It seems counter intuitive to reduce contact hours for couples and families for those seeking

distinction as a marriage and family therapist, even at the internship level.

The current requirement for 83% of an intern’s clinical experience to be “relational” hours is both excessive and unrealistic. The ratio for an LMFT Resident in Virginia is 50% (1,000 of 2,000 direct hours), and graduate school interns should not be held to a higher ratio. In COAMFTE training programs, the relational hours requirement is 40%, or 200 hours of the 500-hour internship requirement. Changing the Virginia requirement to 120 of 240 hours brings it into line with national accrediting bodies and many other states (50%). 

The current requirement is also unrealistic as graduate interns typically have the least amount of influence on the types of clients they are assigned during their clinical experience. Functionally, the current regulation may force interns to accumulate over 400 total direct hours in order to get 200 relational hours, a heavy burden for MFT/MFC interns. Interns who graduate with less than 200 relational hours cannot be approved for residency, even though they met the university requirements. How will they be able to gain additional hours after graduation without residency status? They can get stuck with no way forward to pursue licensure.   

As an LMFT, an AAMFT Approved Supervisor, and a Virginia board-approved supervisor, I am completely in favor of this petition. The current requirement of 200/240 direct hours being relational for graduate internship places an unreasonable burden on students to find sites with 80% relational clients. Residents in Marriage and Family Therapy should have experience with both relational and individual hours to build clinical competency as a mental health professional. To require students to attain such a high ratio of relational hours hampers their overall clinical competency and severely limits their experience with applying systemic and individual theoretical models when counseling individuals. Furthermore, the board's requirement greatly exceeds the COAMFTE requirement for internships of 40% relational hours as well as the 50% relational hours required for licensure as an LMFT in Virginia.

I recommend reducing the requirement to 50% or 120/240 direct hours.  This balance of 50% relational hours will ensure clinical competence for working with couples and families as well as with individual clients, be more reasonably attainable for students, and be more consistent with residency requirements.

As the Director of Clinical Training for a university that provides training for both residential and online MFT students, I strongly support this proposal.  Our office receives regular feedback from students preparing for VA licensure that they have significant difficultly in gaining the required direct couple/family hours at their site/s. Furthermore, our office does not receive similar concerns from other students across the country, which leads me to believe that this heavy educational requirement may not exist in other states.  While I am unaware of the initial rationale for the current requirement (200/240), it certainly is not commensurate with the COAMFTE ratio for training programs nor with the VA residency requirements. It would seem much more consistent to require similar couples/family hours between the educational and residency components rather than placing this undue stress on students during their educational experience.  As stated in the proposal, I support the recommended 50% (120/240) requirement of seeing couple/families. 

This seems like a common sense change that will still provide perspective MFTs with distinctive experience with families and children while removing a burden that could stand in the way of residents getting the required hours needed for licensure. The fact that this change is in alignment with the majority of other state/national accrediting bodies further supports its passage. 

The American Association for Marriage and Family Therapy’s Virginia Family TEAM Network (AAMFT Virginia) thanks you for the opportunity to provide input on the Petition for Rulemaking to amend 18 VAC 115-50, which aims to lower the relational experience hour ratio from 83% to 50% during the graduate program supervised practicum. AAMFT is a professional organization representing the interests of Marriage and Family Therapists (MFTs) in Virginia and across the United States. AAMFT Virginia is pleased to support the petition, with reservations. 

We empathize with the issue presented in this petition as there can often be a scarcity of places who can provide consistent relational hours to interns. Further, while we want to maintain an expertise in relational work through rigorous training requirements, we also do not want the current relational hour requirement to pose an insurmountable barrier to MFT trainees and result in trainees pursuing another type of licensure. The amendment proposes a change from 83% relational hours to 50% (120/240). We support this petition for a few specific reasons. First, a 50% relational hour requirement is more congruent with both LMFT residency licensure requirements in Virginia (i.e., 50% direct relational hour requirement), as well as COAMFTE (the national accreditation organization for marriage and family therapy training) training requirements (i.e., 40% direct relational hour requirement). Second, therapy interns often do not have control of what cases they are assigned, and therefore, they may not have the power needed to ensure a high relational caseload. Third, rural areas often experience severe provider shortages and disproportionately high rates of mental health issues. For instance, of the 95 counties in Virginia, 7 counties have only LPCs or MFTs rendering services. In three counties, there are no documented mental health providers at all. Given the shortage of providers in these areas, finding a practicum placement site that provides consistent relational hours and onsite supervision can be challenging. The current relational hour requirement (83%) may incentivize MFT trainees to pursue internship placements in more urban counties, where practices and organizations catering to relational services may be more widely available, to ensure meeting the high relational hour requirement in a timely manner. We propose that lowering the relational hour requirement to 50% is not only commensurate with other MFT hour requirements (i.e., COAMFTE and VA LMFT licensure) but may also incentivize MFT trainees to continue practicing in and serving rural counties. 

Our reservation with supporting this petition is that it may be “a slippery slope” to further relational hour requirement reductions. We support the current petition as it stands, reducing the relational hour requirement to 50%, with the caveat that we do not support further reductions in the MFT relational hour requirements. A 50% relational hour requirement will both maintain an essential relational hour training experience, thereby upholding MFT expertise and training in relational work, while also becoming more attainable for MFT trainees pursuing MFT licensure. 

Amy Morgan, LMFT & Debra Rezendes, LMFT

AAMFT-Virginia Advocacy Leaders

I am writing in support of this petition. As an MFT graduate student, and as someone who will in the near future be in the licensure process. I believe this adaptation will be more congruent with other Mental Heath professionals that practice in the state of Virginia, as well as better acknowledge the breadth and depth of the work MFTs so as systemic thinkers and practitioners. This adaptation and adjustment I believe will allow MFTs to be of better service to their community when the hours restriction is less rigid and is more on par with other practitioners in the field. MFTs provide a unique skill set in the mental health profession, and I believe this adjustment will allow for more growth within the MFT community and allows for a more holistic approach to our work. Thank you for considering this change and petition. 

We are writing in response to the “Petition for Rule-Making,” regarding 18VAC115-50: Regulations Governing the Practice of Marriage and Family Therapy, dated 9/16/2019 and submitted by David and Suzanne Mikkelson. At issue is the number of “relational” hours required during the internship (18VAC115-50-55) and requesting a reduction of those hours from 200 (of 240) to 120 hours. The Virginia Association for Marriage and Family Therapy (VAMFT) recognizes and understands the difficulties faced by students in acquiring those hours deemed “relational,” i.e., with more than one related consumer in the counseling room. The points brought up by the Mikkelson’s are valid and have been considered and debated for some time within the family therapy community.

As VAMFT sees and understands this dilemma, we are faced with two competing ideas. The first idea strikes to the very basis of the profession of marriage and family therapy and that is that the training and experience requirement to become a licensed marriage and family therapist (lmft) is strictly defined as the ability to work in a therapy space with more than one consumer. That difference in training and experience is, by definition, what makes our training, experience and supervision unique and has led to the creation of a license that is separate from other mental health professionals. In order to achieve expertise and some assurance of safety to the consuming public, we must be assured that persons granted a degree in mft and subsequently licensed as mft’s do have, in fact, the ability to competently navigate in that relational space. It is, of course, arguable as to how many hours would give some assurance of this expertise and presumed safe practice. VAMFT believes that reducing the relational hours in the internship, as currently mandated, would jeopardize the creation of the core of experience that someone heading for independent practice should have.

The second, and somewhat opposed concern is, as outlined by the Mikkleson’s, the difficulty in assuring that students can get the relational hours in a typical internship setting. Aside from those agencies providing intensive in-home services, an unlicensed intern has few chances to work with more than one designated consumer at a time. In the COAMFTE guidelines, the 500 hour requirement is somewhat modified by the ability to count up to 100 hours in “alternative hours or clinical activity (e.g., couple or family groups; live cases where reflecting teams are directly involved…, etc.) (pg. 33 of COAMFTE Accreditation Standards Version 12.0; Effective January 1, 2018) (Bold in original). Use of those hours, also not always available in an internship site, would make the 200 hour requirement at 50%. The somewhat reduced hourly requirement established by COAMFTE is based on the reality that students in an on-going program of mft will be surrounded by others working from the same systemic bedrock that is rarely the milieu in residency settings. If VAMFT had its way, more internship sites would be using family therapy as a model for treatment and even when individuals are seen (as the Mikkelson’s highlight), the therapist’s focus on the relational rather than the intrapersonal field. Short of allowing interns and residents who are seeking degrees or licenses in mft and receiving mft-based supervision (VAMFT’s fondest wish), the dilemma remains. Both of the undersigned are Approved Supervisors with AAMFT and both supervise interns and residents who are seeking education and licensing as mft’s. Both believe that, regardless of the number of consumers in the room with the therapist, the therapist is performing family/relational therapy.

In light of all the above, we would not like to see any diminution in the required experience that aspiring mft’s accrue during either their internships or their residencies. We are concerned that the goal of possible portability of the license would result in all standards being devolved to the lowest common denominator. It is difficult to imagine any state regulatory body being willing to increase the requirements for licensing in their jurisdictions. We would, reluctantly and in light of the dilemma outlined above, be willing to support a reduction in those relational hours to 180 of the total of 240.

William Scott, Ph.D.

President, VAMFT

Arnold Woodruff, LMFT

Executive Director, VAMFT