Until 2019, the Board of Counseling allowed LCSWs (and Psychologists) to supervise LPCs towards licensure. I want to say at the beginning of this comment that I also support changing those new rules to allow LCSWs to supervise Residents in Counseling as well. I do not think it unreasonable to ask both Boards to work together to ensure there is a two-way arrangement.

I think that at least part of the supervised hours should be able to come from people in other, closely related, disciplines. Perhaps the Board could decide that only up to half of supervised experience hours could come from an LPC. I also think it could be fair to say that an LPC must have a doctorate in order to supervise Social Workers towards becoming LCSWs. I certainly see no reason that an LPC with a doctorate should not be allowed to supervise some portion of a Social Worker's hours if that Social Worker wants.

To respond to some of the concerns others have here, I would point out that, in terms of codes of ethics, everyone with a license is bound to follow the rules of the licensure Board they are licensed under. Social Workers would have to follow their Board's regulations regardless of who is supervising them. Even within a discipline individuals only have to follow their professional association's Code of Ethics if they are a member of that organization, which many professionals are not - so we already have many professionals in these fields who are not actually bound by their professional organization's code of ethics. This may be unfortunate, but it is already the case. However, they are all bound by state licensure Board regulations, which does not change under this proposed new flexibility in supervision. This rule would not change anything about the regulations that Social Workers in Virginia have to follow, aside from the new option for supervision. Some individuals in this public comment section may make broad claims about risk to the public, but I see no actual evidence of that. I do not think that having LCSWs supervise LPC Residents before 2019 was a risk to the public.

This new rule would increase access to options for supervision. Yes, supervision may be completed online, but many people prefer in-person supervision, and may wish to work at a site that only has an LPC available as a potential supervisor. On-site supervision has numerous advantages, including that your supervisor may know the area, population, or even a specific client's situation. Finally, many individuals in our fields specialize. It is not unreasonable for a Social Worker who is accruing hours towards licensure to want a supervisor who has specific knowledge of a population they are interested in. What are they to do if no approved supervisor Social Workers in their area have knowledge with that population? For example, if one wants to work with individuals with Cluster C personality disorders, it may be hard to find a supervisor with that particular skill set. If an LPC with such a skill set happens to be available, and both parties are willing to agree to that supervision arrangement, why not have some flexibility to allow it?

In summary, I think it would be beneficial to allow LPCs and LCSWs (at the very least those who have doctorates) to supervise each other for a portion of hours towards licensure in each other's disciplines. I believe this is a very moderate compromise that would help a lot of people, share specialized knowledge across disciplines, and increase access to high quality and specialized supervision. Thank you for considering this, and I do hope both Boards can work this out.