On behalf of the professional counselors who are members of the Virginia Counselors Association, I am pleased to provide comments on the proposed regulatory changes regarding portability, supervision, and residency for professional counselors and marriage and family therapists.

We commend the Board for its commitment to update the regulations while holding public safety as a paramount concern.

Specifically, we are pleased to support changes in prerequisites for licensure of professional counselors and marriage and family therapists that take into account standards in other states that are commensurate with Virginia’s standards (18VAC115-20-45).  Endorsement into Virginia will be eased by these new regulations and at the same time assuring that counselors and M&F therapists will be able to practice more easily and expeditiously in the Commonwealth.

We are also in support of the proposed change in residency requirements (18VAC115-20-52) that replace the permissive language on supervision with mandatory language.  All clients deserve the most highly qualified therapists regardless of the settings in which they receive services.  At the same time, we support changing the supervisory requirements 52-B-2) that would modify the manner in which supervision takes place (individual replacing “face-to-face”) as this takes into consideration the technological advances in our field and allows for more ease of access to qualified and experienced supervisors.

VCA supports the changes in supervisory qualifications found in 18VAC115-20-52.C.2 that specify the professional training needed to adequately supervise residents.  These requirements are clear and should remove any ambiguities that were present in the current regulations.

Finally, while our association does not represent M&F therapists, we are pleased that professional counselors with marriage and family therapy experience will be able to supervise M&FT residents (18VAC115-50-60Cc).

Thank you for your interest and consideration regarding our thoughts about these proposed changes. We are always glad to see the Board consistently maintain a high level of respect and concern for the counselors in the Commonwealth, and hope to continue to do what we can to support the Board in these decisions.

Sincerely,

Lisa M. McDowell, LPC, LSATP, NCC

President – Virginia Counselors Association