I disagree with this requirement

1. We already have regulations requiring supervision training and yearly ethics CEUs. 
2. Adding another regulation is unnecessary, burdensome and paternalistic. At some point, clinicians have to be responsible for their own ongoing education.
3. This is going to be a waste of time. It is already difficult to find engaging yearly ethics trainings (especially for those of us who have been doing this for many years), how are we going to get “useful” supervision information every year. 
4. If you must do something like this, what about the following compromise options
   1. Allow supervisors to substitute ethics CEU requirements for supervision CEUs.
   2. Require supervision CEUs in a longer period of time – for example, there needs to be 2 supervision CEUs every three years.
   3. Define "Supervision CEUs" broadly so as to include cultural competence, training in specific therapeutic interventions (a DBT program supervisor can use training in DBT for their supervision CEUs, training in motivational interviewing is clearly applicable to supervision tasks), supervisors who meet for peer supervision with other supervisors can count their hours in supervision (2 ours of peer supervisor supervision = the 2 CEUs requirements), etc. 
   4. Allow supervisors to substitute pro bono supervision for all the CEU requirements. For example, the Virginia Telemental Health organization needs clinical supervisors. So supervisors who provide 6 months of weekly supervision pro bono are allowed to use that supervision in place of their required 20 hours of CEUs per year.

In summary, providers are ethically required to have continuing education. Adding undue requirements regarding the type of education (2 hours of ethics AND 2 hours of supervision) CEUs is unreasonable.