I oppose this petition primarily because it is completely unclear what the intent is. The petition begins with:  "To accept 1500 direct/indirect service hours". Does that mean 1,500 Direct and 1,500 hundred Indirect, or 1,500 Direct and Indirect combined? In either case, it would be proposing a significant reduction in the number of direct hours required. One would be a catastrophic reduction from 3,600 hour to 1,500. Let's assume the petitioner was not proposing halving the required hours. In that case, the reduction is still from 2,000 Direct hours to 1,500 and the total number of hours is reduced by 400 (from 3,400 to 3,000). Interestingly, in the actual petition, the text goes on to read, "For the 1000 hours to be considered, they must be in excess of the practicum and internship hours required for licensure..." This is the first mention of 1,000 hours, and I have no idea what that means, or where that reduction would come from. 

The most concerning part is that the petition suggests, "reducing the supervision concurrent with that experience from 200 hours to 50." That is a patently bad idea. Having trained over 1,000 LPC supervisors in the past decade one of the common concerns expressed is that they have so little time to influence a positive chance in supervisee knowledge, skills, and abilities in the 200 hours and two-years.

The purported rationale for this petition is to "expedite licensure" for residents from "comprehensive and well developed programs" and to "address the growing burden of mental illness for Virginians while also addressing limited career opportunities for Residents". With all due respect, the job of the Board is to protect the public and ensure client welfare. The proposed changes have the potential to reduce the quality of mental health services in Virginia, and licensing highly competent counselors should be focus of the Board not expediting licensure. Please do not accept this petition.