I agree with removing ancillary hours while upholding the 200 hours of supervision requirement for residency.  However, I would like to echo Amy Bullin’s concluding comment: “I respectfully urge the Board . . . to continue allowing the 20 hours of internship supervision to count toward the 200-hour residency requirement. Maintaining this provision would support new professionals, uphold training quality, and better align with the stated intent to streamline and modernize the licensure process.”

Finally, I would strongly support Dr. David Mikkelson’s comments and rationale leading to his insightful recommendation “to adjust the supervision ratio to a maximum ratio of 1:7 and a minimum ration of 1:25 for each quarterly report”.   

Thank you for your consideration.