While the revisions are described as a “reduction” in total hours, they actually increase the supervision requirement by removing the ability to count the 20 hours of internship supervision toward the 200-hour residency supervision total. In practice, this change adds additional supervision hours — and therefore additional cost and time — to the licensure process. Most residents pay for supervision out of pocket, and the removal of these internship hours would increase both financial burden and the duration of residency, despite the stated goal of reducing barriers to licensure. Internship supervision is already provided under close oversight from qualified supervisors and academic programs. Those hours represent legitimate, structured supervision that directly contributes to a resident’s professional development. Excluding them diminishes the value of accredited internship training and creates an unnecessary redundancy in supervision. This proposed change would disproportionately affect new graduates, lower-income residents, and those working in rural or underserved areas, where finding and affording qualified supervisors is already challenging. It also risks discouraging new professionals from entering the counseling field at a time when access to mental health care in Virginia is critically needed.

I respectfully urge the Board to reconsider this portion of the proposal and 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.