The Board’s mission to protect the public through rigorous assessment of applicants for residency and licensure is, in my direct experience, met with the strongest support of applicants, supervisors and providers. Consistent with this mission, the training of Marriage and Family Therapists focuses on the best interests of the mental health consumer, with attention to the highest standards of evaluation in that endeavor. As an active member of the VAMFT board, an approved and active supervisor, and a former educator in Virginia Tech’s MFT program, I strongly support a focus on rigorous education and training standards.

This petition serves to address the backlog of applications due to procedural changes in 2010, which have had a direct effect on the services available to citizens of the Commonwealth. The petition would ensure both mental health consumers and applicants of a win/win: a rigorous assessment period at no cost in professionalism to serving the greater public good; and low cost to the applicant, knowing that, once the approval process is complete, they will be able to retroactively count most of their working hours and supervision expenditures toward licensure.

The most significant factor driving this petition is to correct the delays caused by the backlog initiated in 2010. I am hopeful that this petition will apply retroactively to those many applicants who continue to be affected; these applicants who were told, after months of work and supervision, that the same job they have held for many months as they await final approval, will only count “once their application is complete.” Often they are already employed, their job descriptions do not change and they are graduates of a COAMFTE-approved program. In other words, as they wait for the approval backlog to clear, they are doing the jobs for which they are merely awaiting acknowledgement. They are gaining knowledge and experience that should fully be counted, assuming it is deemed to be an appropriate workplace setting with qualified supervision.

With due respect and appreciation to the hard work of volunteer reviewers, over time there have been numerous reports of applicants who have experienced inconsistency in assessment of credentials. This has resulted in applicants who have worked in good faith and believe they are “registered” but told years later that their credentials were, after all, insufficient. This reversal represents years of work hours and applicants’ personal resources wasted, and financial resources burned with no progress toward licensure. This petition would address the delays for these applicants, as well.

Definitions of “registration of supervision” and “completed application” have been vague in the regulations, rife with misunderstanding and misinterpretation. Is registration mailing in all the required paperwork? Many interpret it that way. Is an application complete when everything is sent in? Many understand this to be the case. And yet, for example, detailed explanations regarding workplace are requested and provided, several times in some cases; though the applicant has complied with answering questions, they discover their application is considered “incomplete.” Questions to the Board staff often go unanswered or receive insufficient responses, so that applicants move forward in the dark, with the hope that what they are doing will be approved, but with no assurances. These factors, combined with the 2010 backlog, have resulted in months of delays for applicants; these delays would be mitigated by this petition.

Going forward, the Board and DHP leadership have spoken to an interest in addressing these concerns. They have heard suggestions and received work product that can significantly decrease the processing time for applications, done in a spirit of good faith and collaboration. This petition acknowledges, though, continued delays that resulted from 2010. Further, it provides a safeguard both to the public and the residency applicants that mental health trainees will be appropriately educated and supervised, and that applicants’ work is moving them with timely progress toward their ultimate destination of licensure. Delays may be unavoidable in endeavors where public protection is paramount; however, this petition will ensure that applicants do not continue to literally and metaphorically pay the price of delays. It should be approved and applied to both current and future applicants.