Agency
Department of Health Professions
 
Board
Board of Counseling
 
chapter
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]

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5/5/26  8:44 am
Commenter: Arthur R. Branner II

Comment: Petition for Rule Making QMHP supervised hours to count towards LPC licensure requirements
 

According to the Virginia Department of Health Professionals, there is a high demand for Licensed Professionals (LPCs), marriage and family therapists, and substance abuse treatment practitioners. 29% of Virginia's population lives in a designated mental health professional shortage area.  57% of VA health care facilities recently reported severe staff shortages of psychologists and therapists, with many hiring for hundreds of roles.  High demand for services has forced some state psychiatric hospitals to limit admissions due to a lack of staff.  Cities like Virginia Beach have offered incentives for mental health professionals to address the high vacancy rates. This ruling would incentivize more prospective QMHP's to become licensed clinicians. 

CommentID: 240504
 

5/5/26  8:56 am
Commenter: Esmie Branner

Comment: Petition for Rule Making QMHP supervised hours to count towards LPC licensure requirements
 

According to the Virginia Department of Health Professionals, there is a high demand for Licensed Professional Counselors (LPCs), marriage and family therapists, and substance abuse treatment practitioners. High demand for services has forced some state psychiatric hospitals to limit admissions due to a lack of staff. While Virginia ranks reasonably well compared to other states for overall access to care, the sheer demand has overwhelmed the current workforce, particularly for specialized care. This ruling, if passed, will incentivize QMHPs to become licensed therapists.

CommentID: 240505
 

5/5/26  1:49 pm
Commenter: Genne Jackson

Petition for Rule Making QMHP supervised hours to count towards LPC licensure requirements
 

According to the Virginia Department of Health Professionals, there is a high demand for Licensed Professionals (LPCs), marriage and family therapists, and substance abuse treatment practitioners. 29% of Virginia's population lives in a designated mental health professional shortage area.  57% of VA health care facilities recently reported severe staff shortages of psychologists and therapists, with many hiring for hundreds of roles.  High demand for services has forced some state psychiatric hospitals to limit admissions due to a lack of staff.  Cities like Virginia Beach have offered incentives for mental health professionals to address the high vacancy rates. This ruling would incentivize more prospective QMHP's to become licensed clinicians. 

CommentID: 240506
 

5/6/26  12:59 am
Commenter: Penny Pelter, National Counseling Group

Petition for Rule Making QMHP supervised hours to count towards LPC licensure requirements
 

According to the Virginia Department of Health Professionals, there is a high demand for Licensed Professional Counselors (LPCs), marriage and family therapists, and substance abuse treatment practitioners. High demand for services has forced some state psychiatric hospitals to limit admissions due to a lack of staff. While Virginia ranks reasonably well compared to other states for overall access to care, the sheer demand has overwhelmed the current workforce, particularly for specialized care. This ruling, if passed, will incentivize QMHPs to become licensed therapists.

 

CommentID: 240507
 

5/6/26  6:30 am
Commenter: Queben Cruz , NCG

Petition for Rule Making QMHP supervised hours to count towards LPC licensure requirements
 
According to the Virginia Department of Health Professionals, there is a high demand for Licensed Professionals (LPCs), marriage and family therapists, and substance abuse treatment practitioners. 29% of Virginia's population lives in a designated mental health professional shortage area.  57% of VA health care facilities recently reported severe staff shortages of psychologists and therapists, with many hiring for hundreds of roles.  High demand for services has forced some state psychiatric hospitals to limit admissions due to a lack of staff.  Cities like Virginia Beach have offered incentives for mental health professionals to address the high vacancy rates. This ruling would incentivize more prospective QMHP's to become licensed clinicians. 
CommentID: 240508
 

5/6/26  6:34 am
Commenter: Jennifer Reyes

Comment: Petition for Rule Making QMHP supervised hours to count towards LPC licensure requirements
 

According to the Virginia Department of Health Professionals, there is a high demand for Licensed Professional Counselors (LPCs), marriage and family therapists, and substance abuse treatment practitioners. High demand for services has forced some state psychiatric hospitals to limit admissions due to a lack of staff. While Virginia ranks reasonably well compared to other states for overall access to care, the sheer demand has overwhelmed the current workforce, particularly for specialized care. This ruling, if passed, will incentivize QMHPs to become licensed therapists.

CommentID: 240509
 

5/6/26  6:45 am
Commenter: Dr. Ebonie Pritchett

Support for Petition to Count QMHP Supervised Hours Toward LPC Residency
 

I am writing in strong support of the petition to allow supervised hours worked as a Qualified Mental Health Professional–Trainee (QMHP-T) to count toward the residency requirements for Licensed Professional Counselor (LPC) licensure.

 

As a current QMHP-T in the process of becoming a registered QMHP, I am actively providing direct mental health services under supervision. The work performed in this role requires the application of clinical skills, ethical standards, and professional judgment that closely align with the competencies expected of LPC residents. Despite this, these hours are not currently recognized toward LPC licensure, creating a gap that does not reflect the reality of the work being done in the field.

 

Allowing QMHP supervised hours to count toward LPC residency would create a more equitable and efficient pathway to licensure. It would reduce unnecessary duplication of supervised experience, alleviate workforce shortages, and support professionals who are already serving communities in critical mental health roles.

 

Additionally, this change would help retain qualified individuals in the behavioral health field by removing barriers that can delay or discourage career advancement. Many QMHP-Ts are already working in high-need settings, gaining valuable, hands-on experience that should be acknowledged as part of their professional development.

 

I respectfully urge the Board to approve this petition and recognize the validity and value of supervised QMHP experience as counting toward LPC residency requirements.

 

Thank you for your time and consideration.

 

CommentID: 240510
 

5/6/26  9:17 am
Commenter: Beatrice Barry, National Counseling Group

QMHP hours to count toward my LPC licensure
 

Good morning,

I am a QMHP (T) who has been finishing my Master's in Clinical Mental Health Counseling. I graduate this weekend, and I was disappointed to learn that the hours of overage in my internship won't count toward my 3400 hours toward full licensure. If the QMHP hours could be credited, it would be very helpful in moving me towards licensure in Virginia. I would be grateful for this opportunity. As a QMHP working with Medicaid clients, I have encountered a variety of diagnoses and have learned a great deal from my supervisors and my hands-on work with clients. NCG has been a very good site for both my QMHP and my internship. Thank you for considering this provision for using QMHP hours toward my LPC licensure. 

CommentID: 240511
 

5/6/26  10:59 am
Commenter: National Counseling Group

QMHP License opportunity
 
According to the Virginia Department of Health Professionals, there is a high demand for Licensed Professional Counselors (LPCs), marriage and family therapists, and substance abuse treatment practitioners. High demand for services has forced some state psychiatric hospitals to limit admissions due to a lack of staff. While Virginia ranks reasonably well compared to other states for overall access to care, the sheer demand has overwhelmed the current workforce, particularly for specialized care. This ruling, if passed, will incentivize QMHPs to become licensed therapists
CommentID: 240512
 

5/6/26  2:27 pm
Commenter: Warren C. Washington National Counseling Group

High Demand for LPC's in VA
 

According to the Virginia Department of Health Professionals, there is a high demand for Licensed Professional Counselors (LPCs), marriage and family therapists, and substance abuse treatment practitioners. High demand for services has forced some state psychiatric hospitals to limit admissions due to a lack of staff. While Virginia ranks reasonably well compared to other states for overall access to care, the sheer demand has overwhelmed the current workforce, particularly for specialized care. This ruling, if passed, will incentivize QMHPs to become licensed therapists.

CommentID: 240514