I am an LCSW who provides licensure supervision for supervisees in Social Work as well as residents in counseling en route to their independent licensure.

This regulation change would further harm pubic access to needed counseling services for mental health needs, by shrinking the pool of qualified providers.  Many licensure candidates struggle to find positions where they can build their expertise with qualified supervisors.  Making it so that candidates could not provide this service, while in their residencies under supervision of persons already holding the credential would not support the training routes for practitioners of the future. 

Most people are aware that medical doctors serve a residency under supervision of more experienced doctors.  Clinical social workers and counselors in training have an analogous route for their training as well.  And this serves a cost containment purpose for services overall.  If these regulations were passed, more expensive care from practitioners who are already licensed would be in demand; or the services just wouldnt be there.  Please dont be so short-sighted.  Mental health emergencies strike all socio-economic groups, when you or a loved one needs mental health care, you want a robust service system with a range of providers, to be there!