The American Association for Marriage and Family Therapy’s Virginia Family TEAM Network (AAMFT Virginia) thanks you for the opportunity to provide input on the Petition for Rulemaking to amend 18 VAC 115-50, which aims to lower the relational experience hour ratio from 83% to 50% during the graduate program supervised practicum. AAMFT is a professional organization representing the interests of Marriage and Family Therapists (MFTs) in Virginia and across the United States. AAMFT Virginia is pleased to support the petition, with reservations. 

We empathize with the issue presented in this petition as there can often be a scarcity of places who can provide consistent relational hours to interns. Further, while we want to maintain an expertise in relational work through rigorous training requirements, we also do not want the current relational hour requirement to pose an insurmountable barrier to MFT trainees and result in trainees pursuing another type of licensure. The amendment proposes a change from 83% relational hours to 50% (120/240). We support this petition for a few specific reasons. First, a 50% relational hour requirement is more congruent with both LMFT residency licensure requirements in Virginia (i.e., 50% direct relational hour requirement), as well as COAMFTE (the national accreditation organization for marriage and family therapy training) training requirements (i.e., 40% direct relational hour requirement). Second, therapy interns often do not have control of what cases they are assigned, and therefore, they may not have the power needed to ensure a high relational caseload. Third, rural areas often experience severe provider shortages and disproportionately high rates of mental health issues. For instance, of the 95 counties in Virginia, 7 counties have only LPCs or MFTs rendering services. In three counties, there are no documented mental health providers at all. Given the shortage of providers in these areas, finding a practicum placement site that provides consistent relational hours and onsite supervision can be challenging. The current relational hour requirement (83%) may incentivize MFT trainees to pursue internship placements in more urban counties, where practices and organizations catering to relational services may be more widely available, to ensure meeting the high relational hour requirement in a timely manner. We propose that lowering the relational hour requirement to 50% is not only commensurate with other MFT hour requirements (i.e., COAMFTE and VA LMFT licensure) but may also incentivize MFT trainees to continue practicing in and serving rural counties. 

Our reservation with supporting this petition is that it may be “a slippery slope” to further relational hour requirement reductions. We support the current petition as it stands, reducing the relational hour requirement to 50%, with the caveat that we do not support further reductions in the MFT relational hour requirements. A 50% relational hour requirement will both maintain an essential relational hour training experience, thereby upholding MFT expertise and training in relational work, while also becoming more attainable for MFT trainees pursuing MFT licensure. 

Amy Morgan, LMFT & Debra Rezendes, LMFT

AAMFT-Virginia Advocacy Leaders