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]

11 comments

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9/9/24  1:49 pm
Commenter: Michelle Smith

Agreed wholeheartedly
 

I applaud Petitioner Watson's request for two hours of continuing education specifically related to supervision/supervisory ethics.  I believe this is long overdue, a minimal ask to those of us that supervise, and essential as we attempt to guide, gatekeep, and stay abreast to current trends in our field.  

Change can be hard, even when it is positive change.  For anyone reluctant to embrace that which will benefit future professionals and those we serve, an additional consideration: the National Board for Certified Counselors (NBCC)'s Approved Clinical Supervisor credential requires 45 hours of approved training as well as 20 hours of continuing education specifically related to supervision every five year term, meaning approximately four hours each year.  This is double what is being proposed in this petition.

In sum, I say bring it on!

CommentID: 227743
 

9/10/24  7:32 pm
Commenter: Suzan Thompson, Ph.D., LPC

I support this petition
 

LPC supervisors are in a position to model to their supervisees how a professional continues to learn and develop. Continuing education for supervisors should be a component of their own professional development. Other specialties require ongoing related education and training. The Board of Counseling should require supervisors to continue their education in supervision. I support this petition!

CommentID: 227762
 

9/10/24  7:42 pm
Commenter: Jerry Mize

Agree
 

I fully support the petition to amend 18VAC115-20-52(C)(2) and 18VAC115-50-60(C)(3). Supervisors often face challenges in adequately preparing for their role, and without sufficient training, there can be ethical concerns. Further, there can be concern around financial exploitation of residents where supervisors lose sight of their role. Requiring supervisors to complete two hours of continuing education focused on residency, supervision requirements, and ethical issues will help ensure that they are better equipped to supervise ethically and effectively. This change would protect both supervisees and the integrity of the profession.

CommentID: 227763
 

9/17/24  7:49 am
Commenter: Carmen Greiner, LPC

I disagree
 

I disagree with this requirement

  1. We already have regulations requiring supervision training and yearly ethics CEUs. 
  2. Adding another regulation is unnecessary, burdensome and paternalistic. At some point, clinicians have to be responsible for their own ongoing education.
  3. This is going to be a waste of time. It is already difficult to find engaging yearly ethics trainings (especially for those of us who have been doing this for many years), how are we going to get “useful” supervision information every year. 
  4. If you must do something like this, what about the following compromise options
    1. Allow supervisors to substitute ethics CEU requirements for supervision CEUs.
    2. Require supervision CEUs in a longer period of time – for example, there needs to be 2 supervision CEUs every three years.
    3. Define "Supervision CEUs" broadly so as to include cultural competence, training in specific therapeutic interventions (a DBT program supervisor can use training in DBT for their supervision CEUs, training in motivational interviewing is clearly applicable to supervision tasks), supervisors who meet for peer supervision with other supervisors can count their hours in supervision (2 ours of peer supervisor supervision = the 2 CEUs requirements), etc. 
    4. Allow supervisors to substitute pro bono supervision for all the CEU requirements. For example, the Virginia Telemental Health organization needs clinical supervisors. So supervisors who provide 6 months of weekly supervision pro bono are allowed to use that supervision in place of their required 20 hours of CEUs per year.

 

In summary, providers are ethically required to have continuing education. Adding undue requirements regarding the type of education (2 hours of ethics AND 2 hours of supervision) CEUs is unreasonable.

 

CommentID: 227865
 

9/19/24  12:45 pm
Commenter: Anonymous Citizen

In Agreement
 

We are in a time when ethics seems to have been in many cases thrown out the window due to external pressures to perform to meet certain goals and billable hours rather than fully focus on a client and each client's needs as the priority it should, and was intended to be. Ethics must always be top of mind in performance of any profession.

CommentID: 227869
 

9/24/24  12:51 am
Commenter: Sharon Watson, LPC, LMFT, LSATP, NCC, ACS

My justification for submitting this petition
 

I am requesting that the Board of Counseling amend the regulations for LPC and LMFT supervisors to require that at least 2 hours of the 20 hours of continuing education required yearly for licensure renewal to be on the current LPC/LMFT regulations specifically on residency and supervision requirements and the related supervisory ethical issues.  This would not change the current requirement of having a total of 20 hours of CEs yearly, of which 2 hours currently are to be on any ethics topics.  This would only be for supervisors to have 2 hours specifically on supervision regulations and ethics.

 

The reason I submitted this petition is because, over the past few years, I have become aware of multiple instances of supervisors supervising inappropriately (not following the regulations) or unethically.  It's not clear that this is volitional or due to ignorance of the regulations.  Some examples are: supervision "prep" hours (preparing case studies) in advance of in-person supervision being counted as face-to-face supervision hours; dyad supervision being counted as individual supervision; immediately "firing" a resident as retribution for the resident giving the required 30 or 60 days' notice of leaving their practice (which did not allow for appropriate termination with their clients); supervisors making negative comments to clients about the resident who resigned; supervisors writing negative/inaccurate information on the verification of supervision form as retribution; the supervisor using their resident as a confidant in dealing with their own personal issues; supervisors requiring their resident to have and pay for supervision they're unable to count (i.e. when the resident does not have enough indirect & direct hours to justify the supervision); supervisors not providing enough supervision (or not suggesting outside additional supervision) to cover their resident's hours, leaving the resident with needing more supervision hours even after completing their total (direct + indirect) work hours resulting in unnecessarily prolonging their residency and postponing their licensure.

 

My petition is specifically only for supervisors and is specifically for 2 CEs reviewing the Virginia regulation requirements for supervisors and residents and any specific ethical issues regarding the supervisory process.  I understand this would only be for those supervisors who, for whatever reason, have not kept up with the changes in the regulations or who may simply be functioning based on what they “think” are the regulations without checking for any updates.  I understand this will not address some of the issues I listed above for supervisors who are acting out of retribution or volitionally ignoring the regulations.

CommentID: 227891
 

9/25/24  5:55 am
Commenter: Anonymous

Agreed
 

As its true that Supervisors in some instances have taken advantage of residents, something should be done and this is as good of an option as has been proposed in the last many years that I'm aware of. 

While this won't fix a supervisory issue that's purposefully predatory towards a resident, it will help those supervisors who have forgotten about rules and ethics. 

A 2 hour, or 10% of a Supervisory credit hours being dedicated to supervision requirements and the related supervisory ethical issues sounds like a small and appropriate ask. 

Any reminder that supervisors are to operate ethically and correctly would be appreciated.

 

CommentID: 227899
 

9/26/24  6:11 am
Commenter: Anonymous

Disagree
 

The issue at hand is subpar clinicians and clinical supervisors. Two CEUs, forced by this petition, is not the way to correct the issues Sharon identified.

The  standard CEU courses are not 2 credits. One CEU or 6 is the norm. I would be hard pressed to find a course offering “2 CEUs”. I don’t have the time, energy or resources to comb through CEU offerings to figure out how to get 2 hours. We must already take Ethics. Ethics courses typically touch on ethics in supervision. 

The issue is poor supervision and poor supervisors. The other issue is the lack of highly trained clinicians. When you allow people to work in the field after taking 30 credits, virtually, and say that they now have a Masters degree, you will have poorly trained clinicians. When you allow non clinically trained people to open and operate mental health services in the community, you will have poorly trained clinicians. When the insurance reimbursement is a pittance of what other providers make, you will have poorly trained clinicians.

The gatekeeping must be done earlier in the process. Once an individual is a supervisor, all the classes in the world will not prevent the ridiculous shenanigans that Sharon is observing. 

I have been a fully licensed clinician from a state that requires two levels of licensure for therapists, for 20 years. I have moved back to VA and am embarrassed of my colleagues because it’s apparent they have not been trained properly. That level of responsibility must be addressed at the lowest level- at the educational standards, licensing standards, etc before adding on more oversight to those who are already supervisors tasked with cleaning up the mess a terrible state system created. 


CommentID: 228003
 

9/26/24  7:20 am
Commenter: Anonymous

I agree
 

I agree 

CommentID: 228004
 

9/26/24  9:40 am
Commenter: Shelby DeBause

Support fully
 

I think in order to keep one's place on the registry of state supervisor's one should have to complete this 2 hour yearly requirement. I have been supervising for 12 years and see the need in the field. 

CommentID: 228005
 

9/26/24  9:11 pm
Commenter: Robin Brown

Comment
 

I support this petition 

CommentID: 228007