The VACSB represents the 40 CSBs in matters of policy related to behavioral health and developmental disability matters. The VACSB does not support these regulations because we believe they will add to the already existing workforce challenges that CSBs struggle with statewide.

1. Requiring an LMHP to provide supervision to a QMHP will put an unnecessary burden on the role of the LMHP. CSBs struggle, especially in rural areas, to hire LMHPs and requiring them to provide additional supervision of QMHPs would cause LMHPs to leave the CSBs or leave the LMHP field all together. As well, because an LMHP has different roles and responsibilities than a QMHP, VACSB feels that having an LMHP provide the supervision is counterproductive to the purpose of supervision. A QMHP with a number of years of experience would be a more appropriate fit for providing supervision to a QMHP in need of supervised hours.

2. Changing the supervised hours to 1500 puts a tremendous burden on CSB staff to fulfill this requirement. As well, it is even more of a burden because a licensed staff person is required to provide these supervision hours.

3. Also contributing to the workforce issue is that supervision hours that have occurred in other states cannot be counted toward a QMHP registration. VACSB disagrees with this requirement.

4. The VACSB supports having a Sociology degree on the list of human services degrees that qualify an individual to become a QMHP.