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.