In the PDF of "Key Regulations Changes Effective 12/18/25", under the row "Residency Requirements", it describes "Residents are no longer required to complete the residency requirements within four years; however, residents must complete at least half of their residency hours within two years immediately preceding application for licensure as a professional counselor (LPC).  A minimum of 1,000 of the required 2,000 hours of face-to-face client contact; and 100 of the 200 hours of supervision. hours of in-person supervision."    Another place of the redlined "Proposed Text" under 18VAC115-20-52; B4 reads "4. The resident will complete a minimum of 1,000 hours of face-to-face client contact and 100 hours of supervision within two years immediately preceding application to the board for licensure as a professional counselor. "

My question is about the definition of "application for licensure" - is this referring to "application for residency" or the final stage of residency after all hours are accumulated and when one is applying for a full LPC (once all residency and supervision requirements are met). 

The answer to this question will significantly change the interpretation.  On the one hand, if it is "within two years of application of residency" I would count the 1000 hours after I initially started my residency.  On the other hand, if it is referring to "two years preceding application for FULL licensure as LPC" then regardless of the length of time it took to accumulate hours, I would need to make sure that the 1000 hours and 100 hours of supervision are within two years of applying for full LPC.   Please help to clarify this.  Thank you.