I am opposed to this proposed change for a number of reasons.

First, I feel this proposed change would cause undue burden on the vast majority of individuals attempting to find the placements that will allow them to gain the supervision hours required to get licensed in VA. Many individuals in this situation find themselves having to pay up to $100 an hour out of pocket to fulfill the requirement as it stands now. With the current standard, qualified individuals from closely related disciplines can provide up to half of the necessary hours, which allows those seeking LPC licensure strong interdisciplinary background yet still more than suficient exposure with an LPC. In many agenices, people with social work backgrounds are much more prevalent, and therefore are often the ones available to provide supervision, generally on par with supervisors of any other discipline.

If the goal of this proposed change is to ensure that LPC's are trained sufficiently, then I strongly feel that the current setup works best and provides a multi-dimensional bastion from which LPC's can enter the diverse health-care marketplace. Further, it seems that LPC's do not dominate the mental health marketplace and this change would place undue burden on residents and be counterproductive to long-term growth in the field.

Another major issue is that review and approval of paperwork related to approving supervisors is seriously compromised. Oftentimes, turnaround time is a minimum of three months (even though processing of fees occurs immediately), further delaying the accumulation of hours.

In summary, this proposed change seesm to place more burden on trainees in residency, seems short-sighted and not likely to produce significant gains in the quality of LPC training, and it promulgates continued administrative woes... all factors combined, perhaps driving quality individuals to other health-care fields.

I worry that this change will actually end up making it much harder for individuals in need of supervision for licensure to find an appropriate supervisor.  LPCs providing supervision for licensure are not easily found in some areas of the state.  In addition, residents often get their supervision provided as part of their employment.  If they are employed in an agency that does not have an LPC available to supervise them then the resident will have to incur significant cost in order to obtain supervision acceptable to the Board.  Furthermore, a resident may be employed in an agency where they receive individual supervision from an LPC but group supervision is led by an LCSW or clinical psychologist.  That resident would then be unable to count any of the group supervision hours which hardly seems fair.  Residents cannot control who is available to provide supervision at their place of employment and, if they are expected to get all of their supervision from an LPC, it could add unnecessary restrictions to their job search.  I also worry that this rule will make it harder for students to apply some of their internship hours towards the counseling residency.  Students are currently able to apply 600-900 hours of their internship towards their residency.  Many students complete internships at agencies where their primary supervisor is an LCSW or LCP.  Would these students be unable to have their internship hours accepted under this rule?  If so, then training programs are going to be very hampered in their ability to place students in appropriate internship sites in the future.

It is my understanding that the Board is worried that a resident's supervisor may not have any accountability to the Board if the supervisor is not licensed under the Board of Counseling.  I assume, however, that the supervisor would still have accountability to the board under which he/she is licensed and appropriate complaints could be filed with the appropriate board.  The regulation has allowed for no more than 50% of the supervision to be given by an allied professional for many years and it does not seem the board has encountered many problems under this arrangement.

Although I am supportive of efforts to strengthen professional identity, I also believe there is much to be gained from cross-disciplinary training and interaction.  Residents can have tremendous learning experiences with a supervisor from social work, clinical psychology, counseling psychology, or psychiatry.  They gain different perspectives, learn how professionals in different guilds think, and are exposed to new ideas.  I realize that the boards of social work and psychology do not recognize supervision provided by an LPC but I don't buy the argument that counseling should follow suit and refuse to recognize supervision from allied professionals.  I see more potential harm coming from this regulation than potential good.

As a graduate student completing internship, this change concerns me greatly.  My site supervisor is a LCSW and I have enjoyed my supervision experiences with him greatly.  Additionally, he has stated many times that having me as an intern helps him see the LPC side of things; it's a mutually beneficial, professional relationship.  I work with LCP's and psychiatrists at my site, as well, and we all learn from one another.  

If my current supervisor is no longer allowed to oversee my work, what happens to all of the hours I have logged previously?  I am, greatly, concerned that there will not be enough LPC's in the area to provide supervision to all of the graduate students requesting it.  Finding supervision, in and of itself, can be very challenging.  This change would make it all the more difficult.  Quite frankly, I agree with Dr. Miller in that this could very well push students into another field.  What's more, it could delay a student from graduating and subsequent licensure because of the difficulty in finding a supervisor and getting the required hours.

Please, I ask you to lay this change to rest.  It's not necessary, and will create undue hassles for students/residents.  Why create a problem to solve one that doesn't exist?  Thank you for your time.

Sincerely,

Michelle Sowards

As a current Resident in Counseling, I have been receiving supervision under an LCSW for the past year and am currently in the process of finding a LPC in the area to finish out my hours - which has been extremely hard. Many LPC's charge $80-100/hour, which is difficult for someone in this field to pay out of pocket every week. There are also a lack of LPC's who are willing to provide supervision in many area in Virginia. By doing it through my agency,  I have had a good experience being able to work directly under someone who understands what I do in my position and can be available to me every day if I need her. Also, it takes 3+ months for the board to approve a supervisor, and I have lost many hours just waiting for the board to approve my paperwork. The board needs make the approval process easier before making things more difficult in the long run for us.

I have a few suggestions:

-The board should regulate the amount a LPC can charge for their supervisory sessions to make it realistic instead of a way for them to gain an extra $100 or more a week in cash.

-Maybe the board should provide some type of class for LCSW's before they can supervise LPC's to help them better understand the LPC requirements and ethics, so they are more readily prepared to provide supervision for LPC's, if that is the worry.

If I had not been able to receive supervision under an LCSW, I probably would be nowhere near where I am now in regards to my hours.