Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Counseling
 
chapter
Regulations Governing the Registration of Qualified Mental Health Professionals [18 VAC 115 ‑ 80]
Action Initial regulations for registration of Qualified Mental Health Professionals
Stage Proposed
Comment Period Ended on 4/5/2019
spacer
Previous Comment     Next Comment     Back to List of Comments
3/27/19  8:58 am
Commenter: Jonina Moskowitz, Virginia Beach Dept. of Human Services

Supervision Requirements - QMHP-Es
 

We share the concern expressed by others regarding the requirement that the work of a QMHP-E be supervised by an LMHP or someone under supervision to become licensed.  Licensed clinicians are needed to provide direct clinical services and recent increased requirements for their involvement in various services has already put a strain on resources for the behavioral health care system across the Commonwealth.  In addition, over-reliance on those still under supervision to become licensed for supervision of QMHP-Es has the potential to undermine the residency/supervisee process, which is intended to ensure these individuals have the experience and qualifications to safely work as independent practitioners.  We do appreciate recent changes allowing for inclusion of supervised experiences from other states.  However, we will continue to face difficulties hiring experienced applicants, if they relocate from states without a similar requirement or were grandfathered in another state when that implemented similar requirements.

CommentID: 70733