As a faculty member in the Marriage and Family Therapy doctoral program at Virginia Tech, I support this petition to count 600 hours of supervised experience toward residency. Counting supervised hours, accumulated in doctoral study, toward residency will facilitate training and licensure. I would like to reference another petition as a possible model for those pursuing licensure in VA as an LMFT from a COAMFTE doctoral program:

Summary:

Purpose: The proposed regulatory action will allow persons who have obtained a doctoral degree in counseling to become licensed with a smaller number of postgraduate hours in a supervised residency. It will accelerate the licensure process for those candidates and will allow them to provide counseling services in independent practice more quickly. Since the practicum or internship hours are within a Council for Accreditation of Counseling and Related Educational Programs (CACREP) program and under the supervision of credentialed faculty, the board is assured of appropriate oversight to protect the health, safety, and welfare of the public.

Substance: The proposed amendments, requested per a petition for rulemaking, provide that supervised practicum and internship hours in a CACREP-accredited doctoral counseling program may be accepted for up to 900 direct or indirect hours and up to 100 supervision hours if the professor or supervisor has an active professional counselor license.

 

As a faculty member in the Marriage and Family Therapy doctoral program at Virginia Tech, I support expansion of this petition to count hours of supervised experience toward residency. Counting supervised hours, accumulated in doctoral study, toward residency will facilitate training and licensure. I would like to reference another petition for comparision (Petition 254, filed 3/10/2017, Hours of residency in counseling), and request that the board consider approval of up to 900 direct or indirect hours and up to 100 supervision hours for those pursuing licensure in VA as an LMFT from a doctoral program accredited by the Commission on Accreditation for Marriage and Family Therapy Education (COAMFTE). 

Petition 254 Summary:

Purpose: The proposed regulatory action will allow persons who have obtained a doctoral degree in counseling to become licensed with a smaller number of postgraduate hours in a supervised residency. It will accelerate the licensure process for those candidates and will allow them to provide counseling services in independent practice more quickly. Since the practicum or internship hours are within a Council for Accreditation of Counseling and Related Educational Programs (CACREP) program and under the supervision of credentialed faculty, the board is assured of appropriate oversight to protect the health, safety, and welfare of the public.

Substance: The proposed amendments, requested per a petition for rulemaking, provide that supervised practicum and internship hours in a CACREP-accredited doctoral counseling program may be accepted for up to 900 direct or indirect hours and up to 100 supervision hours if the professor or supervisor has an active professional counselor license.

As the current Director and former Clinical Training Director of the Marriage and Family Therapy doctoral program at Virginia Tech, which is the only Commission on Accreditation for Marriage and Family Therapy Education (COAMFTE)-accredited doctoral program in Virginia, I am in full support of this petition and any related efforts to allow clinical and supervision hours accumulated in a COAMFTE-accredited doctoral practicum and internship to count toward Virginia LMFT residency requirements.  Our doctoral students, all of whom are post-master's clinicians, receive significant amounts of close supervision from qualified and credentialed supervisors during their doctoral practicum and internship.  Allowing these clinical and supervision hours to count toward residency will facilitate the licensure process for our students, many of whom go on to become licensed marraige and family therapists, state and American Association for Marriage and Family Therapy (AAMFT) Approved Supervisors, and trainers in COAMFTE master's programs.  

I am aware of a similar petition (Petition 254; http://register.dls.virginia.gov/details.aspx?id=7007) related to counting up to 900 hours direct or indirect hours and up to 100 supervision hours accumulated in a CACREP-accredited doctoral program toward licensure/residency requirements.  I suggest that the Board consider using this petition as a model for those seeking licensure as an LMFT from a COAMFTE-accredited doctoral program.

As a faculty memeber in the Virginia Tech Marriage and Family Therapy (MFT) masters program, I support this pettition as it will help doctoral students in the state of Virginia as well as unlicensed faculty who come to Viriginia to count clinical and supervision hours accumulated in docotral programs accredited by the Commission on Accreditation for Marriage and Family Therapy Education (COAMFTE) toward Virginia LMFT residency requirements.  Typically, doctoral students in MFT programs have already have completed a masters degree in MFT or a related mental health degree and the supervision provided in academic settings tends to be of high quality.  This change would make staying in Virginia more enticing to MFT doctoral students and would also make moving to Virginia to practice as an MFT more enticing to clinicians who recently graduated from an MFT doctoral program in another state.  I do not see a downside from this proposed change.

The faculty of the marriage and family therapy doctoral program at Virginia Tech are in strong support of this petition or similar regulations (e.g., Petition 254; http://register.dls.virginia.gov/details.aspx?id=7007) that would allow clinical and supervision hours accumulated in a Commission on Accreditation for Marriage and Family Therapy Education (COAMFTE)-accredited doctoral practicum and internship to count toward Virginia’s LMFT residency requirements.  Allowing these hours to count toward residency will facilitate the licensure process for our doctoral students, all of whom come to Virginia with master’s degrees in marriage and family therapy or a closely related field and are interested in seeking licensure as LMFTs.  It would also help the Virginia Tech’s master’s and doctoral marriage and family therapy programs attract the best faculty candidates, which is critical to the future training of marriage and family therapists working and providing supervision in Virginia. 

In considering this petition, we would note that students in COAMFTE-accredited doctoral programs are pursuing advanced clinical training and, as part of the accreditation requirements, receive significant supervision and oversight of their clinical work, from credentialed supervisors.  As such, as a faculty, we see no concerns related to the quality of the training and supervision doctoral students would be receiving as part of their practicum and internships.

We urge the Board to give this petition or similar regulations that allow clinical and supervision hours accumulated in a COAMFTE-accredited doctoral practicum and internship to count toward Virginia’s LMFT residency requirements its highest consideration.

As a resident of Virginia and second-year student in the Virginia Tech HDFS (Marriage and Family Therapy) PhD program, I wholeheartedly support this petition. This petition would make it much more enticing for many recent graduates to continue clinical practice in Virginia  post-graduation as opposed to moving to another state. I know that we receive high-quality clinical supervision during our program at Virginia Tech, and the passing of this petition would greatly facilitate the licensure process for new professionals. The passing of this petition would greatly benefit us MFT, PhD students. Thank you for your consideration.

I am a current student in the Virginia Tech Marriage and Family doctoral program. I strongly support the petition to count 600 hours of supervised experience from this doctoral program toward residency in Virginia. The Marriage and Family Therapy doctoral program at Virginia Tech is an asset to the New River Valley and surrounding areas. This program has an off-campus clinic that provides individual, couple, and families from the New River Valley, students and faculty from the university, and other Virginian residents, some of which who have traveled up to two hours to receive therapy services. In addition, the program requires students to acquire 18 consecutive months of clinical work and provides regular supervision from established faculty members. During these 18 months, therapists can acquire valuable experience for working with individuals from rural communities, some of whom are coming to therapy for the first time. 

This program attracts therapists and clinicians from across the United States and the world to provide varying skill sets, certifications (i.e., EMDR, trauma-informed care, TFCBT, Theraplay) and training to Virginian residents and marginalized rural populations. Unfortunately, when students graduate from the program, many choose to leave the state to pursue licensure in other states given more attractive licensure options, such as doctoral hours counting towards that state's licensure. If this petition were to be accepted, I believe that more students would stay in Virginia for both short- and long-term periods and contribute their knowledge and expertise to residents. In a recent meeting of LMFT therapists across Virginia, one of the major concerns was the lack of LMFT providers and supervisors in the state. The MFT doctoral program at Virginia Tech both provides training in clinical work and initiates the supervisor training for its students. Choosing to accept this petition would be a step forward in addressing this concern. Further, the Board would be taking an additional step in supporting marginalized and isolated populations by providing more accessible services. 

As a current student, I have chosen to pursue licensure in Virginia, as I currently plan to stay for a few years. Yet, the path is daunting, as none of my clinical hours at the program clinic currently count towards my licensure. I can understand why former students would move away--as the incentive to move to another state that will accept the hundreds of individual and relational hours done through the Virginia Tech clinic is very attractive and more affordable (i.e., supervision costs). 

I strongly encourage the Board to consider approving the motion to permit doctoral students to count up to 600 hours of supervised experience in a COAMFTE or CACREP doctoral program towards hours of residency." I also strongly encourage the Board to consider extending Petition 254 to COAMFTE or CACREP accredited programs (please see below), making the supervised hours counted as 900, rather than proposed 600.  

Purpose: The proposed regulatory action will allow persons who have obtained a doctoral degree in counseling to become licensed with a smaller number of postgraduate hours in a supervised residency. It will accelerate the licensure process for those candidates and will allow them to provide counseling services in independent practice more quickly. Since the practicum or internship hours are within a Council for Accreditation of Counseling and Related Educational Programs (CACREP) program and under the supervision of credentialed faculty, the board is assured of appropriate oversight to protect the health, safety, and welfare of the public.

Substance: The proposed amendments, requested per a petition for rulemaking, provide that supervised practicum and internship hours in a CACREP-accredited doctoral counseling program may be accepted for up to 900 direct or indirect hours and up to 100 supervision hours if the professor or supervisor has an active professional counselor license.

Thank you for your time and consideration. 

As a current student in the Marriage and Family Therapy doctoral program at Virginia Tech, I support this petition to count 600 hours of supervised experience toward residency. Counting supervised hours accumulated in the doctoral study, toward residency will be heavily influential in accelerating the licensure process for doctoral students so that they may begin to serve the community in effective ways. The state of Virginia is in need of licensed professionals as demand increases. 33.3% of older adults in the state of Virginia have a reported disability ( Disability Statistics Report, 2017).
As a student hoping to work with individuals with a disability(s), the movement of this petition will allow me to serve the populations with high needs. Below is another petition that could be used as a guidance

Summary:
Purpose: The proposed regulatory action will allow persons who have obtained a doctoral degree in counseling to become licensed with a smaller number of postgraduate hours in a supervised residency. It will accelerate the licensure process for those candidates and will allow them to provide counseling services in independent practice more quickly. Since the practicum or internship hours are within a Council for Accreditation of Counseling and Related Educational Programs (CACREP) program and under the supervision of credentialed faculty, the board is assured of appropriate oversight to protect the health, safety, and welfare of the public.

Substance: The proposed amendments, requested per a petition for rulemaking, provide that supervised practicum and internship hours in a CACREP-accredited doctoral counseling program may be accepted for up to 900 direct or indirect hours and up to 100 supervision hours if the professor or supervisor has an active professional counselor license.
 

I am writing to support the petition for doctoral students/graduates to count the clinical hours earned during their PhD program toward Virginia residency.  I am a faculty member for the Virginia Tech MFT program, provide clinical supervision to students in that role, and provide residency supervision to individuals working toward LMFT licensure in Virginia.  For COAMFTE accredited programs, the level of therapy services that students provide to fulfill the clinical requirement and the extent of supervision that students receive as they earn hours toward completion of their degrees is as rigorous as supervision received during residency.