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  9:44 pm
Commenter: Anonymous


The petitioner requests that the Board of Counseling amend 18VAC115-20-52 to:

1.    Reduce the total required residence hours from 3,400 to 3,000;

2.    Reduce residency client contact hours from 2,000 to 1,500; and

3.    Change supervision requirements from a minimum of 200 hours to a requirement for weekly supervision with no minimum.

I am open to keeping the residency hours the same or reducing the hours from 3400 to 3000 post graduate hours as long as minimum clinical hours are required during the internship.

I do not concur with reducing the client contact hours or the minimum supervision hours. 

If someone is working 35 to 40 hours in a clinical setting then their work should be primarily working with clients (performing screening, intake, orientation, counseling etc) and obtaining hours should not be attainable in a 2 year period.

My concern as a clinical supervisor is that many recent residents show little proficiency in basic counseling skills, diagnosing, understanding theory or the application of theory. Much of the growth and skills are developed with hands on experience and quality supervision.

My suggestions would be to include a mini-exam or case conceptualization once a year to demonstrate what they learn on the job and how they apply their skills. 

Other issues to be addressed may include school programs not adequately preparing individuals with foundational skills, supervisors are having to spend more time teaching basic concepts or are too busy to provide quality supervision. Finally, a large percentage of residents are in positions/roles that are not primarily clinical. The hands on experience is a must.

I think there has to be larger conversation around if and how to revise the requirements while ensuring that quality  is being maintained.






CommentID: 222631