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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11/3/19  11:11 am
Commenter: Synergy Counseling

Fully Supportive
I have been an AAMFT Supervisor for many years. As always Virginia is the standard bearer for the counseling profession. I respect this very much and appreciate the efforts of the Board to maintain high standards.
I wholeheartedly agree and support the current proposal based on the following reasons:
The Virginia Board requires relational hours for MFT residency at 50% (1,000 of 2,000 direct hours) to apply for licensure. I believe the internship requirement should be consistent with residency requirements. The current Virginia Board internship percentage of 83% (200 of 240 direct hours) is unrealistic because interns have the least influence over the types of clients they are assigned. Just finding an internship is a challenge for students and then the unrealistic expectations of relational hours makes it even more difficult. In addition, COAMFTE only requires a 40% relational hours ratio for internships (200 of 500 direct hours). 
A review of the licensure regulations of about 20 states reveals requirements of no more than 50% relational hours. MFT/MFC interns also need clinical skills for individual clients, not just couples and families; a balance of 50% during internship is very appropriate. Under the current rule, interns may need to complete up to 400 direct client hours in order to obtain the minimum 200 relational hours needed for the VA Board requirement. This places unnecessary stress and financial burden on the intern to extend internship of up to two additional semesters just to obtain the unrealistic amount of direct relational hours.
In addition MFT/MFC students can meet university requirements and graduate with less than 200 relational hours, but he/she cannot be approved as a resident and has no path to licensure. Interns are often ignorant of the VA Board requirements and frequently depend on their university to guide and direct them towards licensure requirements which seems to rarely happen effectively.
In summary, the required direct relational hours for internship needs to reflect the same percentage (50%) as the required direct relational hours for residency.
CommentID: 76837