We respectfully request that the requirement for Behavioral Health Technicians (BHTs) to complete the DBHDS Behavioral Health Technician Academy be reconsidered. Limiting compliance to a single state-sponsored training pathway is unnecessarily restrictive when the Virginia Board of Health Professions has already established a statewide credentialing process that recognizes multiple pathways to qualify as a Behavioral Health Technician.

The Board of Health Professions' credentialing framework was intentionally developed to provide flexibility in how individuals demonstrate competency while maintaining consistent professional standards. Requiring completion of only the DBHDS Behavioral Health Technician Academy effectively excludes individuals who have obtained the state-recognized BHT credential through other approved pathways, despite meeting Virginia's competency requirements.

This requirement creates an unnecessary barrier to recruitment and retention at a time when behavioral health providers continue to face significant workforce shortages. Agencies would be limited to hiring individuals who have completed a single training program rather than drawing from the broader pool of credentialed professionals recognized by the Commonwealth. This restriction reduces workforce flexibility, increases onboarding timelines and costs, and may delay access to services for individuals in need of care.

Additionally, requiring providers to track and document completion of the DBHDS Academy, even for staff who already hold a valid Virginia BHT credential through another approved pathway, creates duplicative administrative burden without providing additional assurance of competency or improving quality of care.

We recommend revising the requirement to recognize any Behavioral Health Technician who holds a valid credential issued through the Virginia Board of Health Professions' approved credentialing process, regardless of the pathway used to obtain that credential. This approach would maintain consistent competency standards, align with existing Commonwealth policy, reduce unnecessary administrative burden, and expand the qualified workforce available to deliver behavioral health services while preserving provider flexibility.