I am concerned with the proposed removal of allowing excess hours accrued during internship to be counted toward residency. These hours are performed under supervision, and allowing up to 300 excess internship hours to be applied to the total hours required for residency would further encourage the fast track licensure these regulations aim to support. 

As others have stated, no longer allowing supervision hours accrued during internship creates a significant barrier in earning the required supervision hours in residency.