In or about September 2021, I was involved in a single incident that later resulted in a conviction for assault and battery. The incident did not involve a weapon, did not result in serious bodily injury, and has not been followed by any subsequent incidents of criminal or violent conduct. My case proceeded through the Richmond City Behavioral Health Docket, a specialty docket designed to address underlying behavioral health concerns and promote rehabilitation rather than punitive outcomes alone. Due to the nature of that docket, court congestion, and compliance with treatment-oriented conditions, the case remained pending for an extended period. As a result, although the underlying conduct occurred in September 2021, my final conviction was not entered until 2023. Since the September 2021 incident, I have: - Remained arrest-free and incident-free; - Fully complied with all court-ordered requirements; Engaged in treatment and recovery-oriented services; Received certification as a Peer Recovery Specialist; and - Sought lawful employment within the behavioral health field. Measured from the date of the incident, the relevant date for assessing public-safety risk, I have now demonstrated four full years of good behavior. - Application of the Barrier Crime Statute DBHDS applies the barrier crime statute by measuring the four-year “good behavior” period from the date of conviction, rather than from the date of the underlying conduct, without any individualized assessment and without accounting for court-caused delay. As applied to me, this interpretation: - Extends the employment exclusion beyond four years of actual good behavior; - Penalizes participation in a behavioral health specialty docket; - Converts administrative delay into an additional civil sanction; - Bears no rational relationship to present fitness or public safety. Two individuals who engaged in identical conduct on the same date may face materially different exclusion periods based solely on how long the court system took to resolve their cases, a result that is arbitrary and constitutionally suspect. As applied, DBHDS’s enforcement of the statute raises serious concerns under the Fourteenth Amendment, including: 1. Substantive Due Process The automatic extension of a civil employment exclusion based solely on conviction date, rather than time since the conduct, irrationally burdens my liberty interest in pursuing lawful employment and is not rationally related to public safety. 2. Equal Protection The conviction date rule creates arbitrary distinctions between similarly situated individuals and penalizes those whose cases were delayed due to court-imposed or rehabilitative processes beyond their control. These time-based employment exclusions lack individualized assessment and fail to account for rehabilitation, particularly in the context of behavioral health and workforce reintegration. On December 8, 2025, after a rigorous hiring process, I was hired with Chesterfield County Mental Health as a Certified Peer Recovery Specialist on the Assertive Community Treatment team. Our team lead, department manager and Director all agreed on my fitness for the role. After being employed for 30 days, I was terminated due to the DBHDS barrier crimes statute.

These should be basic right standards. These cause less trauma, less injuries, deaths, and for a better society

On behalf of the American Academy of Physician Associates (AAPA), I write to express AAPA’s support for HB 746, which eliminates the requirement for a physician assistant to have a practice agreement with a physician. PAs are licensed clinicians who practice medicine in every specialty and setting. PAs are dedicated to expanding access to care and transforming health and wellness through patient-centered, team-based medical practice. Often serving as the patient’s main healthcare provider, PAs diagnose and treat illnesses, order and interpret lab tests, prescribe medications, perform medical procedures and examinations, and perform key components in surgery. PAs are rigorously educated medical professionals who earn a master’s degree. Incoming PA students must have a bachelor’s degree and have typically completed prerequisite coursework in basic and behavioral sciences and upwards of 3,000 hours of direct patient contact. PA education programs provide classroom training in anatomy, physiology, pharmacology, physical diagnosis, behavioral sciences, and medical ethics. This is followed by at least 2,000 hours of clinical practice rotations in medical and surgical disciplines such as family medicine, internal medicine, general surgery, pediatrics, obstetrics and gynecology, emergency medicine, and psychiatry. HB 746 is a part of the solution to bring greater flexibility to the healthcare system by allowing PAs to deliver care where they’re needed without unnecessary administrative burdens mandated by the state. This is about expanding access to care and ensuring the state fully leverages the education, training, and experience of its PA workforce. Most importantly, these changes would improve access to care for patients. As one of the fastest growing medical professions, PAs are positioned to make a positive and lasting impact on patient care. Public opinion research, conducted by The Harris Poll, found that patients overwhelmingly support PAs as part of the solution to address the shortage of healthcare providers (91%). They recognize that PAs increase access to care and make medical appointments easier to obtain (90%). A new study “Medical Malpractice Payment Reports of Physician Assistants/Associates Related to State Practice Laws and Regulation” published in the Journal of Medical Regulation examined 10 years of medical malpractice payment reports compared to the laws and regulations of states for the same time period and found that states with more permissive practice environments compared to restrictive states had no increased risk of PA medical malpractice payment reports. The research also determined that almost all PA practice reforms (such as allowing PAs to practice in collaboration or without a formal relationship without a physician) lead to a reduction in medical malpractice payment reports for PAs and physicians. AAPA is committed to improving patient access to care. Removing barriers to PA practice and improving the regulatory environment in Virginia is an essential component of that. We appreciate the opportunity to provide input on this legislation and look forward to addressing access issues in Virginia.

Support for Alternative Pathways to Practice for Experienced Substance Abuse Professionals In support of Bill HB1282 Members of the Committee, I respectfully urge you to consider legislation that creates alternative pathways to practice for individuals who possess extensive experience and education in substance abuse treatment but do not currently hold a valid state license. Why this matters 1. Addressing the Workforce Shortage Our state is facing a critical shortage of qualified behavioral health and substance abuse professionals. At a time when overdose rates, mental health crises, and treatment waitlists continue to rise, we cannot afford to exclude capable, experienced individuals who are ready to serve. 2. Valuing Real-World Experience Many professionals have spent years working in recovery support, peer services, community programs, case management, or prevention education. Their hands-on experience with high-risk populations often exceeds the practical training of newly licensed professionals. Alternative pathways allow the state to recognize competency gained through experience, not just traditional academic routes. 3. Expanding Access to Care—Especially in Underserved Areas Rural and low-income communities are disproportionately affected by provider shortages. Allowing experienced practitioners to qualify through supervised practice, competency exams, or provisional credentials can rapidly expand access to lifesaving services. 4. Supporting Recovery-Oriented Systems of Care Individuals with lived experience and long-term recovery work bring credibility, cultural competence, and trust to the populations they serve. Research consistently shows that peer-informed and experience-based support improves engagement and retention in treatment. 5. Maintaining Public Safety While Increasing Access Alternative pathways do not lower standards—they modernize them. Requirements such as: • Supervised practice hours • Background checks • Competency examinations • Continuing education • Time-limited provisional licenses ensure accountability while removing unnecessary barriers. 6. Economic and Community Impact Expanding the qualified workforce reduces emergency room use, incarceration costs, and lost productivity. Every additional trained provider increases treatment access, supports family stability, and strengthens community health. Conclusion This bill is not about lowering professional standards—it is about recognizing competence, expanding capacity, and responding to a public health emergency with practical solutions. By creating structured alternative pathways, the state can responsibly bring experienced, dedicated professionals into the workforce and save lives. Thank you for your consideration and your commitment to improving behavioral health care in our communities.

Based on my professional experience as a certified addictions counselor in Virginia, I have directly observed that counselor competence and therapeutic effectiveness are driven more by the quality and depth of supervised clinical experience than by performance on subjective or exam-based assessments alone. I was trained by highly experienced clinicians who were grandfathered into licensure and whose extensive practical expertise, clinical judgment, and application of evidence-informed treatment models—including structured use of 12-step recovery frameworks—significantly enhanced treatment engagement, retention, and recovery outcomes. This experience underscores a critical distinction in counselor preparation: standardized testing may assess theoretical knowledge, but it does not reliably measure clinical skill, therapeutic alliance, ethical decision-making, or real-world treatment effectiveness. These competencies are developed through sustained, supervised practice with diverse client populations. Establishing an alternative licensure pathway that places greater emphasis on supervised clinical experience would strengthen the counseling workforce without compromising quality of care. In the context of a nationwide shortage of mental health and substance use disorder professionals, this approach preserves clinical rigor, expands access to qualified providers, and prioritizes therapeutic outcomes and public safety.

To Whom It May Concern, I am writing in strong support of House Bill HB1282 (Cole, J.G.), a bill that is both timely and necessary in addressing the ongoing substance use and addiction crisis in the Commonwealth of Virginia. Virginia continues to face a critical shortage of qualified and accessible substance use treatment providers. This shortage has serious consequences. Individuals and families seeking help often encounter long waitlists, limited provider availability, or barriers that prevent experienced professionals from practicing to the full extent of their training and expertise. House Bill HB1282 directly addresses these challenges while maintaining the integrity and standards of care within the substance abuse treatment field. Importantly, this bill does not lower or weaken professional requirements. It upholds established standards, ethical obligations, and competency expectations for practitioners. What it does recognize is that experience matters—especially when professionals have spent ten or more years practicing under supervision and meeting all required standards. House Bill HB1282 responsibly removes unnecessary barriers for long-standing, qualified professionals who have already demonstrated competence and accountability. Requiring indefinite supervision for individuals who have fulfilled all expectations serves as an administrative obstacle rather than a public safety safeguard. This bill allows those practitioners to move forward with full credentialing while remaining subject to licensure requirements, ethical oversight, and regulatory accountability. Additionally, this bill expands access to care at a time when access is urgently needed. Virginia is facing a fentanyl crisis, with overdose deaths continuing to rise and families and communities suffering profound loss. Every barrier that delays treatment increases the risk of preventable harm and loss of life. Substance use disorder is a complex, chronic condition that requires timely, consistent, and qualified care. When experienced providers are restricted from practicing independently, those seeking help are the ones most affected. House Bill HB1282 strengthens Virginia’s treatment infrastructure by retaining experienced providers, increasing access to care, and ensuring professional standards remain intact. This legislation is not about convenience—it is about capacity, safety, and saving lives. For these reasons, I support House Bill HB1282 because it addresses provider shortages, maintains professional standards, removes unnecessary barriers for qualified practitioners, expands access to care during an overdose crisis, and has the potential to save lives. I respectfully urge support for this bill and thank you for your continued commitment to the health and well-being of the Commonwealth of Virginia. ---

I support this bill provided that the person has the proper degree and experience in this field.

I support HB1282 as a result of the specific professional requirements met as a result of experiential learning: Certified as a substance abuse counselor for at least 10 years and is actively practicing; Completed a master's degree within appropriate field of counseling; Completed a minimum of 5 years of documented supervised experience; and holds a Master Addition Counselor credential issued by the professional organization NAADAC supersedes any further required examination as a result of the experiential years of knowledge actively acquired within the counseling field.

Support for Alternative Pathways to Practice for Experienced Substance Abuse Professionals In support of HB1282 Members of the Committee, I respectfully urge you to consider legislation that creates alternative pathways to practice for individuals who possess extensive experience and education in substance abuse treatment but do not currently hold a valid state license. Why this matters 1. Addressing the Workforce Shortage Our state is facing a critical shortage of qualified behavioral health and substance abuse professionals. At a time when overdose rates, mental health crises, and treatment waitlists continue to rise, we cannot afford to exclude capable, experienced individuals who are ready to serve. 2. Valuing Real-World Experience Many professionals have spent years working in recovery support, peer services, community programs, case management, or prevention education. Their hands-on experience with high-risk populations often exceeds the practical training of newly licensed professionals. Alternative pathways allow the state to recognize competency gained through experience, not just traditional academic routes. 3. Expanding Access to Care—Especially in Underserved Areas Rural and low-income communities are disproportionately affected by provider shortages. Allowing experienced practitioners to qualify through supervised practice, competency exams, or provisional credentials can rapidly expand access to lifesaving services. 4. Supporting Recovery-Oriented Systems of Care Individuals with lived experience and long-term recovery work bring credibility, cultural competence, and trust to the populations they serve. Research consistently shows that peer-informed and experience-based support improves engagement and retention in treatment. 5. Maintaining Public Safety While Increasing Access Alternative pathways do not lower standards—they modernize them. Requirements such as: - Supervised practice hours - Background checks - Competency examinations - Continuing education - Time-limited provisional licenses ensure accountability while removing unnecessary barriers. 6. Economic and Community Impact Expanding the qualified workforce reduces emergency room use, incarceration costs, and lost productivity. Every additional trained provider increases treatment access, supports family stability, and strengthens community health. Conclusion This bill is not about lowering professional standards—it is about recognizing competence, expanding capacity, and responding to a public health emergency with practical solutions. By creating structured alternative pathways, the state can responsibly bring experienced, dedicated professionals into the workforce and save lives. Thank you for your consideration and your commitment to improving behavioral health care in our communities.

To whom it may concern, I am reaching out regarding House Bill, which I support for the following reason: Firstly, there remains a significant shortage in Virginia concerning the treatment of individuals with addictions. Secondly, this bill does not reduce the standards expected in the substance abuse field. Thirdly, it removes barriers for those who have practiced for over a decade under the supervision of a licensed professional. This change will enable these individuals to pursue credentialing independently, as they have fulfilled all necessary requirements. I firmly believe that this bill has the potential to save lives, especially in light of the ongoing fentanyl crisis, which continues to claim lives due to drug overdoses. Thank you for your time, Kevin Williams

To whom this may concern, I am grateful for this platform and opportunity to present my reasons for supporting the aforementioned bill. This bill establishes an additional licensure by endorsement pathway for substance abuse treatment practitioners who meet defined education, experience, and credentialing requirements. It does not replace existing licensure pathways or remove current regulatory standards. Eligibility under this pathway requires at least ten years of certification as a certified substance abuse counselor, a minimum of five years of documented supervised experience, a master’s degree in an appropriate counseling-related field, and a Master Addiction Counselor credential issued by NAADAC. These criteria reflect long-term professional practice and formal training. Virginia continues to experience increased demand for substance use and mental health services. Workforce shortages in these areas have contributed to delays in access to care. This proposal supports workforce capacity by allowing the Board of Counseling to recognize professional equivalency for a limited group of experienced practitioners, reducing unnecessary administrative barriers while maintaining existing safeguards. The pathway does not eliminate public protections. All education, supervision, and credentialing requirements remain in place. It provides a more efficient route to licensure for practitioners who have already demonstrated sustained competency through years of regulated practice. Respectfully, Elison Epperson Angelo Recovery, Office Assistant

I support HB1282-Cole because I believe we still have a shortage in the state of Virginia when it comes to treating people that have addictions. Reason two. This bill does not lessen the requirements that is expected to be in the substance abuse field. Reason three. This bill also take away any barriers for someone who's been practicing for over 10 years under supervision of another licensed person. This will give that person the opportunity now to be able to go forward with all of the credentialing without any forms of supervision because they've done it all and what was required of them. I believe this bill will help to save lives due to the fact that we have a fentanyl crisis and people are still dying from overdosing drug addiction.