I cannot impress enough to the Board how imperative telephone counseling has been for my rural, lower SES, immunocompromised, and disabled clients during this pandemic.  As resident counselors, we have had to embrace flexibility to meet the myriad of mental health needs that have been exacerbated by the uncertainty of these times we are living in.  We are truly working in a proving ground, and to disallow the hours we have put into helping others amid a pandemic due to a lack of an electronic interface does not feel adaptive, but restrictive.  If DMAS is allowing for reimbursement via telephone contact, how can not including those same hours in pursuit towards licensure be considered?  Telephone counseling has a precedence - Suicide Hotlines save lives.