Virginia Regulatory Town Hall
Department of Health Professions
Board of Counseling
Regulations Governing the Practice of Marriage and Family Therapy [18 VAC 115 ‑ 50]


All comments for this forum
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7/30/12  9:20 pm
Commenter: Julia B. Sayre, M.S., LMFT

Support for the Petition
The Board’s mission to protect the public through rigorous assessment of applicants for residency and licensure is, in my direct experience, met with the strongest support of applicants, supervisors and providers. Consistent with this mission, the training of Marriage and Family Therapists focuses on the best interests of the mental health consumer, with attention to the highest standards of evaluation in that endeavor. As an active member of the VAMFT board, an approved and active supervisor, and a former educator in Virginia Tech’s MFT program, I strongly support a focus on rigorous education and training standards.
This petition serves to address the backlog of applications due to procedural changes in 2010, which have had a direct effect on the services available to citizens of the Commonwealth. The petition would ensure both mental health consumers and applicants of a win/win: a rigorous assessment period at no cost in professionalism to serving the greater public good; and low cost to the applicant, knowing that, once the approval process is complete, they will be able to retroactively count most of their working hours and supervision expenditures toward licensure.
The most significant factor driving this petition is to correct the delays caused by the backlog initiated in 2010. I am hopeful that this petition will apply retroactively to those many applicants who continue to be affected; these applicants who were told, after months of work and supervision, that the same job they have held for many months as they await final approval, will only count “once their application is complete.” Often they are already employed, their job descriptions do not change and they are graduates of a COAMFTE-approved program. In other words, as they wait for the approval backlog to clear, they are doing the jobs for which they are merely awaiting acknowledgement. They are gaining knowledge and experience that should fully be counted, assuming it is deemed to be an appropriate workplace setting with qualified supervision.
With due respect and appreciation to the hard work of volunteer reviewers, over time there have been numerous reports of applicants who have experienced inconsistency in assessment of credentials. This has resulted in applicants who have worked in good faith and believe they are “registered” but told years later that their credentials were, after all, insufficient. This reversal represents years of work hours and applicants’ personal resources wasted, and financial resources burned with no progress toward licensure. This petition would address the delays for these applicants, as well.
Definitions of “registration of supervision” and “completed application” have been vague in the regulations, rife with misunderstanding and misinterpretation. Is registration mailing in all the required paperwork? Many interpret it that way. Is an application complete when everything is sent in? Many understand this to be the case. And yet, for example, detailed explanations regarding workplace are requested and provided, several times in some cases; though the applicant has complied with answering questions, they discover their application is considered “incomplete.” Questions to the Board staff often go unanswered or receive insufficient responses, so that applicants move forward in the dark, with the hope that what they are doing will be approved, but with no assurances. These factors, combined with the 2010 backlog, have resulted in months of delays for applicants; these delays would be mitigated by this petition.
Going forward, the Board and DHP leadership have spoken to an interest in addressing these concerns. They have heard suggestions and received work product that can significantly decrease the processing time for applications, done in a spirit of good faith and collaboration. This petition acknowledges, though, continued delays that resulted from 2010. Further, it provides a safeguard both to the public and the residency applicants that mental health trainees will be appropriately educated and supervised, and that applicants’ work is moving them with timely progress toward their ultimate destination of licensure. Delays may be unavoidable in endeavors where public protection is paramount; however, this petition will ensure that applicants do not continue to literally and metaphorically pay the price of delays. It should be approved and applied to both current and future applicants.
CommentID: 23750

7/31/12  5:37 pm
Commenter: Mary Linda Sara


I believe that the proposed rule to have a 30 day period for response to requests for supervision is very important to the supervisee in terms of their ability to plan their schedules and work venues for supervision.

Further more, I believe that given the backlog that currently exists, backdating approvals is only fair to the people who have been waiiting months to know if the work they may be doing will be approved.


It is very hard for students to find opportunities to do their residency and to expect them to wait for months to have that supervision approved is unresonable. Frequently students  have less than a month between being accepted to do their work and the actual starting date.

CommentID: 23752

8/1/12  1:08 pm
Commenter: Michelle Ward, LMFT

Support of Petition to Backdate Resident Hours
The MFT licensure process has become increasingly confusing and difficult to navigate. MFT students graduate from their programs of study with the intent to find a job and earn a living as a new therapist—only to be caught up in delays and procedural inconsistencies with the licensure process. Our practice has offered resident placements since 2007. While there were often problems with response-time and consistency, the delays have become increasingly concerning since 2010. Even when paperwork is completed properly, it can take months or longer for residents to hear a reply from the Board. During these periods of no contact, residents need to earn a livelihood, so they continue to maintain employment without knowing if any of their hard work will count toward licensure. There have been cases where it takes over a year to get supervisor approval, or approval is denied, while others in the same cohort with identical coursework receive approval. Meanwhile residents lose months of increased income if the hours are only approved when the Board has attended to the applications, instead of the hours counting from the start of employment. I have grave concerns about the non-supportive licensure process in which our graduates are currently launching their new careers. 


As a result of the ongoing difficulties with the VA MFT licensure process, our practice has made the difficult decision to no longer offer resident placements. I believe this is an unfair conclusion we’ve been forced to make due to a broken system.
CommentID: 23753

8/2/12  11:08 am
Commenter: Scott Johnson, PhD, LMFT, Director, Virginia Tech MFT PhD Program

Support for the VAMFT Petition

Dear Licensing Board members,

I am writing to support the petition from the VAMFT board to end the backlog of unresolved applications for supervision registration.   As someone who was diirectly involved in the passage of MFT licensure for the Commonwelath in 1995, it saddens me deeply to learn of the needless delays and roadblocks to entering the profession that the 2010 change in registration approval has caused.  I am deeply troubled to read that at least one supervision placement has stopped taking interns because of these delays.   That is unconscionable.  Clearly the public needs more licensed MFTs, and needs them as quickly as they can be trained and credentialed.   Please enact the changes recommended by the VAMFT petition so that developing clinicians are expeditiously reviewed and MFT services are available to the public in proportion to the many who wish to serve them.

Scott Johnson, PhD, LMFT 249

Fromer President, VAMFT

Former President, American Association for Marriage and Family Therapy

Approved Supervisor, AAMFT

CommentID: 23759

8/2/12  6:00 pm
Commenter: Brandon Canter

Please approve this!!!

I am currently finishing my degree in counseling from Liberty University.  I have spent thousands of dollars to earn this degree.  I have stayed awake many nights and went on 3 hours of sleep to begin a career in the field I love.  I have taken time away from my wife and kids that I will never be able to make up.  As graduation and internship rules and requirements are done, the thoughts of waiting for the "Board" to make a decision for me that can take months is unacceptable.  I am not any MFT but getting ready to start my approval process for LPC.  I am not sure if this petition covers me or not but I am also requesting that the board also include LPC students.  We have worked very hard to get here.  We now need our board leaders to step up, move whatever may be in the way and get us to work.

The state of VA like most states is suffering a budget shortfall.  I propose that you get us approved quickly so that we can give the state our share.  If for no other reason do it to take our money!!!! Thanks for your time and consideration!!!!


Brandon Canter 

CommentID: 23760

8/3/12  3:14 pm
Commenter: Larissa Errichetto

MFT Supervision Petition

I urge you to consider adopting the proposed regulation regarding registration of Marriage & Family Therapy supervision.

As one working administratively to help recent graduates properly document the hours they have gained during internship, I have continually been exposed to the frustration and distress that this process has engendered.  

I am sure the board’s intentions are honorable and that you all are working under constrains as are the hopeful residents.  I hope - for the benefit of my fellow colleagues, as one who may seek licensure in this state as well, and for the community - that there is some type of solution that can be reached on the matter, some way to think creatively  to reach a resolution such that this process runs smoother for all.

Thank you kindly for your consideration.  

CommentID: 23761

8/5/12  7:58 pm
Commenter: Carl Mojta

Support for the Petition

I am very pleased to offer my support and participate in this important petition.  As a current candidate for MFT residency, it is incredibly frustrating not to have any expectations or timeframes when the application process will be completed and ultimately approved.  This results in increased delays toward the very long and expensive journey toward licensure.  I would like to echo Dr. Scott Johnson's comment about being deeply troubled about one supervision placement no longer taking residents; this is, therefore, one less opportunity for residents in the Northern Virginia community.

All Counseling/Licensure Boards - regardless of the the state or jurisdiction - have the incredible responsibility to protect the public by setting - and upholding - the standards for qualifications, training and experience; however, Virginia's process seems more challenging than some others to navigate.  It seems that if every step of the process has to be reviewed and approved by the Board without any specific timelines in place, such as a review of clinical duties/job descriptions, especially if there are professional changes, then the system has will will continue to be become backlogged.  I would suggest that supervisors whose credentials have been carefully reviewed by the Board should be authorized to verify that the hours being counted adhere to the regulations, given that it's ultimately each supervisor's oversight and responsibility.


CommentID: 23762

8/8/12  4:44 pm
Commenter: Maureen Smith Bethea, LMFT

Support for petition
Gaining experience as a resident is difficult with the current rules and regulations. Currently, therapists and supervisors are receiving the consequence for the lack of response from the Board. This has come in the form of residents being unable to count viable work experience, unending waiting and constant resubmitting of paperwork, as well as the failure to gain employment due to placements inability to wait months and months for their new employees to be approved due to the Board’s lengthy process. The approval waiting time being 6 months to over a year makes beginning employment impossible all while valuable time, income, and experience is lost.
As a resident, the process of submitting paperwork was disheartening. The idea that the Board has an unlimited amount of time to review applications with no obligation the residents or supervisors regarding response time or consistency is negatively impacting new therapist’s faith in the Board and the MFT community.
CommentID: 23763

8/8/12  9:17 pm
Commenter: Michael A. Fronce, MS, Resident in MFT

Support Positive Change

I am writing this comment in support of the rule change petition presented before the Board of Counseling (BofC).  My perspective is as a current resident in Marriage and Family Therapy and as one who has been directly affected by the changes in procedures that took place in 2010.  I began residency in the fall of 2009, excited to grow as a professional under the watchful eye of qualified supervisors. Due to changes in employment, I submitted changes to my supervisors as I changed jobs in the fall of 2010.  I submitted my changes and the reviewer requested additional information about my job.  I submitted their request.  I was again asked for additional information on my job.  After 6 months, I finally had my supervisors approved.  As my job and my supervisors did not change during this process, I requested to have all of my work approved.  My request was denied based on the BofC’s assertion that no experience counted prior to approval.  My frustration with the BofC grew as I learned that my professional career was put on hold even though I was doing the same job and receiving the same supervision.  I began to question whether or not I wanted to continue the process in Virginia, move to a different state, or even quit all together due to the delay in my process of fulfilling requirements for licensure.  Whenever I asked for updates in the process I was denied communication.  ?While 6 months may not seem that long in the grand scheme of things, my perspective is a bit different.  I am a husband who is earning below my potential due to the lapse in turn around and response time.  I am a new father who is spending hours away from my new little boy due to the hours and work schedule that is part of the “dues” that are paid in accruing hours for licensure.  I have spent thousands of dollars in getting supervision from fantastic supervisors who challenge me professionally and encourage me to be the best clinician I can be.   However, my professional career was halted for 6 months.  Had I been granted the approval of the hours that I had earned in those lost 6 months, I would be a licensed professional right now, providing much needed mental health support to citizens of the commonwealth. But now, I continue to work toward licensure in accruing the hours that logically would have been granted had the system been in place that this petition is requesting.  I know that I am not alone in my frustration with the BofC.  Other residents have been experiencing delays as well.  I know that the BofC has made efforts to respond to complaints and frustrations. My hope is that this petition will be considered and that rule changes will be made. ?Not only do I support this petition, but I also encourage the BofC to be more open to suggestions from those who are being affected by the rules and procedures. Suggested improvements include but are not limited to:  **Focus groups of residents to assess the application/resident process. **Technological improvements that could include web-based system to show where applications/changes are at in process (relief to BofC staff from being pestered for information). **Explanation on website of use out-of-state or outsourced reviewers (relief of BofC staff to answer questions). **Electronic database of approved supervisors and their credentials (speed up the process of approval). **Electronic database of work establishments that have been approved (speed up the process of approval). **Email blasts using blind carbon copy to ensure confidentiality, to alert residents of changes in rules/policies. **Communication between residents and reviewers to speed process of approval/compliance?Perhaps there are other ideas that could be helpful in finding solutions.  That is what therapists do, help people find solutions so that they can live their lives with more confidence, happiness, and manageability.  Perhaps we could all work more effectively in having a system that promotes high standards, clear communication and expectations, and speedy service delivery.  I submit my own name as a person that would be willing to be a part a group to help create a more open and streamlined process for those who come after me. I, gratefully, am nearing completion of my hours and supervision in residency. Changes in these rules will not likely affect my experience.  I have come to terms with this.  However, I cannot imagine that this system can continue to operate the way that it has without continued problems of backlogs, lapses, and poor communication.  I would be happy to support positive change and, when it becomes my turn to be a supervisor of impressionable residents in therapy, I can help them navigate a more clear and effective system, one that I can energetically support.   

CommentID: 23764

8/11/12  5:32 pm
Commenter: Cynthia Mathis, LMFT (owner, private practice)

Support Petition

I am in support of the petition for residents to receive verification from the Board within a 30-day time frame to approve their residency.  I currently hire LMFT residents in my private practice, but have encountered numerous difficulties with the Board in past several years.  Recently, it took the Board a year and a half to approve the supervision for one resident I supervise.  This resident is very deligent and turned in all of the paperwork for approval in a timely manner.  However, the Board continued to ask for additional clarification of documents and took long periods of time to respond once materials were sent.  For example, in one instance they asked for a information about the work place on the form that I filled out for the supervisee.  I filled out the information on the form about my practice, kinds of clients the resident would see, etc.  The Board, months later, then said the information wasn't accepted because it needed to be on letterhead (although it had said to put the information on the form).  I put the same information on letterheard, as they requested; however, it still was not accepted.  They then did not understand the definition of the workplace.  I had used this same detailed definition of my practice for other residents and it was always approved.  

I think providing a timely response to residents is crucial for them to be able to receive residency placements, in addtion to clear paperwork and definitions of what the Board needs to complete the packets and giving supervisors some type of notice (via e-mail or a website we can check) if regulations or requirements of supervison/placements change.  I want to continue to be able to hire residents in my practice, but I am very concerned I will not be able to do so in the future if these regulations do not change.  As a community of licensed professionals, I think it is vital that we band together to support  this petition and residents as they work hard to become licensed LMFT's in Virginia.   



CommentID: 23768

8/16/12  2:03 pm
Commenter: May Kanti, VT MFT program

Support for petition

I support the petitio and urge the board to consider doing the same.  I echo the comments made by others urging the board to provide responses to applicants in a timely manner and streamlining the processing of the backlog of applications resulting from the 2010 procedural changes.

CommentID: 23772

8/16/12  2:33 pm
Commenter: Jordan Johnson

MFT petition

As hopefully a future member of the licensed MFT community I wholeheartedly support this petition. 

CommentID: 23773

8/16/12  3:12 pm
Commenter: Andrea K. Wittenborn, Ph.D., LMFT

Support for Petition
I am writing to express my support for the petition. As an educator in Virginia, I have witnessed the increasing difficulties that new MFT professionals are experiencing during the licensure process—loss of significant time, income, employment oportunities and confidence in the field, to name a few. Some highly skilled graduates have even elected to practice in other states or obtain other types of credentials to avoid the roadblocks experienced by their peers. Needless to say, such trends, if continued, have the potential to become quite devastating to the profession and community. The proposed solution seems a valuable first step towards improving the application process and eliminating many of the unfortunate struggles new professionals in Virginia are currently experiencing. I provide my strong support of this petition.
Andrea K. Wittenborn, Ph.D., LMFT
Assistant Professor of Family Therapy, Virginia Tech
AAMFT Clinical Fellow and Approved Supervisor
North Region Vice President, Virginia Association for Marriage and Family Therapy
CommentID: 23774

8/16/12  3:21 pm
Commenter: L. Chris Davies, MS, Resident in MFT and Professional Counseling

Support timely approval

I am writing in support of the petition for the Board of Counseling to count residency hours starting 30 days after submission of supervisor registration.  So much can be said in favor of this petition, and there is not even a compelling reason against it, in my opinion!  This is a "win-win" for all parties involved, not just residents.  It benefits recipients of Marriage and Family Therapy services, organizations recruiting licensed therapists, and the profession in general.  It involves no slackening of the rigor of requirements whatsoever.  This will even benefit the Board itself, because it will not add any workload burden on the Board and will even alleviate pressure on the Board in cases where they need to take longer to respond.  Approving this petition is a step in the right direction and an obvious one.  Frankly, a compelling argument could be made in favor of an even more ambitious petition, and the bar truly could be raised on the part of the Board in several domains.  It is my hope that, in addition to approving this petition, the Board will also endeavor to make other much-needed improvements in actual response times (for all included professions, not just MFT), in the consistency of reviewers' interpretations of academic requirements for licensure, and in the ease with which someone waiting for correspondence from the Board can do a simple status check (such as through electronic query).  It is reasonable to insist on the Board's improvements in these areas, which can be feasibly done through simple improvements in efficiency and consistency in workflow, even by a staff of such limited size. 

I speak as someone who had to wait of two years since my supposed completion of requirements to take the licensure exam due to cumulative delays in the Board's responses to my communications about contested academic requirements before these were finally accepted.  This could have been resolved in a matter of a month or two if responses had been reasonably timely.  The fact that the coursework had to be contested at all also evidences the issues around the subjectivity and inconsistency of the review process. 

CommentID: 23775

8/16/12  6:19 pm
Commenter: Linda C. Padgett, MS, Resident in MFT and Professional Counseling

Support for Petition
I would like to add my voice in support of the petition that the approval date of MFT supervisor registration by the Board of Counseling be no later than 30 days from the receipt of the applicant’s request. No one is served when residents’ time and resources are unnecessarily wasted. Also, as a licensure applicant who is currently waiting for a response from the Board, I greatly appreciate another commenter’s suggestion that the Board consider developing a web-based system to show the status of applications.
CommentID: 23776

8/17/12  11:36 am
Commenter: Mary Moussa, VT MFT Student

MFT Petition Support

I fully support this petition to end the backlog of applications for MFT licensure. As a beginning therapist, it raises major concerns for my desire to pursure a future practice in Virginia. Many colleagues of mine have raised concerns about their ability to obtain post-master's positions, and delays MFTs from beginning their professional careers. Some students are choosing to defer their licensure applications to other states to avoid the difficult process of application in Virginia. I believe that Virginia will lose many able and well-trained clinicians without a solution to this problem.

Thank you for your consideration.

CommentID: 23777

8/17/12  1:02 pm
Commenter: Monica Huerta, VT MFT Graduate Student

Support for Petition

As a future MFT grad, I support this petition.  The ruling to this petition will highly influence my decision to apply for licensure in VA or my state of origin.  

CommentID: 23778

8/18/12  11:29 am
Commenter: Stefani Hendrick-Whetzel, LMFT, LPC

Support for MFT Petition

I am writing in support of the petition requiring that supervision applications be approved within a thirty day timeframe.  As a licensed LMFT in the state of Virginia since 2004, I have noticed a significant shift in the way applications are managed.  When I had submitted my paperwork in 2001 and 2002, I received a quick response.  I was able to begin my residency prior to the approval as it was considered a valid contract as the date it was sent to the board.

As a supervisor in the MFT program at VA Tech, I have been made aware of the increasingly difficulty in obtaining approval and the board's decision not to hold the contract valid as the date of filing.  I find this unfair to those residents as it has jeopardized their placements and jobs.  Due to the current state of public mental health, it has been extremely hard for our graduates to obtain employment in the public mental health sector.  As a result, graduates are turning more to the private practice sector which require timely registration of their residency.  Our graduates do not need further roadblocks in their practice in the marriage and family therapy field.

I kindly ask that applications are approved within a 30 day timeframe and are back dated to the date of the application.

CommentID: 23779

8/22/12  11:22 am
Commenter: Rebecca Gleed

Support for Petition

I fully support this petition.  I moved to Virginia after completing my MA at Syracuse University in MFT.  I have been highly discouraged with Virginia's slow and difficult process.  In NY State, residents are able to contact the board within 24-48 hours with application questions while those in VA often never receive a returned call or email from The Board.  This causes significant anxiety as residents are dependent on the board for professional decision making. 

For example, I have tried multiple times to contact the board in order to confirm that my additional coursework will comply and have not received a return call in over 9 months. I am risking thousands of dollars by taking additional courses which 'I believe (after scrutinizing the regulations)' will comply with Board Requirements.  It also took nearly 9 months before receiving approval to begin residency hours.  This process is in need of serious change.

CommentID: 23783

8/22/12  1:17 pm
Commenter: Jessica Perkins, M.S., MFT Resident

Support for this Petition
I am writing to express my support for this petition. I graduated from an accredited MFT program here in Virginia in the spring of 2010 and have been shocked to hear the stories of my cohort’s experiences with obtaining residency during the past two years. We took the same classes, had similar internships, worked hard, and spent a lot of money and time earning a quality degree. We’ve pursued appropriate and meaningful jobs, lined up Board-approved supervisors to complete our residency, and yet we’ve each had drastically different response from the Board. Some have been positive, some have been confusing, and many have been discouraging.
I can say that everyone I’ve spoken or emailed with at the Board during this process has been very kind and respectful, which I greatly appreciate. But the overall lack of clarity in what to expect from the Board and the months-long waiting periods that exist between Board feedback has been confusing and frustrating. I graduated from my program in 2010 in love with this field and confident about my professional future. Today, my interactions with the Board during the past two years have significantly reduced the confidence that I personally have in the MFT license in the state of Virginia and the Board as a whole. I love this state, I love the work that I do with families in this state, and I respect the fact that the qualifications for licensure in Virginia require substantially more effort and experience compared with most other states. I trust that the Board is working hard to help licensed MFTs and MFT residents, and I don’t know where the breakdown is in the Board’s processes. I hope that the Board will consider this petition and support the future of the MFT field in the state of Virginia.
CommentID: 23784

8/24/12  9:45 am
Commenter: Sarah J. McElhaney, M.S., Resident in Marriage & Family Therapy

Support for Petition
CommentID: 23799

8/24/12  10:06 am
Commenter: Sarah J. McElhaney, M.S., Resident in Marriage & Family Therapy

Support for Petition
As a resident that has been through the process of registering supervision to apply towards licensure in Marriage & Family Therapy, I support this petition whole-heartedly. I recognize and appreciate the Board’s role and their dedication to protect the public community at-large. By establishing and implementing a rigorous credentialing review process of applicants, a respectable standard to our field is recognized and promoted. While understanding and holding all of this, much as being a member of the public community, I have been privy to the experience of what it’s like on the receiving end of this process as an applicant. In short, the lack of clarity, organization, and responsiveness that I experienced in my interactions with the Board as an applicant seems to highlight the supervision registering process is not functioning as well as it could or should. These amenable proposed solutions (found in this petition) maintain the Board’s upmost commitments to the public community, while also providing the proper responsiveness, attentiveness, and understanding deserved by the applicants who are diligently, and in good-faith, going through this process. I think a “lose-lose” situation for both the Virginia public community and our mental-health serving community would be for well-trained, qualified clinicians to lose confidence in the Virginia licensing and credentialing process and go to other locals to practice. I have hope that our community of MFTs can work together with the Board to address concerns and implement changes to benefit all parties. Therefore, I support this petition for the aforementioned reasons.
CommentID: 23800

8/24/12  4:51 pm
Commenter: Frances Bell LMFT LLC

Please approve backdating approval of applications

Please approve the petition change.  When I was a Resident the Board of Counseling was supportive and helpful to me and others in completing my residency--which I did in 2007.  I am grateful to the Board for approving my residency within a month or 6 weeks of application. 

However, it appears that staff cutbacks at the Board of Counseling has changed that attitude and ability of the board to provide timely responses and efficient handling of applications to start Residency.  It is sad that the Board has been unwilling to recognize the need for efficiency and fairness in this process. It is obvious that given the inefficiency is with the board process and not (usually) the Resident, that approval should be given as of the date of submission. 

Achieving 4000 hours of clinical experience in a residency is a a long and hard road.  It is a shame that significant hours of clinical experience are disqualified by the board when applications have been sitting in the board's hands for 3 months, 6 months, a year or more.  The Resident should not be held responsible or made to "pay" for the inefficiency of the board. 

Please accept this petition and approve backdating of applications for Residents. Its the only fair thing to do!


CommentID: 23806

8/25/12  1:41 pm
Commenter: Arlene Malone, M.A.

Support Petittion

I respectfully urge approval of this petition. It is only reasonable for approval to be effective within 30 days after receipt of application.  Applicants should not be penalized for lack of manpower on the Board or whatever other challenges the Board has in being more prompt in reviewing and making decisions regarding residency approval/disapproval.  I personally had to wait six months before hearing back from the Board and then was penalized by the Board for the Board's inability to act more promptly by not being afforded the courtesy of backdating the effective date of my approval to within 30 days after the Board received my application, and this cost me six months of hours/supervision that I will not be able to count towards licensure. When people are trying to take the necessary steps and meet requirements to become licensed as a professional counselor, it is unfair and unjust to penalize applicants when the delay is outside the applicant's control.  I am requesting approval of this petition for LMFT and LPC.


Arlene Malone, M.A.

Counselor in Residence 

CommentID: 23807

8/26/12  2:48 pm
Commenter: Ed Hendrickson, LMFT, LSATP

Support for Petition

I support this reasonable and timely change to the process of approving residents. I have supervised a number of residents in Virginia over the last five years and have found the approval process to be both uneven and inconsistent. I believe this is the result of the Board not having enough staff to perform all of its required tasks. It is my understanding  the Board has contracted out the approval process for residents which has resulted in a great deal of inconsistency in the approval process. I doubt that the Board will be provided sufficent staff anytime in the near future to perform close overslight over this contracted out process, thus when mistakes or misunderstandings occur, and the have occurred much too ofen, there is no real way to quickly resolve them. These mistakes and misunderstandings slow down the approval process for resident candidates, who in actuality meet all the requirements, but can not  in fact begin collecting clincial and supervisory hours in a timely manner. Thus the starting time requested in the Petition when hours can begin to be collected seems to me to be both fair and right for these individuals and is an appropriate response to the situation in which the Board finds itself.

CommentID: 23808

8/26/12  6:34 pm
Commenter: Myra Gillum, Va. Tech MFT Resident

In Support of the Petition

The process of becoming a licensed marriage and family therapist in Virginia is a long and arduous one even when the system functions smoothly, but the purpose is to assure the best possible care.  However, currently the lack of clarity, long delays, lost papers, inconsistent responses, and, worse yet, no responses at all burden the licensing process.  Hard-working, qualified  applicants unnecessarily lose money (thousands in supervision and course fees), time (months and even years), and sometimes ultimately the desire to complete the necessary steps.  If they're extremely well organized and persistent, if their family can be patient, presumably, eventually, they will be allowed to take the difficult written test, get their license, and begin their official career as a therapist.


This does not serve the profession well nor those in need of vital mental health services.  Those who make it all the way through may feel burned out when their career is barely launched, and surely there are those who give up altogether or decide to practice in other states.  Given the crises facing the country currently, hurting Virginians need more practitioners, not fewer. 


I graduated from Virginia Tech's MFT program in 2007, with honors, yet for two major reasons I decided not to pursue licensure, although that was my original goal.  The first reason was a long-term health crisis developing in my immediate family, but the second reason was different.  Having heard so many stories of ongoing frustration from friends and colleagues trying to get licensed, I knew that the increasing demands on my time at  home would not permit me the luxury of dealing simultaneously with a slow, inconsistent, and seemingly indifferent Board of Counseling.  Reluctantly I abandoned my hope of becoming a licensed MFT therapist.


Mental health practitioners have a state-mandated responsibility to report cases of neglect and abuse.  Rather than being a model of professional relations, the Board of Counseling's dysfunction, however unintentional, has had a major negative impact on a lot of fine, well trained clinicians with high aspirations and demonstrated willingness to work hard.  We have been reporting the situation for a long time, and now it's time to officially acknowledge the problems and work together to fix them.


Myra Gillum

CommentID: 23809

8/26/12  6:35 pm
Commenter: Veeta W Mitchell, MA, NCC, Resident

Support For Petition
My initial application for residency was received by the Counseling Board on June 15, 2011, but because I utilized a form that was dated 2010, instead of 2011 (which only had a change in one line), I had to resubmit my application which I again mailed off on June 17, 2011, which was finally approved and confirmed that I could begin counting hours on 9/26/2011. This was three months of awaiting approval and notification. Additional staff or a better system should be implemented to expedite the process of obtaining licensure, because this is affecting people's livelihoods. 
CommentID: 23810

8/26/12  11:51 pm
Commenter: Eve Hornstein, MS, Resident in MFT

Support for Petition

Virginia mandates 4000 hours of clinical experience in residency, which is much greater than many other states. It is essential that hours for residency count as soon as possible so that residents may begin to accrue hours for licensure, which is a long and arduous process. Moreover, all residents should be treated equally. I am, therefore, in support of the petition that the approval date of MFT supervisor registration by the Board of Counseling be no later than 30 days from the receipt of the applicant’s requests.

CommentID: 23811

8/27/12  11:13 am
Commenter: Mary Buchanan, MA, Far Beyond, LLC

This reform is desperately needed!

I strongly agree with what my colleagues have already written here. It is beyond frustrating to be finally ready to begin the long, difficult, expensive process of completing your residency hours only to be told that you may not be allowed to begin moving forward in your career for an unknown period of time because the board does not have time for you. Jobs and finances and career decisions are on the line here. I encourage the board to work with us to expedite this process.

CommentID: 23817

8/27/12  11:45 am
Commenter: Takiya Tarlton, Graduate Student

Support for this petition

I am in support for this petition

CommentID: 23818

8/27/12  9:38 pm
Commenter: Donna C. Fortney, NCC, LPC, President, NVLPC

In Support of Petition

This petition should be considered and rule changes should be made. I encourage the Board of Counseling to be more open to suggestions from those who are being affected by the rules and procedures. Suggested improvements include but are not limited to: Increasing funding to support technological improvements that could include web-based system to show where applications and changes are in the process, adding more staff, using electronic database of approved supervisors and their credentials so Pre-Licensed folks can find supervisors in their area. Electronic database of work establishments that have been approved which would speed up the process of approval. Using Email blasts (blind carbon copy to ensure confidentiality), to alert residents of changes in rules/policies. Communication between residents and reviewers to speed process of approval/compliance. There are many willing mental health professionals in this state that are prepared to help find reasonable solutions to these and many other problems with this broken system.

Thank you for allowing our voices to be heard. Respectfully submitted,

Donna C. Fortney, NCC, LPC

President, NVLPC

CommentID: 23822

8/27/12  11:08 pm
Commenter: Lourie W. Reichenberg, MA, LPC

In Support of the Petition

CommentID: 23824

8/28/12  7:03 am
Commenter: Robin Raniero Norris, PhD, LMFT

In support

Having moved to Virginia from California already as an LMFT in good standing in California, I can say with confidence that the board needs additional resources because the public is accidentally being denied solid residents and clinicians by delays in the process.  There have in recent times been more accurate responses at much more reasonable responce rates than in my arrival in 2008 but, the problem is not fixed, the board needs additional people working in order to keep up with the supply and demand both from the public's need for clinicians and the residents needs to want to meet the demand.

Dr. Robin Norris, LMFT student development chair NVLPC

CommentID: 23826

8/28/12  7:26 am
Commenter: Elizabeth Brokamp, LPC

In support of petition

Individuals seeking licensure in health care in Virginia (LMFTs, LPCs, etc.) should be guaranteed a reasonable timeframe (30 days) in which to receive a response from the Board.  Extending the timeframe means lost hours, lost opportunities, and a negative economic impact.

CommentID: 23828

8/28/12  9:21 am
Commenter: Loretta Schulz, LPC

In Support of Petition

This petition is long overdue.

CommentID: 23829

8/28/12  11:17 am
Commenter: Sarah S. Briggs, LPC, RPTS

In support of the petition

I would like to express my support of this petition.  I have been a supervisor of residents working toward their LMFT and LPC for the last 11 years.  Many of those residents have been graduates of the same reputable Marriage and Family Therapy program.  Over the last few years, I have become increasingly concerned with the licensing process that they are enduring.  In my experience, these residents are entering into the field with enthusiasm and excitement only to be met with frustrating obstacles.  These obstacles are not clinically related but Board related.  I agree with my colleagues sentiment in these posts and am impressed with the variety of proactive ideas that have been generated.  One of the issues that has been the most frustrating, in my experience, is the descrepency in each applicants burden to legitimize their graduate program and coursework.  My hope is that once a program has been reviewed and approved to have met certain educational requirements there would be no need for future applicants to continue justifying the same program.  It seems that this has only created more work for the applicants and I would assume the Board. 

I am sorry to say that for the first time in 11 years I will not be supervising a resident.  The current state of the superisory application process has made it impossible for me to hold a resident position for the length of time needed to gain supervisory approval.  I am hopeful that some of the ideas mentioned in the comments of my colleagues will be implemented and this process will be improved.

CommentID: 23834

8/28/12  12:23 pm
Commenter: Esther Boykin, LMFT; Group Therapy Associates

in suppport of positive change

As someone who was quite lucky in her residency, I feel that it is important to lend my support for this petition.  Like many of my colleagues I am very familiar with the challenges of the residency process for MFTs (and I believe most mental health licenses) in Virginia but as I said I was lucky.  My supervisors were approved quickly as was my work location, coursework, and residency hours.  I moved through the process quite smoothly but all the while I listened and supported former classmates, who tok the same classes, worked in similar professional settings, and even had the same supervisors as I did all struggle with delays, multiple requests for information, and minimal communication.  This process should not be one of "luck" but a consistent and efficient system that encourages residents to develop their professional skills so they can provide licensed services to our communities.

As a private practice owner working with residents, I can see that the challenges continue and I am so glad that this petition has been started.  We are losing excellent clinicians to other states (particularly in Northern Virginia where you can easily commute to Maryland or DC) and other professions because of the problems with residency and licensure in Virginia.  It's time to make a change in support of the next generation of therapists and the thousads of individuals, children, and families that are in need of our services.  I strongly support the 30 day approval period as well as backdating and many of the other changes suggested in the peition and comments.  In particular I would reccomend a database of supervisors and work locations- which would not only help residents but encourage supervisors and potential employers to meet a consistent standard when working with residents. 

CommentID: 23836

8/28/12  2:32 pm
Commenter: Kelsey Myers, MS, Resident MFT

Support for Petition

I would like to add my support for this petition. I am a current resident in MFT and feel strongly that improvements need to be made to address the efficiency, consistency and clarity with which the board conducts and upholds policies and procedures. The level of unnecessary (and clinically irrelevant) anxiety and frustration that meets residents throughout the licensure/supervision process is very disheartening. Unfortunately, I have very talented colleagues who have chosen other professions and pathways as a result of the difficulties encountered in the process of working with the board. My concern is that our field is actively losing qualified associates due to procedural and policy issues that could and should be remedied. I would ask that the board please consider the valuable input of my colleagues in considering changes that may be made to increase opportunities for new clinicians in our field. Thank you for your consideration. 


Kelsey Myers, MS

CommentID: 23839

8/28/12  2:50 pm
Commenter: Margot Schultz, M.A., NCC, Resident in Counseling

Funding for staff increase at the Board of Counseling

I agree with all the residents and their supervisors who have been calling for a larger staff with new response-time deadlines at the Board of Counseling.  I had to wait on approval to change supervisors from October 15th (2011) until February 10th, 2012 with the stipulation that I could not do any counseling until the approval was granted. At this rate of progress, I will not make it out of the pre-licensure phase by the five-year post-graduation mark.

It is astounding to compare the Nursing profession to our own. They come out of their internships provisionally licensed and able to begin working, as long as they pass their license exams. By contrast, counselors, have to find a way to put together 4000 hours in a system where very few people or institutions have any incentives to help us. When we do find a placement, there are not many clients given to us because we are merely "pre-licensed" and cannot accept insurance. Also, the licensed counselors get first choice of the direct pay (cash) clients.  Looking at this scenario is similar to observing a broken food chain;  the weakest members at the end of the chain are getting forced into extinction.

I hope you will help us save the newest Counselors,

Margot Schultz

CommentID: 23840

8/28/12  10:06 pm
Commenter: Erin Sharp

In support of the petition


As a beginning Resident, I write in support of the petition to backdate application approval for Residency supervisors.  I am a recent graduate of a high caliber Virginia Marriage and Family Therapy program, and I feel well prepared by the program and my previous professional experience to continue the learning process by serving as a Resident in MFT.  Wanting to ensure the quality of my work and that of my peers, I have a great deal of respect for the high expectations the Board of Counseling lays out for the licensure process.

However, I currently carry student loans from my education and I've got a young family that I am trying to juggle in the midst of changing careers.  It is so disheartening to learn that it may take 6 months to a year before any of my Residency hours will apply.  Not only that, it is a cause of a great deal of anxiety.  Due to the structure of the Residency program I an entering this fall, I am not even able to send my application to register my supervisor until sometime in the next month.  This puts me in the position of starting my Residency -- and paying for supervision -- knowing that it may well be next summer before ANY of my hours of supervision, client contact, or related administrative work will apply.  Thus, I have had to make the decision to work two part-time jobs in order for my dual-career family to get by: one in my previous field, and the other, my Residency.

I'm sure the staff at the Board of Counseling is working very hard to do their best for their applicants.  If the State of Virginia is unable to supply them with the support they need to do their work in a timely fashion, it is only just to change the regulations so that the Board approval is back-dated to within 30 days or less of the original application.  Residents should not have to pay the high price of these delays.

Thank you for considering this petition.

CommentID: 23845

8/28/12  10:19 pm
Commenter: Ellie Hsieh, MS, LMFT - National Counseling Group, Inc.

In support of the petition

As someone who recently got licensed back in November 2011, I know first hand how difficult it was to get licensed due to the time it took for paperwork to be reviewed or for there to be any confirmation that paperwork was received by the Board of Counseling.

I strongly support this petition to allow requests for licensure supervision to be backdated because it is unreasonable to expect candidates for licensure to be waiting nearly 2 to 3 months before they hear confirmation of approval for licensure supervision. During the time candidates await approval of their licensure supervision, they are working hard to accrue hours towards licensure. However, none of those hours will count because the approval date of their licensure supervsion is often dated months later than when their paperwork was first submitted. Additionally, if a submittal for approval of licensure supervision is rejected or needs additional information and this is not communicated in a timely manner to the candidate, then the candidate has lost even more possible hours to accrue towards licensure. This is nearly an injustice to individuals who have worked hard and paid significant supervision and graduate school fees to reach this point in their licensure process. Furthermore, it reflects poorly on the State's Board of Counseling and indicates significant institutional issues.

There are many possible ways to imrpove and streamline the overall licensure process, including having an electronic submittal system that will ensure paperwork is submitted correctly and confirm that an application has been received. It is high time that our Board of Counseling enter the digital age and take advantage of technology that can improve the professionalism and quality of the Board of Counseling.

CommentID: 23846

8/29/12  12:20 pm
Commenter: Steven Ecker, PhD, LPC; private practice

I support the petition.

Supervisees have complained of long wait times for responses from the licensure board.  They report minimal support along with complex details regarding board expectations.  Their experience discouages efforts to strive to meet licensure standards and, thereby, improve professional skills.  Ultimately, that negatively effects all mental health substance abuse professionals by lowering expectations and qualifications within our field. 

CommentID: 23851

8/29/12  12:38 pm
Commenter: Deborah Sikes, LPC, LSATP, VP Clinical Services, NCG

In Support

In working for an organization that fully supports professional development, I have increasingly seen individuals coming out of graduate programs and struggle to navigate what appears to have become a process within the DHP that is confusing, adversarial at times, and antiquated.  DHP decisions following submission of Licensure Supervision applications can be issued after 3 to 4 months time, resulting in the loss of productive supervision that many of the previous commenters have referenced. 

For these reasons, I am in support of the proposal to accept supervision provided from the time beginning within 30 days of the receipt of the application.  Each step taken to improve the process will encourage and support talented young professionals committed to career development and caring for our most vulnerable populations. 



CommentID: 23852

8/29/12  3:07 pm
Commenter: Joseph Pratt, National Counseling Group

In support


I would be in support of this, across the different licenses.  The Board should recognize how impairing it is to have to put off supervision so long, especially for those just out of school from a CACREP accredited program that have already started official residency hours through their internship, then they have to put everything on hold and wait for the Board.
CommentID: 23854

8/29/12  3:10 pm
Commenter: Jim Pritchard, LPC, NCG

In support

Approvals should be retroactive to date of initial receipt of request.

CommentID: 23855

8/29/12  3:13 pm
Commenter: Lisa Rodgers

In support
CommentID: 23856

8/29/12  3:21 pm

In Support
CommentID: 23858

8/29/12  3:29 pm
Commenter: Lisa Iervolino

In Support


I support this petition for LMFT, as well would like for it to be considered for LPC and LCSW applications. While the laws require for professional counseling services to be provided by those that are licensed or registered for licensure supervision, many, if not most positions where supervisees are able to provide clinical counseling services towards licensure do not have job responsibilities where they cannot be doing any clinical responsibilities during the time period where licensure supervision has been applied for but in the pending process.
Given the current arrangements of the Board for limited reviews during the months, with stated waitlists due to increased volume that they have acknowledged and limited staff available, in addition to increased review of detail and lack of clarity for new applicants on what specific details the Board is seeking in their reviews of job descriptions or whether educational programs will have been approved or not, people are hired or placed in job positions where clients are in need of counseling services, however, the staff may either provide the clinical services without the registered supervision in the meantime, and not receive credit for the hours once later approved, or are providing sub-par clinical services in order to not be accused of “counseling” without having the registered approval from the Board during the time period while pending and since it will not be back-dated when later approved.
I understand the concern of the Board, that they do not want to set a standard of expectation for backdating, in that it then gives counselors and employers the ability to say staff are providing counseling services, when there is a risk that the Board in their review process may find the applicant is not able to meet the requirements for approval, such as the degree program not meeting DHP requirements even if the job description does, or that counselors may lose more money getting started with a supervisor to later find out they are not approved for a similar reason, rather than having waited.
Perhaps the Board could allow a new designation for applicants who have submitted an application for residency supervision but the application is still in the review process, such as “Resident in MFT – pending” (and preferably similarly for LPC and LCSW as well), as a way of demonstrating to clients the current status of the individual, but allowing individuals who have a supervisor believing they will be approved to provide the clinical counseling services that clients in their position need, and document them as such, as well as to have the supervision they are receiving in the meantime backdated, such as to 30 days from application date. For those who are determined by the Board to not meet criteria, then they would have lost their money with risking supervision approval in advance, and the “Resident in MFT – pending” status and counseling duties would need to end at notification, but those approved would be able to continue to have their clients receiving actual counseling services rather than the lower level needing to have waited the full DHP approval process until that time.
Practically, many employers and individuals do not have a luxury of waiting 3-9 months to start a particular job duty that is needed for the approval process. Employers that do provide multiple levels of service to clients and can offer client services but wait until approval for the staff to provide the “counseling” services is leaving the client with a lower level or incorrectly labeled service in the meantime, while the client is likely referred to that particular service/provider due to other options being less appropriate for them at that time.
Allowing a “Resident in MFT – pending status” (as well as for other DHP professions) while the application is pending, with backdating the approval to a date such as 30 days (a more reasonable wait period for an individual in counseling services position to be able to begin counseling with clients) could assist with addressing the concerns of supervisees, provider services, and clients.
(submitted second time since notes not retained on 1st comment attempt)
Lisa Iervolino, LCSW
CommentID: 23859

8/29/12  3:31 pm
Commenter: Lisa Rodgers

In support

(comment not saved on prior submittal)

I applied to start supervision here in Virginia for both MFT and LPC since my masters is marriage and family therapy. I received a confirmation e-mail on May 8th 2012 stating they received my application. It was not until August 1st that I received a response to that application regarding eligibility which is almost 4 months. I know turn around time in other states I have lived is 30 days which should be sufficient. I also feel that during these 4 months of wait time the counselor should be able to start accruing the hours and should not be penalized due to the extraordinarily long time the board takes to process an application. At 40 hours per week for 4 months that's 640 hours that could be lost which is a shame since clinically valuable work is being completed and supervision given.
CommentID: 23860