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 Emergency/NOIRA
Comment Period Ended on 2/7/2018
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Next Comment     Back to List of Comments
1/9/18  5:21 pm
Commenter: Alyce Dantzler

Registration for QMHP's
 
  1. Sociology used to be an approved degree and still should be.  This was voted on at a Board of Counseling meeting on November 2nd and appears that there was no discussion at all concerning this.  Sociology is as related to this field if not more than other degrees that are on the list.
  2. While I understand the reasoning behind doing this and support the move this direction 100%, I am very concerned about the delay in hiring providers will experience related to us requesting that applicants register before we hire them.
  3. I am very concerned that the 8 hours of continuing education be so narrowly defined as to who can provide this training.  I believe that other entities should be allowed to train, there shoud be "train the trainer" opportunities for providers so they can provide in-house training, or some other avenue should be found.  Providers are already required to provide a vast amount of training annually to staff and much of this, if done in a quality manner could count as continuing education. 
  4. There are very loose definitions surrounding supervision of community based programs.  We are concerned about if the board expects that Licensed or Licensed Type individuals supervise the day-to-day operations of programming.  In our part of the state, Licensed individuals or residents are very scarce, especially now that CCC+ has been implemented and the insurance companies have recruited our licensed staff away from us.  In addition, many of the programs that we are talking about are seen as non-clinical by the state and thus should not require that level of supervision.

Thank you for you consideration of these concerns.

CommentID: 63359