While I understand the reasoning behind registration of QMHP staff for adults and/or children, the way the regulation is currently being presented poses many problems to those of us actually working in the mental health field.

1. QMHP-C only goes to age 17, many students with behavioral issues continue through the community-based “child services” through age 21.This means a youth who has had a staff person working with them potentially for all of their life, might have to get transferred to a QMHP-A solely because they turn 18.This will disrupt treatment, especially in school settings.

   1. I request that some consideration be granted that a QMHP be ONE definition where staff can move between children and adult community-based services given experience with both children and adults.

2. The hiring of staff as of January 1, 2018 is already being negatively affected by the way the regulations are reading.Because applicants after January 1, 2018 have not been given the opportunity to be grandfathered in, we are trying to follow the posed regulations for positions that require QMHP staff.Since Sociology has been removed from the list of accepted Human Services Field degrees, our applicant pools have decreased as this has historically been a widely known and accepted degree to work in the human services field.In addition, staff have gained experience with children AND adolescents and having to differentiate between the two could cause someone’s experience to keep them from being eligible under the new regulations.

   1. Can it be clarified that a degree in sociology is still considered a human services field.

3. I need clarification as to who can directly supervise registered QMHP-A’s and C’s.In the southern part of the state, we are significantly lacking in licensed staff and even staff who are eligible to be licensed.If the requirement is to require a QMHP to be directly supervised by a licensed type, organizations in the southern part of the state will have to cease services until we can hire more licensed type staff.

   1. Can it be clarified that a QMHP-A or C can be directly supervised by another QMHP-A or C as long as there is overall oversight by a licensed-type staff person in the chain of command?

      1. Consider the situation where someone desires to maintain their QMHP-A or C, but their position does not require it, but want to have the opportunity for upward advancement.If their supervisor is required to have this credential, it could pose a problem for retaining staff.

4. I am one of those folks who has experience working with children and adults; I am in a position where I am not actively providing services though.I would like to retain my QMHP-A AND QMHP-C status as I continue my education to be licensed.However, this regulation would require me (and MANY others across the state) to register as both, with two fees just to keep our opportunities open in the wide field of mental health services that overlap between children and adults.

   1. Again, can it be considered that the QMHP fee allow for someone to maintain both a QMHP-A and C status?

Thank you in advance for your consideration in updating the regulations to better meet the needs of all folks receiving mental health services in Virginia.