Agencies | Governor
Virginia Regulatory Town Hall
Department of Health Professions
Board of Counseling
Regulations Governing the Practice of Marriage and Family Therapy [18 VAC 115 ‑ 50]
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10/17/19  11:13 pm
Commenter: David P Mikkelson, PhD, AAMFT Approved Supervisor

Strongly in Favor of this Change

The current requirement for 83% of an intern’s clinical experience to be “relational” hours is both excessive and unrealistic. The ratio for an LMFT Resident in Virginia is 50% (1,000 of 2,000 direct hours), and graduate school interns should not be held to a higher ratio. In COAMFTE training programs, the relational hours requirement is 40%, or 200 hours of the 500-hour internship requirement. Changing the Virginia requirement to 120 of 240 hours brings it into line with national accrediting bodies and many other states (50%). 

The current requirement is also unrealistic as graduate interns typically have the least amount of influence on the types of clients they are assigned during their clinical experience. Functionally, the current regulation may force interns to accumulate over 400 total direct hours in order to get 200 relational hours, a heavy burden for MFT/MFC interns. Interns who graduate with less than 200 relational hours cannot be approved for residency, even though they met the university requirements. How will they be able to gain additional hours after graduation without residency status? They can get stuck with no way forward to pursue licensure.   

CommentID: 76589