Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Psychology
 
chapter
Regulations Governing the Practice of Psychology [18 VAC 125 ‑ 20]
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4/30/16  12:01 am
Commenter: Bruce Keeney, Exec Director Virginia Academy of Clinical Psychologists

Opposition to Ill Advised and Potentially Detrimental Suggested Rule Making
 

Comments are on behalf of the Va Academy of Clinical Psychologists which strongly opposes this petition.  The petition appears to be addressing professional counselors rather than clinical psychologists, the latter which are licensed and clinically trained to diagnosis and treat both moderate and severe mental disorders and disease.  The petition's suggestions are often contrary to standard of care, in that approaches to diagnosis and treatment are often on a case by case basis, including consideration of symptoms presented by the patient, medical history, etc.  Recognizing the vast number of diagnoses and of varied severity, it is contrary to quality of care standards to demand all patients be forced to undergo standardized tests (if such occur for that condition) and bear the cost of such when unnecessary.  As to reports, Virginia is perhaps different from other states in that copies of health care records are available to the patient (with some exceptions set in Code.) Likewise, a government mandate on providing often unnecessary testing or reports will either increase the cost to patients or reduce the time available for patient care.  In short, the petitioner's request should be denied in that it fails to recognize the services and higher level of care rendered by clinical psychologists as compared to counselors, and that clinical psychologists are evaluting, diagnosing and treating serious mental illness and disease.  The petitioner's suggestrions are not appropriate for diagnosis and treatment of these types of illness.  The suggestion is contrary to sound, recognized standard of care, has the real potential to jeopardize a doctor-patient therapeutic relationship, and will result in unjustified increases in costs for care.  For these reasons, the Virginia Academy of Clinical Psycyhologists strongly opposes the petition and urges its denial.

 

CommentID: 49735