Virginia Regulatory Town Hall
Department of Behavioral Health and Developmental Services
State Board of Behavioral Health and Developmental Services
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10/31/19  11:02 am
Commenter: Renee Scholten Collins and Collins, Inc.

106-250 &260 and

Requirements for driver's to have a valid Virginia's driver's license and the requirement to obtain three work related references would significantly impact a provider's applicant pool.

It is becoming increasingly difficult to find qualified staff who are willing to work a sometimes difficult job for wages that can be lower than working in another industry. My agency is located in a city with several colleges and universities, where Senior Psychology, Special Education, Social Work or Nursing students often choose to work to not only make extra money, but to gain valuable work experience. Some of these students are from another state or are married to military (and are allowed to keep their home state driver's license per 

The requirement for three job- related references that support the knowledge, skills and abilities of the minimum qualifications according to the job description is unrealistic for younger individuals or an individual who may be re-entering the work force after taking a break to raise a family/care for a family member. Again, this could significantly impact a providers ability to provide quality services to the individuals supported due to a worker shortage.

Requirement for an official copy of transcript or degree could be difficult for individuals who have been out of high school for several years. My agency has several very qualified, hard working and caring staff who have been out of school for decades. This mandate would not only hurt my staffing patterns, but would directly impact individuals receiving services by removing well trained, caring staff from their day to day lives.

CommentID: 76798