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