June 28, 2017
We were invited to participate in the RAP (Regulatory Advisory Panel) at DHP (Department of Health Professions) this week to discuss the new requirement for the QMHP Registry. While no decisions were made, the conversation suggested
- The current QMHPs who are employed by a licensed provider (who is responsible for verifying their credentials under the current system) may be “grandfathered” into the registry with a minimum of paperwork. This could avoid what would inevitably be a long and difficult process of “standing up” the system. This would include all those who were granted “variances” prior to February 11, 2011.
- Those QMHPs who are also professionally licensed in the Commonwealth may not be required to register, though there was discussion about their scope of practice and/or experience as a qualifying factor.
- There will be a close look at exactly what experience is required vis-a-vis the definitions promulgated by DBHDS and how to articulate the experience received. And,
- There was clear understanding of the QMHP-E category and the necessity of keeping it as an option; there was not discussion about relaxing the rules for establishing a QMHP-E program.
There will be more opportunity for comment and participation when something more definitive is available.