Town Hall Comments for Regulations Governing the Registration of Qualified Mental Health Professionals [18 VAC 115-80]

1. Given the scope of practice of a QMHP, Sociology should continue to be an approved degree.  Those working as a QMHP are providing collaborative mental health services and not engaging in independent or autonomous practice.  Many of those who have historically filled roles of the QMHP have been individuals with a Sociology degree.  Removing the Sociology degree from the approved list without substantial factual review and reporting could affect service delivery for those in Virginia.  This degree should be added back to the list.
2. For those who were not employed as a QMHP prior to December 31, 2017, requiring that the experience be within the past five years, is discriminatory for those who may have stepped out of an employed role for family matters.  This stipulation is unfair and should be removed.
3. There has been little to no clarity provided regarding documentation needed for QMHP registration.
   1. There should be a way to print the attestation form needed for staff employed prior to December 31, 2017 prior to paying the registration fee so that staff can ensure an attestation before registering.
   2. For those working after December 31, 2017, there is no clarification on the “evidence” of hours that will be needed.  Is this an attestation form?
4. I echo the multiple concerns noted regarding the requirement of registration and payment for registration for credentials as QMHP-A and QMHP-C.  Requiring separate registrations and re-registrations is redundant and not needed.  The Board of Counseling has indicated that the 8 hours of continued education can be the same hours used for both.  How then is a separate registration needed?
5. Requiring nurses with psychiatric experience to register as a QMHP-A and/or QMHP-C, when they are already registered with the Virginia Board of Nursing, seems unnecessary.
6. I echo the concerns noted regarding the list of those who can provide the 8 hours of continuing education being too narrow.  Further, the Board of Counseling has indicated that they will not pre-approve trainings which will satisfy the requirement.  This puts providers and QMHP staff in a stressful, catch 22 position.
7. I echo the concerns noted about the impact of requiring QMHP or QMHP-trainee registration before a provider can bill for the services provided.  This requirement places a significant financial burden on providers as providers will be responsible for paying employees while waiting for the Board of Counseling registration confirmation.  This burden exits even if the BOC meets their intended 30 day turn around.  The impact will very likely reduce a provider’s ability to serve individuals already in service and/or take on new clients in need of the service when a position is vacated.    Thus, individuals and families will be negatively impacted.