I am a current student in the Virginia Tech Marriage and Family doctoral program. I strongly support the petition to count 600 hours of supervised experience from this doctoral program toward residency in Virginia. The Marriage and Family Therapy doctoral program at Virginia Tech is an asset to the New River Valley and surrounding areas. This program has an off-campus clinic that provides individual, couple, and families from the New River Valley, students and faculty from the university, and other Virginian residents, some of which who have traveled up to two hours to receive therapy services. In addition, the program requires students to acquire 18 consecutive months of clinical work and provides regular supervision from established faculty members. During these 18 months, therapists can acquire valuable experience for working with individuals from rural communities, some of whom are coming to therapy for the first time. 

This program attracts therapists and clinicians from across the United States and the world to provide varying skill sets, certifications (i.e., EMDR, trauma-informed care, TFCBT, Theraplay) and training to Virginian residents and marginalized rural populations. Unfortunately, when students graduate from the program, many choose to leave the state to pursue licensure in other states given more attractive licensure options, such as doctoral hours counting towards that state's licensure. If this petition were to be accepted, I believe that more students would stay in Virginia for both short- and long-term periods and contribute their knowledge and expertise to residents. In a recent meeting of LMFT therapists across Virginia, one of the major concerns was the lack of LMFT providers and supervisors in the state. The MFT doctoral program at Virginia Tech both provides training in clinical work and initiates the supervisor training for its students. Choosing to accept this petition would be a step forward in addressing this concern. Further, the Board would be taking an additional step in supporting marginalized and isolated populations by providing more accessible services. 

As a current student, I have chosen to pursue licensure in Virginia, as I currently plan to stay for a few years. Yet, the path is daunting, as none of my clinical hours at the program clinic currently count towards my licensure. I can understand why former students would move away--as the incentive to move to another state that will accept the hundreds of individual and relational hours done through the Virginia Tech clinic is very attractive and more affordable (i.e., supervision costs). 

I strongly encourage the Board to consider approving the motion to permit doctoral students to count up to 600 hours of supervised experience in a COAMFTE or CACREP doctoral program towards hours of residency." I also strongly encourage the Board to consider extending Petition 254 to COAMFTE or CACREP accredited programs (please see below), making the supervised hours counted as 900, rather than proposed 600.  

Purpose: The proposed regulatory action will allow persons who have obtained a doctoral degree in counseling to become licensed with a smaller number of postgraduate hours in a supervised residency. It will accelerate the licensure process for those candidates and will allow them to provide counseling services in independent practice more quickly. Since the practicum or internship hours are within a Council for Accreditation of Counseling and Related Educational Programs (CACREP) program and under the supervision of credentialed faculty, the board is assured of appropriate oversight to protect the health, safety, and welfare of the public.

Substance: The proposed amendments, requested per a petition for rulemaking, provide that supervised practicum and internship hours in a CACREP-accredited doctoral counseling program may be accepted for up to 900 direct or indirect hours and up to 100 supervision hours if the professor or supervisor has an active professional counselor license.

Thank you for your time and consideration.