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.