Thank you to the Board of Counseling for reviewing this consideration of planned regulation changes.

I noticed that the Board of Counseling Periodic Review draft regulations include changes to limit all hours of LPC  supervision to only LPC's and LMFT's, and no longer accept hours from LCSW's or LCP's  (as well as for LMFT supervision, but the change to LPC regulations will affect a larger number of individuals).

I did not see listed in the draft regulation a proposed effective date for when this change would take place, and how much notice would be given in the regulations for allowing existing and planned Residents to identify a new supervisor with the new limitations, if their current or planned LCSW supervisor will no longer be an option for any of the future hours after the change.

This will require many people to change supervisors earlier than the 100 hours limit currently in place, if not allowed to continue under regulations already registered under, as well as more burdens for new applications if needing to change, with more limited options for supervisors, and more burden on the Board to review the registrations of all of the people needing to change earlier than planned and all at once.

I hope that staff already approved for a registration under an LCSW supervisor would not have a gap in supervision due to the delay of finding and waiting for the Board to go through the process of so many people needing to make changes all at the same time.  They could also experience a gap if needing to identify and register a new LPC supervisor earlier than planned if not permitted to continue with the 100 hours allowance currently in place.

Is there a plan for how the Board would accommodate those already registered, and the increased burden for the Board of Counseling of many Residents needing to change supervisors all at the same time, to avoid delays due to increased volume of Board reviews due to the change?  If this change is made effective, giving advance notice, such as allowing those already registered with an LCSW to finish their eligible hours with them, and a year's notice past the effective date for more planning of those needing a change in the future, would help reduce this burden.  As well as allowing staff adequate time to identify a new supervisor, and employers currently able to offer internal supervision time to look at alternative options when LCSW supervisors are no longer available.

I am writing on behalf of those LPC Residents currently registered under myself as an LCSW, and those at our agency planning to register for licensure supervision in the future, where our agency is able to offer free supervision internally, but have more limited LPC qualified supervisors available as resources in addition to LCSW qualified supervisors (i.e. needing 2yrs post-licensed experience in addition to the 20hrs supervision training). 

Thank you for your consideration of looking to plan for a smooth transition for the numerous current and potential LPC Residents who will be affected by this change, and our agency's wanting to plan our best to support for them to be able to continue the Resident in Counseling status without a gap due to a regulation change, and quickly allow new qualified Residents to register as qualified supervisors are available.

Lisa Iervolino, LCSW

Building into the regulation a plan for grandfathering existing residents, and a future date for implementation if this change is approved to allow for planning of available working with more limited resources in the future, as well as the Board allowing time for the increased volume it will encounter with more registration changes earlier than planned, will allow for a smoother transition and support for Residents to remain in compliance with regulations during a possible period of change in regulations.

Thank you to the Board for the periodic review of the regulations covering the professions over which the Board has jurisdiction.  As an MFT educator, I am particularly happy to see clarification of the relationship between residency hours and master's level internship hours and the resolution of what has been a confusing situation.  At the same time, I am writing to ask that the Board reconsider the language in 18VAC-115-50-55 Section 10 (LMFT Regulations) that requires that Master's "internship hours shall not begin until completion of 30 semester hours toward the Master's degree."  This specification of when students may begin the internship is likely to impose difficulty on MFT programs where COAMFTE accreditation criteria require 500 client contact hours.  That is more than twice the number of client contact hours required by the revised regulations.  Not allowing students to begin the internship hours until after the completion of 30 credit hours means that students will not be able to finish their degrees in as timely a fashion as they are now, creating a burden for them when they are meeting twice the required number of client contact hours.  I would ask that the Board not specify when the internship should begin and leave this to the discretion of the program.  MFT education has historically been based on an apprenticeship model in which students begin closely supervised clinical work - usually in a clinic operated by the program - earlier in their program than is true in other disciplines.  This model has been very successful in training competent practitioners in the past and I believe we can continue to rely on it.  A similar change could also be made in the LPC regulations to preserve the alignment of regulations across disciplines that has been an on-going concern for the Board.  I believe that one genesis of this proposed change in the internship is to make Master's internship hours equivalent to the residency hours for which they are in essence being substituted.  If the Board members believe that this is an important provision to preserve, I would ask that the language be changed to state that applicants for licensure must have completed an internship and that at least 600 of the internship hours (including 240 hours of client contact of which 200 are with couples and families) occur after the completion of 30 credit hours.  This does not limit when students can begin the internship but insures that at least 600 of their hours meet the requirement  for internship hours applied toward residency in the current regulations.  

If the Board proposes to accept the proposed change to the internship as well as the other changes to course requirements in the proposed revision, I would also ask that the Board make some provision for delayed implementation of the regulations in order to give programs time to meet them.  It is possible that a student who is currently enrolled in a program like ours that satisfies all of the current regulations could apply under the new regulations and not meet the educational requirements. 

Thank you for your consideration of my request.