37 comments
Hello,
Thank you for taking the time to read my comment. It is my opinion that this would be detrimental to the mental health community. Years of practice alone should not qualify anyone to be a supervisor. For example, someone who holds a doctorate in psychology but is not a licensed psychologist should not be supervised by someone with a bachelor's degree. This simply does not make sense.
I implore the board to reject this petition.
Thank you.
Two years of experience as a QMHP is not equivalent to the education, training, and professional obligations/responsibility of a LMHP. I oppose this petition for rulemaking.
My concern is that the standards, that are suppose to be for safety of the clients continually are being lowered. What is the purpose of licensure? To insure the safety of the public. Once again, you have the least experienced people being empowered to care for some of the most vulnerable people in our community. At least there should be a licensed professional to supervise the care that is given.
The rationale for QMHPs to provide supervision to other QMHPs due to lack of LMHP types available is a ridiculous and watered down reason to encourage this change. QMHPs do not have the skill set or training that a licensed therapist has in order to guide the practice and service delivery for another QMHP. The purpose of supervision is to ensure that we are good stewards of services for the clients we serve. If we change that standard of service delivery we are doing a disservice and harm to our clients and our communities. I strongly oppose this change and continue to advocate for supervision by an LMHP type for all QMHPs.
Thank you for the opportunity to provide public comment. As petitioner, the Virginia Association of Community Services Boards (VACSB) is supportive of these proposed changes which fall into two categories, the second of which involves a guidance document change and therefore not listed on this petition. However, DHP will consider this guidance document change at its September 16, 2022 meeting, so please feel free to comment on the guidance document change as well.
1st A regulation change to allow a hybrid approach to supervision hours where the QMHP-Trainee would complete some supervision hours with a seasoned QMHP who is specifically trained for this supervision, and some supervision with an LMHP.
2nd Allow an undergraduate degree in criminal justice to be added to the Board of Counseling’s guidance document titled 115-8 - Approved Degrees in Human Services and Related Fields for QMHP Registration and to reinstate sociology as an approved degree.
Substance of the Change:
To allow a seasoned (2 years of experience and specifically trained for supervision) Qualified Mental Health Professional (QMHP) to provide supervision to a QMHP-Trainee. Currently regulations only allow an LMHP to provide that supervision. The request is to allow a hybrid approach to supervision hours, where the QMHP-Trainee would receive some supervision from a seasoned QMHP who is specifically trained for this supervision, and some supervision from an LMHP. The seasoned QMHP would provide supervision through-out since the seasoned QMHP is already there working closely with the QMHP-Trainee, and at least two hours a month of supervision would be provided by an LMHP.
Recommended Trainings: The Virginia Association of Community Services Board’s (VACSB’s) Mental Health Council recommends two trainings be developed in partnership with relevant state agencies and providers for approval by DHP. Those trainings would be for:
Recommended Replacement Language for Section C in both 18VAC115-80-40 and 18VAC115-80-50. A QMHP-Trainee’s required work experience must be supervised by an LMHP or a QMHP who is trained for supervision. There must be documentation of at least weekly supervision to address training, provide feedback and address implementation of treatment plans. At least two hours a month of supervision must be provided by a LMHP while a QMHP-Trainee is completing work experience.
Add undergraduate degrees in sociology and criminal justice to the Board of Counseling’s guidance document titled 115-8 - Approved Degrees in Human Services and Related Fields for QMHP Registration.
Rationale:
LMHPs are in High Demand: In CSBs (and some private providers as well) there are not enough LMHPs on staff to provide supervision. Some rural CSBs only have 1-2 LMHPs on staff. Some programs have had to reduce services because they have to hire someone to provide the supervision, which is an inefficient use of resources given that there are most likely seasoned QMHPs on staff who could be trained to provide the supervision. Plus, from a business perspective, for the few LMHPs whom the CSBs do have on staff, their time is best being spent on billable therapy sessions.
QMHPs Can Provide More Specific Training: Seasoned and specially trained QMHPs can provide supervision that is more specific to what a QMHP-Trainee needs to learn and experience for the QMHP profession. The LMHP profession has different roles and responsibilities than a QMHP role. The LMHP may very well have never been trained or worked in the same job responsibilities of a QMHP.
The following are specific tasks or competencies that are unique to QMHPs. Though an LMHP can provide conceptual guidance of these areas, an experienced QMHP can provide position-specific guidance and oversight based on that QMHP’s experience.
Utilize QMHPs to Their Fullest Potential: The current trends in healthcare dictate that healthcare providers need to have the tools available to utilize their staff in the most efficient ways, so more people can be served and so that the provider is running a sustainable business model. One example is for staff to be able to practice to the outer edges of their scope of practice. Allowing seasoned QMHPs to provide supervision is an example of that. With this amendment to the current regulations, CSBs and other providers would be utilizing QMHPs to their fullest potential, which can motivate QMHPs to stay in that role longer and this would be maximizing providers’ investment in staffing costs. As well, this allowance for QMHP supervision would make a large impact in incentivizing QMHP-Trainees to work at a CSB to become a QMHP, because supervision will be more readily available.
CSBs are experiencing serious problems with workforce recruitment and retention, which includes the professions of LMHPs and QMHPs. The goal of this request is to alleviate some of the barriers to registration for QMHP-Trainees and give more time back to the LMHPs to do the work they are licensed and trained to do without changes in adequate supervision to QMHP-Trainees.
The pool of candidates from which CSBs and other providers could draw would be enhanced if a degree in sociology is added back to the Board of Counseling’s guidance document. Removing a sociology degree has created a situation where fewer applicants are eligible for employment. As well, adding a degree in criminal justice to the list of approved degrees would be beneficial because CSBs serve legal-involved populations, provide substance use disorder services and mental health programs for mandated clients. CSBs estimate that only half of the applicants for QMHP/QMHP-Trainee positions meet the requirements because many applicants have qualifying experience, but don’t meet the field of study requirement. Many of those candidates being turned away have a sociology or criminal justice degree. It takes the CSBs an average of 3-6 months to fill QMHP or QMHP-Trainee level positions.
I am in support of the following:
As you are probably aware, the Mental Health Council has been working with VACSB on pursuing a regulation change through the Board of Counseling at the Department of Health Professionals to allow for:
1st A regulation change to allow a hybrid approach to supervision hours where the QMHP-Trainee would complete some supervision hours with a seasoned QMHP who is specifically trained for this supervision, and some supervision with an LMHP.
2nd Allow an undergraduate degree in criminal justice to be added to the Board of Counseling’s guidance document titled 115-8 - Approved Degrees in Human Services and Related Fields for QMHP Registration and to reinstate sociology as an approved degree.
In addition to considering a hybrid approach to supervision and for criminal justice to be an approved degree, I feel there are at least two other matters that should be taken into consideration.
I am a Clinical Trainer and QMHP at Norfolk Community Services Board, and I am fully supportive of the proposed changes to the QMHP requirements. Sociology should have always remained an approved degree. Additionally, having trained QMHP's assist with QMHP-T's is a MUCH more feasible option than requiring LMHP's to provide supervision. There is a known shortage of LMHP's in Virginia at this time, and therefore it is extremely difficult to find LMHP's to supervise our trainees--it's hard enough finding supervision for licensure these days! Thank you so much for considering my comment.
Stephanie Stewart, M.Ed, Management Analyst I/Clinical Trainer
Norfolk Community Services Board
Norfolk, Virginia
I support the changes listed in the VACSB petition. Specifically, the supervision of a QMHP trainee by a QMHP is consistent with the supervision process available with CSAC trainees. While supervision from an LMHP would be beneficial, many LMHP's are not familiar with the roles and tasks of a QMHP and have never worked as a QMHP directly. To obtain the CSAC credential, applicants must follow a prescriptive path of supervision, supervised experience and didactic learning. That process is not unlike the QMHP process until it diverges with the supervision requirements. The CSAC trainee is allowed to be supervised by a CSAC with 2 years experience. Allowing this change would promote consistency among certifications regulated by the board of counseling.
I support the allowance of both sociology and criminal justice as eligible degrees for the QMHP credential. Before the requirements changed, persons with these educational backgrounds provided services to CSB consumers. They brought diversity of thought and experience that was beneficial to the services rendered. These educational backgrounds should not have been excluded and allowing this petition will correct that.
There are many problems with the petition and the responses.
Petitioner requests "The petitioner requests that the Board of Counseling amend 18VAC115-80-40©(1) and 18VAC115-80-50©(1) to allow qualified QMHPs to provide supervision of QMHP-Trainees. QMHPs qualified to provide such supervision would have two or more years of experience and be specifically trained for supervision."
This is very ambiguous. In the first sentence they say "qualified QMHPs..." this is redundant and leads me to believe that they did not do adequate research. Specifically trained is not specific. Would this be a college course? a CEU? Would it require accreditation?
Second, the petition would have additional consequences beyond that of allowing supervision of a QMHP-Trainee by a QMHP with 2 years experience. As noted in 12VAC35-105-20, a QMHP may not engage in independent or autonomous practice. By allowing a QMHP to supervise independently you are removing the LMHP requirement for supervision.
In their comment, the Virginia Association of Community Services Boards stated that they want QMHP's to receive some supervision from a QMHP and some from a LMHP. This is a bad idea that could cause conflicting information, uneducated responses, and discrimination of degree vs position.
I agree that both criminal justice and sociology should be added to the approved fields. I would also support adding the following: anthropology, medicine (non medical practice), speech and language pathology, addiction, drug and alcohol counseling, occupational therapy, chiropractic, naturopathic, communication disorders, and others related.
The Rationale offered by the Virginia Association of Community Services Boards is not acceptable. The rationale seems only to be concerned with the business and practitioner rather than the public safety which should always be first when considering changes. They do not address this even once.
I implore the board to grant and deny in part the petitioners request. Granting the additional specialites for qualification but rejecting the QMHP supervision. I personally believe that the QMHP-C and QMHP-A should be merged and that the requirements are the same. Virginia is the only state that I am aware of that does it like this.
Prof. Michael Moates, MA, LP, LBA, LMHC, LADAC
Adding a Criminal Justice degree to the credential will allow many law enforcement officers and personnel to transition into the mental health field to continue to help others after retirement or making a career change. Criminal Justice degree covers many classes that deals with the mental health population. QMHP A & C is very important when it come to working with the diversity of a population that is showing great deal of youth under the age of 18 and older adults entering into the system after being release from mental health institutions and prison . Reviewing the guideline is very important so adjustments can be made to allow staff to obtain their certification. When the grandfather clause was allowed many mental health employees was able to full filled their duties on a higher level.
1) How would we determine if a QMHP is qualified to provide training to QMHP-T? Is training enough? As someone who hires and works with QMHPs regularly, I see inconsistency in skill levels of QMHPs.
2) I am opposed to sharing LMHP and QMHP supervision. This places an additional burden on LMHP to know what QMHP trainer is doing and increases risk of sharing conflictual information, depending on knowledge, background, and skill set of QMHP.
3) I believe sociology should be added as an appropriate degree. My experience shows that they are just as qualified as someone who has a degree in psychology.
4) If we are going to allow QMHPs to supervise QMHP-T's, might we require QMHP-T's to go through basic training to acquire baseline universal skills like we do for peer counselors - active listening, reflection, non-judgmental stance, empathy, relationship building, crisis intervention skills, etc.?
I agree with the following:
1st A regulation change to allow a hybrid approach to supervision hours where the QMHP-Trainee would complete some supervision hours with a seasoned QMHP who is specifically trained for this supervision, and some supervision with an LMHP.
2nd Allow an undergraduate degree in criminal justice to be added to the Board of Counseling’s guidance document titled 115-8 - Approved Degrees in Human Services and Related Fields for QMHP Registration and to reinstate sociology as an approved degree.
The best training I have ever experienced is direct engagement with someone who knows what it takes and has done the job I am being trained to do. It is essential that we are taught the policies, procedures, and history of mental health professionals. It is also imperative that we learn alongside seasoned specific trainers so that real dialogue can occur about the specifics of the profession, particularly regarding areas that cannot be taught in textbooks or classrooms. I have met many individuals throughout my career who may not have had supervision from a licensed person, but had qualified direct experience that reflected positively in their work.
I just want to point out that the CASC is not a license to practice. It is a certification. It does not authorize mental health practice. I don't see how it compares to the QMHP.
I do not believe the answer to a workforce shortage is to lower the requirements of those delivering or supervising services. The quality of services in Virginia appears to be continuously declining. More individuals seem to be failing to make sustainable progress in services despite being in services significantly longer. With a focus on improving the quality of services received and recovery focused mindset, individuals/families would be serviced more effectively, and in turn this will allow more individuals to be serviced. I do not see how this petition would improve or even maintain the quality and safety of services provided.
Two years of experience should not be the only qualifier considered to ensure an individual is "seasoned" enough to guide/supervise treatment. I would support the allowance of additional degrees to be considered as qualifying towards a QMHP, but would only do so if the level of expertise, education, and training of the supervisor is upheld. Regardless of degree or licensure status, any supervisor should be required to engage in training related to supervision for that particular scope of practice, whether they are supervising a QMHP or a resident working towards licensure.
Thank you for accepting this comment. I am in favor of adding Sociology and Criminal Justice as approved human service degrees for QMHP credentialing in Virginia. Sociology primarily focuses on understanding human interaction and social behavior which is relevant to MH and SUD. Undergrad/Graduate level Criminal Justice education includes rehabilitiative approaches to addressing criminal conduct which is strongly correlated to AOD and MH. The field of Criminal Justice is not simply punitive approaches to changing or deterring behavior, and includes enhanced focus on rehabilitation (especially in Juvenile Justive Systems where QMHPs provide support). The main issue, as Bachelor Level QMHPs are not considered "Therapists" or "Counselors" and can only provide psycho-education and skill building interventions, it is appropriate to approve Sociology and Criminal Justice as approved QMHP degrees as they are human services degrees (helping professionals) similar to Bachelor Level Social Work or Psychology.
Degree Requirements: Crossroads is a rural CSB, and the hiring of quality case management staff is frequently hindered by the degree requirements for for the QMHP registration. We have had to turn away good candidates because of this. It should not be forgotten that case management positions offer people who want to work in the mental health field and entry level work experience, where on the job training is much more significant than the degree. We believe that individuals with criminal justice and sociology degrees are qualified to learn the specific job functions of case management. In the event that we feel they don't have this potential, they will be selected out through the hiring process.
Hybrid Supervision: I support this regulation change as well. While I see the benefit of having some supervision provided by a licensed mental health professional, I see even more benefit to allowing a combination of supervision from two perspectives. Additionally, our clinicians are extremely taxed at present, and with the amount of turnover in case management positions, this just creates one more task for licensed clinicians that may not be essential.
I am in favor of VACSB's petition regarding QMHPs.
Supervision by a combination of QMHPs, with 2 years experience and trained in supervision, and LMHPs is a good way of getting broad look at client issues. While having different supervisors may give conflicting opinions/guidance, people having different opinions will continue throughout one's career.
I am in favor persons with degrees in criminal justice and sociology being eligible to pursue the QMHP.
Both of these will help to address the current mental health workforce shortage. Hopefully, it will also help to address the number of persons with mental illness who are incarcerated due to mental health issues.
I support this petition. When I was an Resident in Counseling I received supervision from another LPC, not a level above LPC. My LPC supervisor needed 2 years experience and the 20 hour supervision course. I believe the key to success with this petition will be the supervisor training provided to the QMHP's, not the number of years of experience.
I am in support of both of these proposed changes!
Adding sociology and criminal justice degrees to the accepted degree list will open the door for agencies to stop missing out on potentially good employees moving forward.
Having a QMHP, that is currently doing the work, supervise a QMHP-Trainee, makes sense. We will no longer be taking time away from other clinicians and their other assigned duties.
Having the education, knowledge and theory is very important, but having actual knowledge based on experience is essential for this job. Being trained by someone with more than 2 years experience is all we want when working on the field.
The proposed changes compromises public safety. 2 years experience as a QMHP is not sufficient to act in a supervisory capacity nor substitutes the clinical guidance and skillset of a LMHP for whom the clinical oversight is intended for.
Secondly, a criminal justice degree prepares an individual for a career path in law enforcement. The curriculum does not provide an adequate foundation in the etiology and treatment of behavioral disorders, which is needed given the SMI population that QMHPs are tasked to work with.
Perhaps the CSB needs to explore their staffing and retention concerns through other methods but this proposal is certainly not the ideal solution.
I think allowing supervision of a QMHP trainee by a QMHP is a great idea, but I do think that it needs to be someone with more than 2 years experience. I think that the supervision should be by a QMHP with 5+ years of experience in the field and there should be training on providing supervision. LPC's and LCSW's are supervised by peers so why not QMHP's. There could be a mechanism for having an LMHP available to the supervising QMHP for consultation if needed.
As for sociology and criminal justice degrees, those should definitely be allowable degrees for QMHP's
I support this petition. I think the supervision training is valuable for QMHP's in supervising QMHP-trainee's. QMHP's with experience and supervision training are capable of supervising trainee's. There is value in QMHP's providing the supervision as QMHP's are providing specific services in the mental health field that are very different than counseling services. LMHP's provide supervision to residents who are eligible for LMHP credential. I see this the same QMHP's providing supervision to trainee's eligible for OMHP credential. These are two very different credentials. Thank you for considering my comments.
The bottom line is QMHPs cannot provide Counseling, nor can they provide Therapy and should not be placed in the same supervision "bucket" as Residents in Counseling. In addition, Criminal Justice degrees are not simply "law enforcement" degrees as some have insinuated. Criminal Justice Curiculuum includes law, system management, detterence as well as rehabilitative programming, and offender interaction skills needed to facilitate changing behaivor.
I am in favor of VACSB's petition regarding QMHPs providing supervision. I am also in favor of Criminal Justice and Sociology degrees as approved degrees for QMHP. Increasing Mental Health needs that are being experienced across the state are outpacing our workforce. Systems are needing to adapt to meet these ever increasing needs, and this may be that opportunity.
Thank you for the opportunity to provide public comment.
QMHPs are essential to the behavioral health workforce responsible for arranging, coordinating, monitoring, evaluating, and advocating across systems to address clients' complex needs. They are most directly involved with helping clients complete the action steps on the ISP. Allowing seasoned QMHPs to provide supervision hours for QMHP-Ts benefits the BH system in two ways. First, it will improve workforce retention by creating career advancement opportunities. Second, many LMHPs have never worked solely within the QMHP scope of practice. Rather, LMHPs scope of practice focuses more narrowly on clinical assessment and intervention. The presumption that LMHPs are uniquely able to impart competency and professional identity to QMHPs simply by virtue of clinical training is misguided. LMHPs provide supervision that highlights the broader clinical and ethical context of client care. However, seasoned QMHPs speak more directly to the application of theory into practice in real-time. Seasoned QMHPs can better assess the QMHP -T within the scope of practice and promote professional identity unique to the QMHP role.
Curricula in Criminal Justice and Sociology address human behavior, social psychology, societal issues, and the legal system - the major themes that human services agencies address in their mission. For many individuals graduating from undergraduate and graduate human service programs, there is a gap between theory and practice that on-the-job training fills. Quality assurance mechanisms are in place at the state level that defines professional development and training for QMHPs. The Board of Counseling outlines continuing education requirements, and the DBHDS Office of Licensure defines training standards to which all direct service employees at licensed facilities must adhere. With these factors in mind, individuals with degrees in Sociology and Criminal Justice are equipped and capable of holding the QMHP credential.
IMPORTANT: If some supervision must be done by LMHP, please include the language LMHP or LMHP-E. Regulations currently allow for a master’s level clinician under supervision toward clinical licensure (LMHP-E) can provide supervision. We do not want to remove this ability and therefore make the requirements more strict.
Thank you for considering the petition and providing an opportunity to comment. I am in support of this petition. It is appropriate and, in my experience, more effective to have someone with the same credentials supervising. It has become redundant and exhausting for agencies to provide two levels of supervision by two different staff. At our agency we have QMHP-A supervisors who have been doing this work effectively and efficiently for a very long time. They are capable and qualified to supervise those trying to achieve the same credentials. Licensed staff can be hard to come by and it is not practical to require them to supervise Residents in Counseling and QMHP-E's, in addition to regular supervision duties. Overtasking licensed staff places the goal of quality supervision at risk. Requiring supervisory CEU’s is appropriate. Our industry does not need more regulations though. We need to set standards within our agencies to address supervisory training.
Pursuant to § 54.1-2400.1:
""Mental health professional" means a person who by education and experience is professionally qualified and licensed in Virginia to provide counseling interventions designed to facilitate an individual's achievement of human development goals and remediate mental, emotional, or behavioral disorders and associated distresses which interfere with mental health and development."
Someone with a bachelor's degree in criminal justice does not have the knowledge, experience, or education to train someone else regardless of experience. I do not object to the degree being a degree that qualifies for the QMHP.
I take issue when that same degree is used to train people on the foundations of "human development goals and remediate mental, emotional, or behavioral disorders and associated distresses which interfere with mental health and development." It is my opinion that that is not the proper foundation to teach or train on those issues.
I do not object to the creation of a QMHP-Supervisor certification to training someone if all of the following are met:
I am in support of QMHP -T supervisions completed by a QMHP-A with 5 years experience. As you are aware, many trainees have degrees and multiple years of training, just not the supervised number of hours required by the BOC. This can be due to difficulty with obtaining verfication from previous employers. Supervision training prior to a QMHP-A being certified to train could also be a requirement. Having the available support of a LPC or LPC-Resident, if needed, would also eliminate any concerns of not having input from licensed individuals. I also support having criminal justice and sociology as continued recognized degrees by the BOC.
I support the proposal of experienced QMHPs supervising QMHP trainees as the proposal specifies that such QMHPs would be trained to provide supervision. I believe this is a responsible use of educated and experienced professionals and not a lowering of the standard.
We are in support to allow QMHPs to supervise QMHP trainees along with LMHPs in a hybrid approach as outlined in the VACSB petition.
I am in support of QMHP Trainees having supervision completed by experienced QMHPs who have access to a LMHP. QMHP supervisors could be required to complete additional training prior to supervising QMHP trainees and pass a competency test. I also support having criminal justice and sociology as continued recognized degrees.