8/23/2021 1:55 pm
Date / Time filed with the Register of Regulations
VA.R. Document Number: R____-______
Virginia Register Publication Information

Transmittal Sheet: Response to Petition for Rulemaking
Initial Agency Notice
Agency Decision
Promulgating Board: Board of Counseling
Regulatory Coordinator: Elaine J. Yeatts


Agency Contact: Jaime Hoyle

Executive Director


Contact Address: Department of Health Professions

9960 Mayland Drive

Suite 300

Richmond, VA 23233
Chapter Affected:
18 vac 115 - 20: Regulations Governing the Practice of Professional Counseling
Statutory Authority: State: Chapter 35 of Title 54.1

Date Petition Received 03/24/2021
Petitioner Dawne Sherman
 Petitioner's Request
To allow all face-to-face client contact hours accrued during the supervised graduate internship in excess of the minimum required 240 direct client hours to be counted towards the 2000 total required direct client contact hours required for residency.
 Agency Plan
The petition will be posted on Townhall and published in the Register of Regulations on April 12, 2021 with comment requested until May 12, 2021. The petition and all comments received will be considered at the first meeting of the Regulatory Committee scheduled after the comment period on August 6, 2021. The Board will receive a recommendation from the Committee and decide whether to initiate rulemaking at its meeting on August 20, 2021. 
Publication Date 04/12/2021  (comment period will also begin on this date)
Comment End Date 05/12/2021
 Agency Decision
Take no action
Agency Response Date 08/23/2021
 Agency Decision Text
The Board considered the petition at its meeting on August 20th and decided it would include amendments to the internship and residency requirements in the adoption of final regulations relating to its periodic review. The amendments will specify the proportional hours that could be counted as face-to-face. However, in practice, those hours are already being applied to a residency. For example, a person who completed 659 hours in an internship with 296 face-to-face hours was credited with 59 hours (the number in excess of required 600 hours) towards the residency and 56 hours (the number in excess of required 240 hours) was credited towards the 2,000 hours of face-to-face client contact. While the regulation does not currently specify how those excess hours are applied, an applicant is currently receiving the credit.