We are writing in response to the “Petition for Rule-Making,” regarding 18VAC115-50: Regulations Governing the Practice of Marriage and Family Therapy, dated 9/16/2019 and submitted by David and Suzanne Mikkelson. At issue is the number of “relational” hours required during the internship (18VAC115-50-55) and requesting a reduction of those hours from 200 (of 240) to 120 hours. The Virginia Association for Marriage and Family Therapy (VAMFT) recognizes and understands the difficulties faced by students in acquiring those hours deemed “relational,” i.e., with more than one related consumer in the counseling room. The points brought up by the Mikkelson’s are valid and have been considered and debated for some time within the family therapy community.

As VAMFT sees and understands this dilemma, we are faced with two competing ideas. The first idea strikes to the very basis of the profession of marriage and family therapy and that is that the training and experience requirement to become a licensed marriage and family therapist (lmft) is strictly defined as the ability to work in a therapy space with more than one consumer. That difference in training and experience is, by definition, what makes our training, experience and supervision unique and has led to the creation of a license that is separate from other mental health professionals. In order to achieve expertise and some assurance of safety to the consuming public, we must be assured that persons granted a degree in mft and subsequently licensed as mft’s do have, in fact, the ability to competently navigate in that relational space. It is, of course, arguable as to how many hours would give some assurance of this expertise and presumed safe practice. VAMFT believes that reducing the relational hours in the internship, as currently mandated, would jeopardize the creation of the core of experience that someone heading for independent practice should have.

The second, and somewhat opposed concern is, as outlined by the Mikkleson’s, the difficulty in assuring that students can get the relational hours in a typical internship setting. Aside from those agencies providing intensive in-home services, an unlicensed intern has few chances to work with more than one designated consumer at a time. In the COAMFTE guidelines, the 500 hour requirement is somewhat modified by the ability to count up to 100 hours in “alternative hours or clinical activity (e.g., couple or family groups; live cases where reflecting teams are directly involved…, etc.) (pg. 33 of COAMFTE Accreditation Standards Version 12.0; Effective January 1, 2018) (Bold in original). Use of those hours, also not always available in an internship site, would make the 200 hour requirement at 50%. The somewhat reduced hourly requirement established by COAMFTE is based on the reality that students in an on-going program of mft will be surrounded by others working from the same systemic bedrock that is rarely the milieu in residency settings. If VAMFT had its way, more internship sites would be using family therapy as a model for treatment and even when individuals are seen (as the Mikkelson’s highlight), the therapist’s focus on the relational rather than the intrapersonal field. Short of allowing interns and residents who are seeking degrees or licenses in mft and receiving mft-based supervision (VAMFT’s fondest wish), the dilemma remains. Both of the undersigned are Approved Supervisors with AAMFT and both supervise interns and residents who are seeking education and licensing as mft’s. Both believe that, regardless of the number of consumers in the room with the therapist, the therapist is performing family/relational therapy.

In light of all the above, we would not like to see any diminution in the required experience that aspiring mft’s accrue during either their internships or their residencies. We are concerned that the goal of possible portability of the license would result in all standards being devolved to the lowest common denominator. It is difficult to imagine any state regulatory body being willing to increase the requirements for licensing in their jurisdictions. We would, reluctantly and in light of the dilemma outlined above, be willing to support a reduction in those relational hours to 180 of the total of 240.

William Scott, Ph.D.

President, VAMFT

Arnold Woodruff, LMFT

Executive Director, VAMFT