Thank you for the opportunity to comment.

I share the concerns expressed by others in terms of the LMHP/Type individual’s expectations to supervise the day-to-day operations of services provided by QMHPs and QMHP-Trainees. Please clarify the nature and extent of these supervision requirements. Does the LMHP/Type have to be present with the QMHP and/or QMHP-Trainee when the QMHP and/or QMHP-Trainee is providing a service either at a program location or in the community? Can group supervision suffice? In addition, what are the Supervision documentation requirements?

I would like to echo the recommendation to expand the narrow definition of approved organizations, associations, or institutions to provide the annual 8 hours of continued competency training. The BOC FAQs state, “The Board staff cannot pre-approve any CE courses. Each registrant shall use their best and professional judgment to determine if the course meets the requirements outlined in the regulations.”  This leaves only federal, state, or local government agencies, public schools, or licensed health facilities as the providers of this training.

Sociology should remain as an approved degree qualified for this credential. As expressed by multiple commenters, removing this degree substantially impacts the qualified applicant pool and those who have filled the roles as QMHPs.

The requirement for documentation of supervised experience by an LMHP/Type for services historically supervised by QMHPs (ie: Mental Health Skill Building and Psychosocial Rehabilitation Services) will significantly limit eligible applicants who are in the process, but have not yet completed, the required experience hours. Will there be any allocation to accept these supervised hours?

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.