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.