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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5/8/24  1:35 pm
Commenter: Sharon Watson, LPC, LMFT, LSATP, NCC, ACS

Strongly support with a caveat - Additional comments

I would like to add to my initial comment submitted 5/1/24 after reading subsequent comments in order to correct some misinformation and address some of the commentors’ concerns.


I would like to correct my initial sentence from 5/1/24 to read:

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. 


  1. LPCs are now able to take Medicare clients if they so choose.
  2. LPCs have been able to take Tricare for several years.
  3. “Reducing requirements will result in deaths” seems a catastrophizing conclusion. With that logic are we to assume that LCSWs, because they’re only required to have 100 hours of supervision, have more client deaths than if they were required to have 200 hours of supervision?
  4. Re the concern there are more case decisions against LPCs than LCSWs.  It’s possible this is a skewed assessment.  First of all, some of the case decisions during that period are for QMHPs not LPCs. Second, some case decisions were not for client care, but were fines for failing to meet the CE requirement (still not acceptable, of course). Third, is it that almost all LPCs are practicing as therapists/counselors whereas it’s possible that many LCSWs are working in social services and not doing counseling and therefore less likely to have a complaint against them?  Regardless of these possibilities, it’s problematic to assume there are many more complaints in counseling than social work without researching the issue.
  5. For the individual who wrote “one hour of supervision per 40 of work time seems fair” and then did not support the petition is incorrectly calculating the requirement.  The current requirement is 3,400 hours of total work.  If that is divided by 40 hours of total work with one hour of supervision per 40 it would mean the resident would only have 85 hours of supervision when the current requirement is 200.  So why not support the petition requiring 100 hours of supervision?  Its likely many people don’t know the history of the requirements and subsequent changes.  When the regulations for licensure were set up in Virginia, the 200 hours of supervision were initially based on a supervisee working full time (40 hours) over the course of 2 years (104 weeks minus likely 4 weeks of vacation) totaling 4000 hours (40 x 100 = 4000).  Those 4000 hours were then reduced to 3,400 when the regulations were changed to include the 600 hours of internship in graduate school. So, to reach the 200 hours of supervision now required, a resident has to receive 2 hours of supervision per week.  Therefore, reducing the hours to 100 is actually what the petitioner is suggesting.
  6. For the individual who wrote reducing supervision hours would result in “subpar” LPCs, would that mean that LCSWs, who only have 100 hours of supervision, are SUBPAR?
  7. For the individual who said “I have seen a huge lack of respect for LPCs, especially from the field of social work”, I agree that I have sometimes experienced the same. Isn’t it possible, though, that the lack of respect may be due to social workers being first in the field as counselors (because LPCs didn’t exist at the time) and that LPC licensure coming onto the landscape was possibly threatening to their livelihoods, their professional philosophies, or because LPCs were using different theories or practices due to the differences in graduate programming/educational requirements and not because of our licensure/residency requirements? In any case, I suggest we don’t allow the perception that some social workers may not respect LPCs to define who we are as LPCs and cloud our decisions on what licensure requirements we should support for ourselves.   
  8. For “Do No Harm” who said lowering the standards is “outrageous” and “needs to be denied for the safety of our clients”: are you saying that LCSWs who only have 100 hours of supervision are affecting the safety of clients?  Have you put in a petition to the Board of Social Work to increase the required 100 hours of supervision for LCSWs to 200 hours so their current low requirements won’t be “outrageous”?
  9. For “Lowering hours lowers opportunities for multi-state licenses,” relating that to the Counseling Compact needs to be clarified. Every state that passes the Compact legislation has agreed to accept the standards (the number of supervision hours, total work hours, and F2F hours) that are required for LPC licensure in every other Compact state whether the requirements are higher or lower than their own.  Also, importantly, it will not require applying for licensure (and meeting individual state requirements) which is the purpose of the Compact.  It will entail requesting a “privilege to practice” in another Compact state regardless of what requirements you’ve met in your own home state.  What you’ve suggested that may be true, is that it may make it easier to be grandfathered into another state’s licensure if you move to a non-Compact state.
  10. For “LPC for 25 years” so, because the requirements were hard for you, you want to make sure that others suffer like you did?  I was licensed and in the field 30 years ago.  I had 400 hours of supervision: 300 for LPC (because at the time group was counted for half, i.e. I had 200 hours of group and 100 hours of individual) and then I had an additional 100 hours of supervision for my CSAC.  Despite that, I’m still supporting this petition with my caveat (100 hours of supervision and not weekly) because as one writer noted “we have evolved” in that our graduate programs are better, supervisors are required to have 20 hours of supervision training, and I believe our field is better monitored now than it was in the past.
  11. The idea of “weekly” supervision does not meet the needs of some residents who have very small practices due to various reasons.  I’ve had residents that had to have supervision over the course of 5 years due to having only a few clients because of personal circumstances (with granted extensions) because they needed to reach 200 hours. When put in that perspective 200 hours of supervision seems excessive.


“Very Concerned Client” – Is not addressing the petition.  But to clarify, based on my training in the public sector, any diagnoses, charting, and progress noting CANNOT be changed because they are part of the permanent record and are date stamped.  If they were changeable, a clinician that actually did something inappropriate would be able to go back and modify the record to make it appear they did nothing wrong.  So, those who are declining to change the record are doing so because of the fact that the record cannot be changed.  A client is allowed however, to write anything about how and why they dispute the accuracy of the record and ask for what they write to be added to the record.

CommentID: 222622