The Virginia Network of Private Providers does support the concept of registration for QMHP for the reasons that the original proposal was made, but offers the following comments on the Emergency Regulations:

1) There should either be an opportunity for registration as a QMHP C/A for an indivudual trained and able to work with both children and adults, or the secondary registration (for either QMHP-C or A) for an individual already registered should be at a significantly reduced rate.

2) CEU requirements for someone with dual registration should not exceed 8 hours.

3) QMHP-C should be qualified to work with any individual up to age 22 who is still in school, or foster care through the independent living program.

We share concerns expressed about the regulations becoming an impediment to building and maintaining an adequate, competent and professional workforce, but are willing to work with the Board of Counseling to manage the process as efficiently as possible.