With the recent opportunity to review the Board of Counseling (BOC) applications and additional documentation that must be submitted for QMHP-A and QMHP-C registration, additional concerns are noted.  These requirements will make registration more difficult, places a financial burden on providers and will reduce service capacity for individuals in Virginia.  Listed below are four noted concerns and proposed solutions to each issue.

• When the information was original presented, providers were told that individuals who currently met the qualifications as a QMHP-A or QMHP-C would be able to register with an attestation from the current employer that they met the qualifications and were employed as of December 31, 2017.  However, the attestation BOC included with the application indicates that the person must have been employed as of December 31, 2017 AND currently working as a QMHP-A or QMHP-C.  This creates an issue in the following ways:
  1. We have supervisors who are QMHP-A and/or QMHP-C based on qualifications and previous experience; however, these staff were not currently working as a QMHP-A or QMHP-C providing services, but were supervising services.  Thus, this wording creates an issue and problem for providers. 
  2. Further, what if the person was hired while meeting the qualifications of a QMHP-C and QMHP-A, but was currently working only as a QMHP-A.  Why wouldn’t the agency be able to attest that the person met criteria for both QMHP-A and QMHP-C? 

Proposed Solution:  The attestation form should be changed to attest that the person was employed with the agency as of December 31, 2017 and meets the criteria to be a QMHP-A/QMHP-C as defined at that time.

• The verification form requiring (original) signatures creates a barrier for registration and services.  Below are examples of where this creates an issue.
  1. Few, if any, outside of Virginia DBHDS licensed programs heard or dealt with QMHP status until now.  This places a barrier for staff registration in numerous cases.  How are past supervisors, educators and/or supervisors from outside Virginia to sign off on a form indicating the work was as a QMHP-A and/or QMHP-C if this is not something that they are familiar?
  2. The verification form for hours of work requires original signatures of supervisors verifying that the work meets the QMHP-A/AMHP-C criteria.  This is a major barrier for certification.  What if the supervisor no longer works at the organization, if the supervisor is deceased, or if the organization no longer exists?  The experience should be able to count. 

Proposed Solution:  An attestation form, should replace the verification form.  The attestation form should be completed and signed by the person registering for QMHP-A/QMHP-C credentials and require the following:

1. Dates of experience, work schedule and hours worked
2. Attachment of a job description or job responsibilities summary for the work performed.

• With the application form noting that the “processing time can take up to 60 business days” I echo the concerns about the financial burden placed on the providers and the cost of service time for individuals in Virginia. 

Proposed Solution:  Establish and recognize a preliminary or provisional QMHP-C/QMHP-A status while the paperwork is being reviewed by BOC.

• As a final note, the requirement of registering and paying online, while requiring that documents be mailed into the BOC, creates a slow and antiquated registration process. 

Proposed Solution:  Utilize a computer system that allows for the uploading and attachment of documents.