Dear Virginia Board of Counseling, 

I am echoing Dr. David Mikkelson's mathematical concerns concerning the new change in residency supervision ratios. 

I am asking the Board to consider the mathematical impact of removing the indirect or ancillary hours from the computation of hours ratio of supervision per clinical experience. I recommend new parameters of supervision per direct client hours be a maximum of 1:7 and a minimum of 1:25. Maintaining the current maximum rate (or pace) of supervision at 4:40, or 1 hour of supervision per 10 direct client hours, will ensure that nearly every resident will be required to go beyond 200 hours of supervision and 2,000 direct client hours in order to get licensed.

Mathematically, if the required overall supervision rate is 1:10 (200: 2,000), and the maximum rate is also 1:10, a resident ever falls behind this ratio has no way to “catch up” by going faster than 1:10 at some point. This will add months to residency and cost nearly every resident in the state thousands of dollars in extra supervision cost and in delayed full licensure, probably by several months.

Please consider this realistic example. In the old system, a resident’s quarterly report could state 200 direct client hours and 100 ancillary hours for a clinical experience of 300, and 15 hours of supervision. This is a 15:300 ratio or 1:20 which is perfectly allowed, yet the resident is 5 hours “behind” their overall ratio of 1:10 supervision; they should have done 20 hours of supervision for 200 direct client hours, but they only did 15. This has been no problem if in the next quarter they again do 200 direct client hours, 100 indirect hours, and now do 25 hours of supervision. This is a 25:300 ratio or 1:12 which is perfectly allowed, and the resident now has completed 400 direct client hours and 40 hours of supervision. Perfect. This back and forth rhythm was always allowed and matched the realities of clinical life and the shifting availability of supervisors, vacations, bad weather, client attendance, months of short finances, etc., and most residents could arrive at 200 and 2,000 within the same month.

With the same realistic example of two quarters under the new system, the resident will have 400 direct client hours but only 35 supervision hours will be counted by the Board. Why? Because in the first quarter you are now only counting their direct hours, and 15:200 is a 1:13 ratio and is allowed. But in the next quarter the resident did 25:200, a ratio of 1:8 which is NOT allowed, and the Board will only give the resident credit for 20 hours of supervision for 200 direct client hours, since the maximum, or fastest, ratio is 1:10. So now they have 35 hours of supervision and 400 direct client hours, still behind. If they try to catch up the next quarter, or in any quarter, by doing 25 supervision hours for 200 client hours, the Board will never count more than 20 supervision hours for the 200 direct client hours, even though they keep doing 25.

In the past, if a resident did 5 quarters of “5 hours behind” in supervision and 5 quarters of “5 hours ahead” in supervision, they arrive at 200 and 2,000 no problem. Now, this same rhythm that occurs in real life will result in 2,000 direct client hours completed but only 175 hours of supervision counted by the Board, and now the resident must do and pay for an extra 25 hours of supervision. Of course, at a maximum rate of 1:10, now they must also do an additional 250 direct client hours, about 4 months of extra residency. The resident will actually be required to do 225 hours of supervision and 2,250 direct client contact hours in order to complete residency.

I predict very few supervisors will be willing to spend less than 1 hour of supervision per every 25 direct client hours, as protection of clients and clinician development become lost in the flurry of hours. The previous (current) minimum rate of 1:40 worked because 15-20 of those 40 hours were ancillary hours, and only 20-25 were direct client hours. Under the new rules, the minimum rate needs to be adjusted to the new reality of applying only to direct client hours. Likewise, a maximum ratio of 1:7 would allow a resident doing 200 hours in a quarter to count 28.5 hours of supervision, creating space for “catch up” without going so fast that supervision becomes “check the box.”

My proposed change also supports the common practice of accelerated supervision in the first 6-12 months, providing supervision at a slightly faster rate when the resident needs it most, and then supervision can slow down in the last 6-8 months when the resident needs it less. Of course, every quarter falls within the prescribed limits.   

As one might recognize, the Board’s new rule will only work if the resident reports exactly a 1:10 ratio in every quarter of residency, never getting even 1 hour ahead or behind. I doubt anyone is able to choreograph this kind of ratio in real life.

Thank you for considering my recommendation to adjust the supervision ratio to a maximum ratio of 1:7 and a minimum ration of 1:25 for each quarterly report.