Virginia Regulatory Town Hall
Department of Health Professions
Board of Counseling
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]
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4/30/24  1:46 pm
Commenter: LPC, LCPC of 12+ years

Keep the requirements.

2,000 direct hours is an average of 9.6 hours per week over 4 years. Or, an average of 19.23 hours over 2 years. A full time caseload for most independently practicing therapists is typically considered 20 hours per week. So, essentially we are asking residents to work an equivalent of two years' worth of full time direct clinical hours in order to minimally consider them as competent and independently licensed.

I think that's beyond reasonable. Especially in a field where our scope of knowledge is so broad, and more and more we're realizing our clients are multi-faceted and often co-occurring. Depression, anxiety, ADHD, Autism, OCD, psychosis, substance abuse, trauma, eating disorders, peri/postpartum, etc. We should not be rushing through the process. Too often I see clients who have been ineffectively treated in the past due to a lack of general knowledge by previous therapists to simply screen for various conditions and refer out as needed. We're not expected to be experts in everything, but I am not convinced that LESS experience and supervision is appropriate or wouldn't cause harm.

I also think that the current board's requirement for a minimum ratio of 1 hour of supervision per 40 hours of experience is appropriate. Realistically, with holidays and time off, the actual calendar week equivalent is less than 1 hour per week when averaged out, so there is flexibility there (it's just messy to calculate/track). A work week looks different for different providers, whether part-time or otherwise, so I strongly advise against the petitioner's recommendation for a flat 1 hour of supervision per week.

For those referencing the desire for residents to be less financially burdened and be free of their dependence on toxic workplaces, I will say I completely understand from personal experience. However, that is another matter to address independent of the need to ensure competent therapists ready to practice independently upon issue of their medical license.

CommentID: 222574