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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5/1/24  12:12 pm
Commenter: Sharon Watson, LPC, LMFT, LSATP, NCC, ACS

Strongly support with a caveat

There are several reasons why I support this petition with one caveat: change the “weekly” requirement for supervision to 100 hours which can still be a combination of individual and group supervision and change . 


I have supervised many supervisees/residents since 1995 in the public system in various roles, in private practice as employees, and those in their own private practices.  As I continue to do so, my recommendation is:

  • 3000 hours total work
  • 1500 hours face-to-face/direct work
  • 100 hours of supervision with a minimum of 1 hour per 40 hours of work
  • Supervision provided only by a trained LPC supervisor


#1. LCSWs in Virginia are only required to have 100 hours of supervision, 3000 hours of work experience with 1,380 hours of face-to-face supervised work experience. If the Virginia Department of Health Professions feels that’s adequate for social workers, they should be adequate for professional counselors. It would be interesting to find out why the requirements were made so much more rigorous for counselors in the first place.  Was it because, as the first state in the U.S. to license counselors they wanted to be sure they could support the requirements for licensure?  Or could it have been that at the time there were no specified graduate programs (like CACREP) that would make the training consistent over the various graduate programs and they wanted to be sure counselors were adequately trained?  In any case, that is no longer an issue.  For that reason, the current imbalance of requirements between LCSWs and LPCs is extremely unfair because it: a.) burdens LPCs with the additional extreme financial expense of paying for twice as much supervision and b.) with the higher total work time requirement it postpones the resident’s licensure and ability to take insurance (if wanted) in order to earn a livable wage? 


#2. Understandably there are some who may suggest that we, as LPCs, want to have a higher standard for counselors than social workers.  However, in the real world, is the public (our clients) making the choice of social worker vs counselor for therapy because of the licensure requirements?  It’s unlikely that the public has any idea about the difference. The way to maintain a high standard and consistency in our field is for LPC supervision to be provided only by LPC supervisors and not LMFTs who have different educational requirements or LCSWs (as was suggested in a recent petition to be an option again), who have even a greater difference in educational requirements and educational focus.   


#3. As was outlined in a previous comment, many states require much less than 200 hours of supervision for LPCs with most only requiring 100 hours. The fact that the Counseling Compact (which includes Virginia) will allow only LPCs (not LMFTs) to request and be granted a privilege to practice in another Compact state, it’s important for us to maintain the integrity of professional counselor licensure.  This is another reason to eliminate LMFTs as LPC supervisors.  So, changing Virginia’s licensure requirements to be more in line with many other states would be a timely and welcome change.


Lastly, the reason supervision should not be based on a weekly schedule is because some residents work part-time or very limited hours.  It would be unreasonable to expect, for instance, someone working 10 hours per week to be required to have the same one hour of supervision as someone working 40 hours per week. Some residents who have difficulty finding clients, especially when starting their practice, shouldn’t have to pay for the same amount of supervision as a resident who has a full caseload and works full time.

CommentID: 222582