Thank you for the opportunity to comment on this proposed regulation. I would like to submit the following for consideration:

It appears that the BOC description of the QMHP role and scope of practice/types of services on the recent FAQs do not match the DMAS regulations. Please refer to current DMAS regulations and insure that the regulations are lined up so as to avoid confusion. Likewise with DBHDS requirements.

I am very concerned about the requirement that QMHPs be registered before they can bill. This places undue hardship on agencies and may result in loss of applicants and/or lost billing in a time when most agencies cannot sustain either loss. Many agencies are already feeling a negative impact. With the rate of turnover experienced by many agencies, a requirement like this could also have a serious negative impact for persons served, such as in residential and crisis stabilization programs, etc.

Sociology should remain an approved degree. It is a relevant degree for the field and has been so for many years. Individuals interested in entering the field have planned college educations around this. To remove it reduces our pool of applicants.

The registration and supervision of qualified mental health professionals can be beneficial to the individuals served. However, please consider having a reduced joint fee for individuals registering for both QMHP-A and QMHP-C. Also, please consider that QMHPs will now be asked to pay for registration and ongoing renewal fees and possibly continuing education costs - without increased salary as reimbursement rates for these positions don’t seem to be addressed with added requirements, as well as no increase for related administrative costs to agencies.

Please consider extending the age range of QMHP-C to serve individuals up to age 21 years of age. Many children with behavioral issues continue through the community-based “child services” through age 21. Requiring them to change providers at age 18 interrupts continuity of care and may disrupt treatment. Please also consider language that would allow clinical judgment to guide the transition of care between “child” and “adult” and to allow for variances in the best interest of the persons served.

I share concerns that there is an expectation that licensed or licensed-eligible individuals must supervise the day-to-day operations of services provided by QMHPs. Licensed individuals are scarce in many parts of the state, especially since CCC Plus has been implemented and MCOs have recruited many of our licensed staff. While I understand the intent is to insure that individuals receive services from qualified staff, it is equally critical to have licensed staff provide direct services to individuals who need them most. As we see more and more administrative and supervision requirements for our agencies, without added funding support, the strain on the system takes a toll on agencies, staff, and the people we serve. Please take this into serious consideration when regulations are passed.

I would request that regulations clarify the nature and extent of supervision that LMHPs and LMHP-types must provide to registered QMHPs. Must the LMHP be the direct supervisor? Can group supervision be used to meet this requirement? How many QMHPs can someone supervise? Does the supervisor have to be registered as QMHP, as an approved supervisor? Are all registered QMHPs required by to be supervised by an LMHP, LMHP-type or is this just for QMHP Trainees? What supervision documentation is required?

I would echo concerns regarding the 8 hours of continuing education being narrowly defined regarding who can provide the training. Please consider making requirements line up with current DBHDS requirements and expectations.

Can licensed individuals provide services that require QMHP registration? Does having a license (LPC, LCSW, RN, LPN) negate the need to register as a QMHP?

Please take into consideration options for those registered as QMHP-A or QMHP-C to be able to work across these boundaries in order to learn new skills and expand their ability to provide services in our system of care. Locking registration down in silos can only serve to limit the options of both staff and agencies to meet the dire needs of our communities. As someone who has worked with both adults and children, I believe there is great value to be added to our services by creating more opportunities for staff to cross train and expand their abilities and value taken away by reducing these opportunities.

Will staff who were grandfathered in as QMHP be able to take their newly-registered status with them if they leave the home agency? If so, this could result in a loss of staff for some agencies. If not, then these individuals will be required to register with the state, complete all continuing education, and yet remained locked into a current job or agency without potential for much advancement. This seems unfair to hard working professionals. Also, can QMHP registered staff move into non-QMHP positions and maintain their registration should they wish to move back into a QMHP position in the future?

Should QMHP-Es begin to register now as either QMHP-A or QMHP-C or to seek to be prepared to move into either?

Thank you in advance for your consideration of these comments when updating these regulations to better meet the needs of all individuals receiving behavioral healthcare services in Virginia.