Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Counseling
 
chapter
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]

8 comments

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11/25/19  11:11 am
Commenter: Anne Beverly Chow, Bluebird Counseling Center

I support this petition
 

Master’s level clinicians should be afforded this leniency in becoming licensed clinicians. It would be more cost effective and help to accommodate Virginia’s ever-growing need for mental health services.

CommentID: 76965
 

11/25/19  4:30 pm
Commenter: Robin Usher

I Strongly Support This Petition
 

Residents may have had experience in counseling professions before the start of their Masters, and many graduate from well-established programs that provide a level of training that is on-par with the supervised experience of some Residents. While the Board of Counseling already accepts 500 hours of supervised experience from the Masters internship, this has done little to reduce the time that it would take for a Mental Health professional to become licensed post-Masters.

Some states have adopted polices to accept a greater number of pre-Masters hours towards the post-Masters experience, so long as the hours occur after 35 course hours, and in excess of the required practicum an internship hours. This petition requests that Virginia's policies be more in line with states that have chosen to focus on the quality of education for counselors rather than the quantity of hours acquired post-Masters. 

Not making a shift towards better credentialing practices will sustain the mental health and substance abuse crisis facing Virginians today. The current licensure process ensures burnout, deters individuals from entering the counseling workforce, and setups a condition where mental health professionals are unable to find meaningful work after the completion of their Masters. The current system may also encourage the abuse of Resident clinicians as they are forced to work in settings where their work isn't fairly compensated.

Again, I strongly support changing the required hours for licensure. I feel that the change is necessary, and I believe that it could benefit all Virginias by expanding the counseling workforce and by highlighting counseling programs that supervise their students for a much broader training experience under the foundations established by CACREP. 

CommentID: 76968
 

11/30/19  10:30 am
Commenter: Carley Graves, Virginia Tech

I support this petition
 

At a time where the demand for mental health counselors is extremely high this is a good step towards removing barriers for those to get into the field while still ensuring that individuals are qualified to offer mental health services.  Considering the cost of education it is only right to allow some leniency for individuals putting in so many hours of work without compensation.  With the increasing awareness of mental health, high divorce rates, and large amount of drug use, the wait time to get mental help is ridiculous in most areas.  If there is anything that can be done to encourage qualified individuals to enter the mental health field, it should be done.

CommentID: 76986
 

12/13/19  8:09 pm
Commenter: Cynthia Miller, Ph.D., LPC

Oppose this petition
 

The petitioner is asking for a significant reduction in the required hours of experience and supervision in order to be licensed in Virginia.  I oppose this petition.  A review of the 2014 report on Licensure Requirements for Professional Counselors published by ACA shows that the majority of states at that time required 3,000 or more hours of post-master's experience and at least 100 hours of supervision.  Only two states, Florida and South Carolina, required just 1000-1500 hours of post-master's experience.  I do not have the 2016 ACA report in front of me but I have no reason to suspect that the majority of states have lowered their experience requirements over the last 5 years.  Moreover, under the current regulations, the petitioner's request to reduce the required supervision hours from 200 to just 50 would mean that a resident would need only six months of weekly individual supervision in order to be licensed (since the current regs allow for 50% of supervision hours to come from group supervision).  That is simply not enough time for any supervisor to be feel reasonably assured that a new counselor is consistently reliable in their ability to competently perform all the functions of a professional counselor.  While I agree that the licensing process is long and rigorous, I do not think that reducing the required experiential and supervision hours necessary for independent practice allows the Board to adequately meet its charge to protect the public.

CommentID: 78500
 

12/14/19  4:42 pm
Commenter: David Tsveer, New Directions Counseling Group, LLC

I strongly agree with this petition
 

CommentID: 78509
 

12/16/19  11:33 am
Commenter: Gerard Lawson, Virginia Tech

Oppose This Petition
 

I oppose this petition primarily because it is completely unclear what the intent is. The petition begins with:  "To accept 1500 direct/indirect service hours". Does that mean 1,500 Direct and 1,500 hundred Indirect, or 1,500 Direct and Indirect combined? In either case, it would be proposing a significant reduction in the number of direct hours required. One would be a catastrophic reduction from 3,600 hour to 1,500. Let's assume the petitioner was not proposing halving the required hours. In that case, the reduction is still from 2,000 Direct hours to 1,500 and the total number of hours is reduced by 400 (from 3,400 to 3,000). Interestingly, in the actual petition, the text goes on to read, "For the 1000 hours to be considered, they must be in excess of the practicum and internship hours required for licensure..." This is the first mention of 1,000 hours, and I have no idea what that means, or where that reduction would come from. 

The most concerning part is that the petition suggests, "reducing the supervision concurrent with that experience from 200 hours to 50." That is a patently bad idea. Having trained over 1,000 LPC supervisors in the past decade one of the common concerns expressed is that they have so little time to influence a positive chance in supervisee knowledge, skills, and abilities in the 200 hours and two-years.

The purported rationale for this petition is to "expedite licensure" for residents from "comprehensive and well developed programs" and to "address the growing burden of mental illness for Virginians while also addressing limited career opportunities for Residents". With all due respect, the job of the Board is to protect the public and ensure client welfare. The proposed changes have the potential to reduce the quality of mental health services in Virginia, and licensing highly competent counselors should be focus of the Board not expediting licensure. Please do not accept this petition.  

CommentID: 78521
 

12/16/19  9:32 pm
Commenter: Suzan K. Thompson, Ph.D., LPC, Integrative Counseling & Wellness

I Oppose this Petition
 

I strongly oppose this petition. Significantly reducing the number of hours a Resident must EARN would potentially impact the skills, supervision and experience they accrue during the Residency. I don't believe this is in the best interest of the public and would cause potential harm. 

CommentID: 78527
 

12/19/19  11:36 am
Commenter: A. Adele Walker-Blue, LPC

Oppose
 

I am proud to be an LPC in the Commonwealth of Virginia, which has been a leading state in establishing liscensing for mental health professionals, with rigorous standards. Upholding strict licensing standards such as practical experience and supervision hours consistent with those recommended by the American Counseling Association are essential for protecting the public when it comes to mental health treatment in Virginia. Additionally, this petition lacks clarity. While the increasing need for mental health treatment may necessitate some adjustments in current system, it must be done in a thoughtful manner that does leave the public vulnerable to harm.  

CommentID: 78541