I do support the proposal submitted by Joyce Samples.   I too am concerned about LPC's who do not have clinical experience of actually working with clients, becoming supervisors.  This to me, is not providing adequate supervision to resident.

I support the petition to increase the time frame from two to five years of post-licensure experience for supervisors who provide supervision to residents. I've seen a lot of inexperienced supervisors providing supervision to others after only two years of work in the field, which is ultimately to the potential detriment of those we serve. Increasing the time frame (or having the individual document clinical experience in all areas) will enhance the supervision offered to residents (F.2.a) and increase their gatekeeping capacity (F.6.b) to our profession. 

I have supervised residents who told me that they "didn't get much from their first supervision experience because that supervisor was not knowledgeable about supervision or supervision in that resident's area of interest. I think that the regulation as proposed is a much needed change.

As it stands, it can be difficult for a new graduate to locate a supervisor. I think pushing the requirement out to 5 years would put an unnecessary burden on these new counselors.

New supervisors are already required to submit evidence for 20 continuing hours which should cover all clinical areas. 

I would suggest that instead of increasing the requirements to become a supervisor, instead add a requirement to remain a supervisor by requiring 5 continuing education hours annually in supervision. 

I can agree with new supervisors needing to document working in various clinical areas during the 2 years post-licensure. 

I support this change in supervision requirements as I believe supervisors need the five year time period to develop their own clinical skills and understanding as well as continue their training prior to supervising other clinicians. Clinical skills are developed in the doing of counseling far more that in classroom/book training or learning (not that these aren't vital as well). Supervisors need to have had the time to hone and deepen their clinical skills experientially prior to supervising other clinicians. 

I am strongly opposed to the proposed changes to the qualifications for supervisors of residents in counseling. Increasing requirements to 5 years post licensure would result in fewer qualified supervisors making it harder for prospective residents to get supervision. Secondly, this proposal doesn’t specify that the increase to 5 years include clinical practice, so the concern may not even be changed with the proposed additional time. Lastly, supervisors should not supervise outside her/his areas of expertise and this is what should be stressed and monitored to address the presented concern.

A interim time frame will need to be established to maintain a level of supervision vice the immediate enforcement of the new regulation..  Also, 5 years of seniority in the field doesn't always provide the best candidate, especially if only minimally successful applicants are available to apply. 

It seems inappropriate to implement this change to all providers as each individual's experience may vary during their time in the field.  Many individuals submerge themselves in various fields, working with a diverse clientele, making them completely qualified and competent to supervise within a 2 year time period.  To date, many residents experience difficulty locating and maintaining clinical supervisors.  Making this change, would increase these challenges for residents and present more barriers during residency.  A better approach would be increasing the amount of continuing education needed for those in a clinical supervisor role 

Amending the requirements for qualified supervisors from 2 to up to 5 would be helpful to training Residents appropriately. Supervisors should have a clinical caseload to assist them with continuing to develop their clinical skills. 

An increase of experience after licensure in order to provide supervision is ideal, but would prove very detrimental in Southwest Virginia for increasing the workforce. The workforce shortage limits service availability for the individuals we serve currently and expanding the requirements now would limit this further. According to the Virginia Medicaid Continuum of Behavioral Health Services report by the Farley Center, "Of the 133 counties in Virginia, 87 (65%) were designated by the Health Resources and Services Administration as Mental Health Professional Shortage Areas in 2018. Significant regional variation exists, with the greatest workforce shortages in the Southwest and Southside regions." Because of this workforce shortage, many people who become licensed do move into administrative roles due to requirements for supervisors to be LMHP type staff. It is difficult to fill LMHP type positions in Southwest Virginia and it is difficult for staff to find supervisors. I would also like to point out this information from the Continuum report as well, "Virginia ranks 40th in terms of access to behavioral health care in the nation. Virginia also ranks 41st in terms of availability of mental health providers, as measured by a ratio of population to providers." I believe this would be better served as a long term goal for the board as we build our work force. 

Early in my career, I was privileged to work with someone who came late in life to her Masters/license, but had a long history of working in addictions and mental health.  Her experience was invaluable, and the quality of the supervision she provided was unparalleled in an area already starving for qualified supervisors. This proposal would likely have been a deterrent for her to even seek a Master's degree/license, and the residents she has supervised over the years would have missed out. To burden this area of far southwest Virginia by more than doubling requirements we are already struggling to meet seems to serve the purpose of making those available supervisors EXTREMELY marketable, perhaps increasing opportunities to do nothing more than provide supervision, but I fail to see how it will help us meet ever increasing Medicaid requirements for licensed providers by creating a bottleneck for residents needing supervision.  

-- I agree that a supervisor should document clinical rather than administrative work experience in order to be a supervisor.  I disagree that the experience should be extended to 5 years before being allowed to supervise.  There are other alternatives to addressing supervisor competency.

-- First, I would like to explain how I’ve come to my response to this petition: I have been a supervisor in Virginia for over 20 years and I am a provider of the 20 hours of Clinical Supervision Training required for LPCs and LMFTs to supervise residents and as such have trained many supervisors over the years.  I have been the Supervision Chair of Northern Virginia Licensed Professional Counselors (NVLPC) for 6 years, a NVLPC Resident Support Group leader for several years, and have researched and written multiple NVLPC newsletter articles on Virginia supervision topics.  In these volunteer positions I have assisted many supervisors and residents in navigating the process of attaining licensure.  (Note that the opinions I express here are my own and do not reflect the opinions of NVLPC.)

-- I have heard about many situations of inadequate supervision based on ignorance, misunderstanding, and/or misinterpretation of the regulations by supervisors (and residents).  So, I understand the need for amendments to the requirements.

-- However, I believe that extending the requirements for supervising from two years to five years is too extreme at the present time. There are currently about 8,700 LPC residents and about 300 LMFT residents according to the Board with the caveat this number may be inaccurate. There are about 2000 supervisors listed on the Board website which I also think is not accurate, but in lieu of any other numbers, I’m using them. That’s a 4 to 1 ratio.  With more students graduating every year there are already not enough supervisors to meet the need and there would be a shortfall during a 3-year extension period.  I’ve been told multiple times by graduates that it has taken them months to find a supervisor because those they contact don’t return their calls and if they do, say they have no openings.  Extending the time-frame to 3-5 years of experience can be revisited when there are more licensed clinicians available to provide supervision. 

-- I believe the answer to assuring quality supervision is in the supervisor training requirement itself. My recommendations are: 1. Require only in-person post-graduate Clinical Supervision Training in Virginia because graduate courses and on-line training (which are currently allowed) are generic and not state specific and therefore don’t address the Virginia requirements; 2. Require that the Clinical Supervision Training concentrate at least 5 of the 20 hours specifically on the Virginia regulations and requirements, review of the Virginia forms, and navigating the Board of Counseling website; and 3. Require a new supervisor to have a specific number of supervision of supervision hours (for example, 10 hours) from a supervisor who has 5 + years of supervision experience or who has the ACS (Approved Clinical Supervisor) credential.  An alternative to #3 would be to require that LPC/LMFT supervisors take a minimum of 5 hours of the yearly required 20 continuing education hours specifically on the topic of supervision every year.

-- Lastly, the 2-year requirement should be defined more clearly.  I recommend that the experience be redefined and based on 2 years of full-time, 40 hours a week, clinical experience or the equivalent if part-time (for example, 4 years if the experience is half-time clinical work).

I agree that the requirements to become a board approved supervisor in VA does need to be amended.  I agree that the requirements need to require the supervisor having more clinical experience post licensure.  Perhaps, if it is 5 years post licensure, that could include someone who has had their 5 years post licensure experience in VA, or if part of their years of post licensure experience was in another state, then that should be added into the 5 years.  I would consider grandfathering any currently registered supervisors to stay supervisors if they have under 5 years if this goes into place in near future.  

Due to the vast mental health workforce shortage and increased need for mental health and addiction counseling, I strongly oppose this proposed regulation. This is a time when we need more qualified supervisors to launch LPCs who can address such issues as community violence prevention, trauma informed care, and increased suicidal ideation. We need more supervisors to ready our next cohort of licensed professional counselors. Do these supervisors need to be trained and experienced? Absolutely! Raising the number of years of experience post licensure does not guarantee that quality supervision will be provided. Instead of further restricting the job possibilities of LPC’s, let’s invest as a state in training top notch Virginia supervisors.

I would have to agree increasing the clinical experience and education required to supervise residents would in the long run benefit both the profession and the population served in the state of Virginia. I understand there will be challenges and this would likely take some time to implement however that does that not mean we should not consider making some needed changes.