Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Counseling
 
chapter
Regulations Governing the Registration of Qualified Mental Health Professionals [18 VAC 115 ‑ 80]
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8/23/22  12:06 pm
Commenter: Prof. Michael Moates, MA, LP, LBA, LMHC, LADAC

Argument Based On Law
 

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:

  1. The QMHP has 3,000 hours of experience. 2 years is not a good criteria as someone could work 1 day a week for 2 years. 3,000 hours is specific.
  2. The 3,000 hours were done under a medical doctor, counselor, psychologist, behavior analyst, addiction counselor, someone authorized by the state within the scope of practice, or QMHP-Supervisor.
  3. The QMHP holds a bachelors degree or higher in psychology, counseling, sociology, anthropology, public health, social work, addiction counseling, special education, etc. or... holds a license by the Commonwealth of Virginia in an educational field that does not qualify as a Licensed Mental Health Professional.
CommentID: 127402