Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Counseling
 
chapter
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]
Action Reduction of residency requirements
Stage Fast-Track
Comment Period Ended on 12/3/2025
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11/24/25  8:48 pm
Commenter: Mary Brown

Agreeing with Dr. David Mikkelson's concerns
 

I hope you will consider Dr. David Mikkelson's excellent point tha the carefully described with specific mathmatical examples.  He pointed out that the new ratio will cause a resident to more than likely have to do more hours directly beyond the 2000 in order to reach the proper amount of supervision, if they were to get behind the rigid ratio.  I love that Dr. Mikkelson brought up the ebb and flow of catching up and getting behind on supervision of the current system.  In real life residency if we are doing both a group supervision and individual supervision, there can be variation in these hours.  It seems too rigid to keep a 1:10 ratio consistently and doesn't allow for flexibility.  It may also incur extra costs just to get supervision hours which can be prohibitive for residents.  

CommentID: 238010