I would like to support the proposed petition. The current guidelines and regulations do not address CACREP Doctoral practicum and internship hours/supervision.  Doctoral practicum and internship hours/supervision in a CACREP accredited Doctoral Counseling programs should be accepted towards residency hours if the professor/supervisor has an active LPC license and meets the supervision training requirements outlined by the current regulations.  This petition should be approved based the VA Counseling Board's precious decision to accept clinical hours in a CACREP master’s program and supervision. Doctoral Level Counseling Programs hours that adhere to the CACREP guidelines provide more extensive clinical work, experience, and supervision.  Doctoral students in CACREP program are carefully overseen by licensed professors and supervisors with NCC and ACS credentials.  Additionally, within the Master’s level internship course, students are not obligated to register their supervisors and those hours are counted in access of 600 hours up to 900 along with 20 hours of supervision. There continues to be an increase of CACREP accredited doctoral counseling and counseling education programs in Virginia. It is imperative that VA Counseling Board address the doctoral students’ unique clinical experience and acknowledge their commitment to the counseling profession and community.