Agencies | Governor
Virginia Regulatory Town Hall
Department of Health Professions
Board of Counseling
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]
Action Resident license
Stage Emergency/NOIRA
Comment Period Ends 1/22/2020


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1/9/20  10:14 am
Commenter: Jane Yaun, for VACSB Regulatory Committee

Clarfication requested

1) Asking for clarification to the new language which requires adding a resident's license number to all written communication. (i.e 18VAC115-20-52 B. 10)  Does this  include clinical documentation/ notes? 

2) Same section: The added language regarding informing client that the "resident does not have authority for independent practice and is under supervision" while providing supervisor's name, professional address and phone number, may lead to unnecessary confusion by individual's served as to the qualifications.  Curious as to the rationale for the added language.  In addition, asking for clarification as to how often the client would need to be provided notice - assumption is only at start of services.

CommentID: 78770

1/10/20  5:05 pm
Commenter: Adrien Monti

Requirement to add resident's license number

18VAC115-20-52 B. 10:  The requirement to add a resident's license number to all written communication seems excessive.  Each resident will registered with the board by name and will sign all documentation with legal name.  Adding the license number would be time consuming and would not clarify or improve upon the clinical record.  Recommendation not to require the resident’s license number be added to all written communication, but only to require legal name and signature.


CommentID: 78838