation for this is the labor shortage. To help with this, we suggest that the board consider starting a program or certification process specifically for QMHPs. This would allow more people to enter the field while ensuring that they are properly equipped to help clients.

Sincerely,

Alexandra Krens and Chloe Billy