I highly support this proposed change. Doctoral students have layers of supervision and support and also advanced training in clinical practice and application. I hope the board will allow hours accrued during doctoral training to be applied towards residency hours.

Although in some counselor education programs doctoral students have several years of experience, I do not believe that "book learning" and research are an equivalent substitute for working directly with clients and the experience that brings. It would be sufficient to permit doctoral students to use their internship hours toward licensure, but no more than that.

Doctoral programs may not provide opportunity for the experience of clinical training to be found outside of the academic framework and hierarchy. Contingencies are very different, and needing to complete existing supervision hours strengthens the achievement of licensure and advancement of the counseling profession.