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]

19 comments

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4/24/23  1:06 pm
Commenter: Anonymous

QMHP
 

QMHP's assist with Skill-Building, ISP's and the behavioral aspect of treating mental health issues or concerns. However, we can't even teach simple courses such as Anger Management or Batters Intervention which are behavioral, w/o a license, yet we provide the technical training for individuals and families in mental health. 

Many of us hold Masters or higher with over 20 years of experience we just choose not to be LPC's, LCSW's, etc. However, there are other licensed titles such as LSW, LMSW,LBA, etc., without the clinical part. QMHP's do not need to be clinical as there are other Licensed titles that are not clinical as well. Having a specific area of LQMHP's would add to the already stretched mental health field or burnt out workers. QMHP's treat/assist with the behavioral aspect of mental health disorders and provide a different skillset and form of compassion. 

Allowing us to be looked upon as Licensed would be a tremendous addition to the Mental Health field and would provide more options for those seeking help. I am not asking that you allow us to diagnose, just to be considered as licensed.

CommentID: 216637
 

4/24/23  1:51 pm
Commenter: Laura Ann Rowsey-Collins

Not an acceptable idea
 

Therapists/Counselors have a master's degree and must meet an intensive set of criteria.  If this is important to ENSURE THE SAFETY AND WELLBEING OF OUR CLIENTS, then to suggest that it is in the public's best interest to license QMHPs is contradictory to the current requirements.  

Further, Virginia just joined the Counseling Compact.  To weaken the licensing regulations for mental health providers may cause problems with Virginia Counselors being allowed to practice in other states.  

Finally, I have been previously a QMHP and am now a LPC (Licensed Professional Counselor).  In no way was I prepared as a QMHP to provide the quality of services I now do.  I did not have the breadth and depth of education or experience I now have.  And, I was not aware enough at that time of what I did not know to have avoided causing harm were I to have been providing mental health services beyond those of the QMHP I was.

CommentID: 216638
 

4/24/23  3:14 pm
Commenter: Anonymous

QMHP seasoned
 

That was your experience. I am not saying through fresh BS/BA level QMHP's in with a license. You may not have known what you were doing..

CommentID: 216639
 

4/24/23  3:18 pm
Commenter: Anonymous

QMHP
 

I have a Masters. I have worked in mental health over 20 years. I am well equipped to provide services on a Licensed level. To the previous comment on not being prepared yourself, that's you. You are only speaking to that because you are now Licensed. 

CommentID: 216640
 

4/24/23  3:32 pm
Commenter: Kathy Johnson- Petitioner

Reasoning
 

I submitted this petition because some, not all, QMHP's indeed have the knowledge and educational background that would make licensing QMHP's a good idea. There are other fields such as Licensed Bachelor/Masters Level Social Workers w/o the clinical piece. There are also LBA's and BCBA's. My reasoning for this petition is because there are plenty of areas in which QMHP's are experts and should be able to be licensed to practice in those specific areas only. We can't even provide Anger Management or Batterers Intervention without a license yet we can do skill-building, write ISP's, create behavior intervention plans and so forth. I am not asking that QMHP's be allowed to practice in areas in which they are not experts. I am not asking that you license Bachelors level QMHP's either. I am asking that it be considered, to license Masters level QMHP's who have been in the field for more than 5 years or so with the work experience. 

CommentID: 216641
 

4/24/23  7:42 pm
Commenter: Erin Holland, LPC

disagree
 

I would potentially be okay with a compromise between the ideas - having a different licensing level between QMHP and LMHP. Something that differentiates between a brand new QMHP and a QMHP who has been in the field for a long time, has taken a certain amount of CEUs, perhaps can pass a certain test, and can demonstrate a higher level quality of care. But I have provided care on a QMHP level and an LMHP level and there is a vast difference between the type of care provided. There are certainly some incredible QMHPs out there, just as there are some not-amazing LMHPs out there. But just as there is a difference in the training between LCSWs and LPCs even though both have master's degrees and some responsibilities overlap, there is a difference in the training provided to LMHPs who qualify for the title and those with a master's degree who do not qualify for the LMHP title. They have gone to schools who have demonstrated that they are providing a certain standard of education, and that the courses are also fitting a certain standard to train their students to be able to provide the more intensive services needed. I also agree with Ms. Rowsey-Collins who commented prior that this could have further reaching implications when it comes to the Counseling Compact. 

CommentID: 216642
 

4/25/23  8:48 am
Commenter: Courtney Holmes

More information needed
 

I have a few questions related to professional identity, role, training, etc. that it may be prudent to answer should these discussions move forward.

If QMHP's were licensed, what does that mean? How does it change their job responsibilities, the necessity for supervision, etc.?
What would the exact requirements be for a QMHP to be licensed? Would it be similar to other professional licenses where you would need an MS degree, supervised practice, and to pass an exam? Would the minimum be a BS degree?
Fundamentally, what is the professional role of a QMHP and how is it different from other licensed professionals? 
 
I could see an avenue where people with MS degrees that are related but do not count for LPC would have an opportunity then for licensure -- however, I would like to see a clear distinction developed between what someone with a QMHP license does professionally vs. an LPC/LCSW/LMFT.
Alternatively, providing services as a QMHP is often a pathway for counseling MS students who are getting the training to become professional counselors, so they can provide services and get experience and training. However, they are in a clinical training MS program and obtaining the skills necessary for LPC/LMFT/LCSW licensure. 
 
Furthermore, would the requirements to become a QMHP need to change to become more stringent? If you are allowing licensure, perhaps the pathways in which someone can take to become a QMHP need to tighten to provide further regulations about learning and practice experiences that would support the professional development of someone with a QMHP. Part of what makes a QMHP accessible is that people can get into the field under supervision and start career or change to a new career path offering direct services. If a QMHP became a path toward licensure, would that make it necessary to further restrict the accessibility of obtaining a QMHP because it would require certain background knowledge, training, and skills?
 
Is it possible that the scope of what QMHP's do now just needs to shift, rather than adopting an entire licensure avenue? There are comments posted about QMHP's not being able to do some behavioral interventions. Is it possible that this can be adapted to provide a slightly larger scope of interventions without changing the licensing structure?
CommentID: 216644
 

4/25/23  10:14 am
Commenter: Anonymous

Agreeable
 

As someone who has a master's degree, completed didactic work to earn my LPC, has worked in the field for 23 years, but was unable financially to earn my license, I would think it would be advantageous to practitioners and patients in this field of practice to be able to pass an exam and license as QMHP.  Again, scope and breadth of how it would be differentiated between QMHP and LMHP can be ironed out, but in this day and age we need more qualified practitioners, and those with experience and level of education should be able to teach and train lower levels and move ahead, whether it's LMPH or QMHP.  Again, not taking away anything from a licensed practitioner who has put in the hours and the education, but there are different ways to get the hours and education that should be recognized.

CommentID: 216645
 

4/25/23  10:21 am
Commenter: Anonymous

Call it a Certification
 

Entry level practice certification can be obtained after 3-5 year license eligible Comprise 

CommentID: 216646
 

4/25/23  10:32 am
Commenter: Anonymous

Agreeable
 

I have worked in this field for over 15 years. I have a Masters Degree in Psychology and several certifications. I have worked beside some of the best LMHP's and I have worked beside some that I have had to help because they were unprepared. I do feel that the QMHP should be respected as a step down from a LMHP. I am not taking anything away from the LMHP's, but I do feel that QMHP needs to be recognized.  

CommentID: 216647
 

4/25/23  11:27 am
Commenter: Anonymous

Agreement with Licensure or Certification
 

I have a Masters in Social Work and a Bachelor in Psychology and 14+ years in the social work field. I obtained all my LSCW supervision hours, tested, did not pass, financially unable to pay to retake and my time frame was then up ( have to do more supervision hours in order to test for LCSW again)

I am currently a QMHP-A and I am in agreement with licensure and or certification for us QMHP’s who have obtained a Masters level education, who have at least 10 plus years of experience, and who have obtained a certain amount of CEU's.

I am more qualified than a straight out of grad school LPC, LSCW, LMHP to be licensed.

LQMHP (In total agreement) 

C- QMHP(A/C) (C=Certified )

 

CommentID: 216648
 

4/25/23  2:25 pm
Commenter: Anonymous

QMHP-
 

Every licensure level has a certain skillset. If you license a QMHP, to practice independently, you would simply "define" their scope of practice which is pretty much already in writing, you would simply be making it a licensure. However, implementing that licensure would only be available to educational levels of Masters or higher and specifying degrees, this could work. Fields such as Human Services, Psychology, Counseling, etc. Many Human Services Masters, you can take specific courses, myself in particularly, although my degree is Human Services, Marriage and Family Therapy, the course load was primarily counseling. I have a BS in Psychology with a minor in Addiction Studies. A 30 credit Masters would be suffice to license a QMHP as the clinical piece will not be attached with the licensure. Many QMHP's indeed have a 30 credit Masters which would cover your basics along with experience and trainings. I myself have worked as an EAP Consultant for over 6 years, a QDDP for over 7 years, a QMHP grandfathered in due to experience and educational background. Not to mention, I have worked directly with SMI consumers for over 15 years. I am not interested in providing therapy as that is my choice as for many or as previous comments on the thread stated, due to finances. This can be ironed out indeed. As I stated before, the clinical piece is for LCSW's, LPC', etc., agreed. However, to license a QMHP will open doors for the current crisis in mental health overall. I agree, you need the clinical piece for diagnosing, but even for non-medical counseling, a QMHP is well qualified to provide that. Afterall, we basically write ISP's, Behavioral Intervention plans, monitor drug side effects, provide crisis management, coping skills, etc. Allowing us to practice our expertise independently would be a great addition to the mental health workforce and decrease the burnout of clinical Providers. We can actually take a load off... 

CommentID: 216649
 

5/2/23  9:26 am
Commenter: Debra Riggs / NASWVA

QMHP licensing
 

The QMHP already has a  registration, and a certification can be a way of giving more credibility to these folks. However, to add an additional license level, to those who already are licensed, poses another issue.  Licensee's must take exams, some of which are national, and recognized by professional organizations, and other "trade organizations" For example, a Social Work Degree 'allows' one to be licensed, and work within a specific scope of practice.  In order to help streamline the process, and support the workforce, the QMHP should be limited to those who are not licensed, but have experiance  and specific scopes.  Those with Masters Degrees in Behavioral Health, should be exempt for the QMHP registation/licensing process, as they already are under the authority of one of the Board, under the Dept of Health Professions.

To require those with specific education and training, with a degree to also be licensed as a QMHP is an undue burden on the practicioner, causing more complications in the workforce "pipeline".

In summary, please do not add another level of licensure to those who are already licensed  and if not licensed, have them work under a licensee, and possibly be certified.

CommentID: 216812
 

5/3/23  6:25 pm
Commenter: Anonymous

In response to Debra Riggs comment
 

In response to Debra Riggs comment:
"Licensee's must take exams, some of which are national, and recognized by professional organizations, and other "trade organizations
This is not always the case.  For instance, in the state of Illinois a person who wishes to be a LSW licensed social worker is not required to complete an examination. (Illinois Public Act 102-0326)

To require those with specific education and training, with a degree to also be licensed as a QMHP is an undue burden on the practitioner, causing more complications in the workforce "pipeline

How will this be a burden on the practitioner and what type of complications do you project?

"please do not add another level of licensure to those who are already licensed and if not licensed, have them work under a licensee"

What type of Licensed professional would suffice for the QMHP to work under for those who are un licensed, already a registered QMHP, holding master's level degrees with over 15+ years in the field and who have already met supervision requirements for  LPC,LCSW and LMHP?

CommentID: 216817
 

5/8/23  3:01 pm
Commenter: Anonymous

Certification as means of demonstrating competence
 

If there are QMHPs with Masters degrees in an appropriate field, not occupational therapy or outside of clinical mental health, then these folks should seek independent licensure in the pathways that are appropriate to their Masters degree. Social Work, Counseling, Substance Abuse Treatment Provider, or Marriage and Family Therapy all have rigorous standards to meet for licensure, and are the prevailing graduate clinical mental health tracks in the US today. Licensure as a standard is the highest of competencies, and should not be watered down by allowing folks without at least a Masters degree, internship/practicum, and residency experiences to be seen as independent providers/practitioners. We are exceptionally honored to provide mental health services to those in need, and for ethical and competent practice, should hold graduate degrees and supervised clinical experiences to demonstrate we are worthy of working with those in need. As others have stated, I am in favor of a certification that requires at least a Masters degree, some form of supervised clinical practice, and requires them to be under regular supervision of someone licensed in a clinical mental health discipline. If folks have a Masters degree in an appropriate clinical mental health field, then they should go through the appropriate licensure track for their graduate discipline. I know there are gaps in what may have qualified someone based on their graduate program, CACREP- or other accrediting body approval, and I recognize that it may take greater effort, time, and money to complete the remaining gaps in education to complete internship and residency, but our impact on humans is too great to get wrong. Independent Licensure dictates competency, ethical practice, and ability to practice with little oversight. Folks with bachelors degrees would not have the appropriate education to do so. Licensure is and should be a different standard than certification, and should be respected as such. I am in opposition of what the original petitioner is suggesting and feel that it could be achieved through channels that already exist for Masters degree-holders.

CommentID: 216887
 

5/9/23  6:08 pm
Commenter: Anonymous

DISAGREE
 

I am reaching out to express my viewpoint regarding the licensure and regard of Qualified Mental Health Professionals (QMHPs) in comparison to Licensed Professional Counselors (LPCs) and Residents.

Firstly, I want to emphasize my respect and appreciation for QMHPs, as I myself started my career as a QMHP-E. I acknowledge the valuable contributions they make to the mental health field. However, I believe it is crucial to recognize the distinctions in the licensure requirements and professional qualifications between QMHPs, LPCs, and Residents.

QMHPs typically hold a bachelor's degree in human services and possess one year of clinical experience. While this foundation provides them with valuable knowledge and skills, it falls short in terms of the extensive academic and residency requirements that LPCs and Residents are required to fulfill.

For instance, a Resident is expected to complete a bachelor's degree, followed by a master's degree that includes practicum placements, internships, and comprehensive exams. Additionally, LPCs are mandated to complete at least two years of supervised residency. These academic and residency requirements play a vital role in equipping LPCs and Residents with an in-depth understanding of clinical practice and ensure their readiness to address the complex mental health needs of individuals.

It is essential to emphasize that my intention is not to undermine the significance of QMHPs or question their competence. Rather, I aim to emphasize the importance of recognizing the variations in qualifications and experience among mental health professionals.

By acknowledging the distinctions, we can ensure that individuals seeking mental health support receive the appropriate level of care from professionals with diverse backgrounds and expertise. This recognition can also contribute to the overall advancement of the mental health profession and facilitate a comprehensive, multi-tiered approach to meeting the diverse needs of clients.

I welcome the opportunity for open and respectful dialogue on this topic, as it is essential for the continued growth and development of our field.

Thank you for taking the time to consider my viewpoint. 

CommentID: 216939
 

5/11/23  12:44 pm
Commenter: Anonymous

Disagree
 

Call it a certification but not a license. 

CommentID: 216984
 

5/15/23  3:40 pm
Commenter: William Moncure; M. A. in Mental Health Counseling, Doctoral Candidate

Support Underlying Goal; Needs Improved Execution
 

I believe I see this issue through a different lens than many here. I find that there is a lot to like in the petitioner's intentions. In fact I encourage those commenting here to read the actual petition if possible rather than only the summary given by the Board. I just wish the petition had more specific requirements for how a QMHP could become a licensed QMHP. I believe the petition would be more likely to be successful if it were more specific and firm about requirements. 

My own background is in Clinical Mental Health Counseling and Addiction Counseling. However, I am concerned that ever since the Board of Counseling stopped allowing individuals with Counseling Psychology degrees to become LPCs (regardless of specific coursework or other training) there has been an issue where we have hundreds of individuals in Virginia who have 60 hour Master's degrees, but who are unable to ever practice independently. Generally they practice at the QMHP level.

I think this measure should be specifically limited to QMHP's with a certain level of experience, who have a Master's Degree, and have completed at least 60 credit hours at the graduate level. The Board seems to be firm in not allowing individuals with Counseling Psychology degrees to become LPCs, but if the issue is the title of Licensed Professional Counselor, perhaps this could be a reasonable compromise. I think ensuring that individuals with significant training and educational background can practice independently is in the best interest of the public given the significant lack of mental health professionals in many parts of the Commonwealth and the ongoing opioid and other epidemics.

I suggest a title like "Master Qualified Mental Health Professional" to indicate the requirement for a Master's degree. Perhaps with 3-5 years of active practice at the QMHP level under appropriate supervision.

Several Psychology master's programs in Virginia shut down after the Board of Counseling decided to not allow their graduates to become LPCs, a phenomena which in part has contributed to the APA finally embracing Master's level accreditation (and presumably licensure of some sort). If the Board of Counseling does not provide a pathway to independent practice for those with Counseling Psychology Master's degrees, the Board of Psychology likely will in the near future. If the Board does not allow this change, those here who are in that boat might consider checking out what the Board of Psychology offers in the future. In my opinion, the question is whether the Board of Counseling wants to have these individuals under their Board, or let the Board of Psychology step in instead.

Essentially I would ask the Board to approve a modified version of the petitioner's request along the lines of requiring a Master's degree in Mental Health Counseling, Applied Psychology, Clinical Psychology, or Counseling Psychology; a total of 60 credit hours at the graduate level; and 3-5 years of experience under supervision.

CommentID: 217003
 

5/16/23  4:29 pm
Commenter: Anonymous

Certification to validate professional development and skillset
 

Because of the educational and professional gaps that require more guidelines, standards of practice, accountability , role clarification and supervision at this point Licensure is a misleading terminology appears incongruent to expectations, training ,professional accountability and competence inherent in the word Licensure. This has already presented a new set of role confusion. Although many QMHP's have pursued advanced degrees this is not the expectation or most at this time. 

CommentID: 217007