Virginia Regulatory Town Hall
Department of Health Professions
Board of Counseling
Regulations Governing the Practice of Marriage and Family Therapy [18 VAC 115 ‑ 50]
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8/16/12  3:21 pm
Commenter: L. Chris Davies, MS, Resident in MFT and Professional Counseling

Support timely approval

I am writing in support of the petition for the Board of Counseling to count residency hours starting 30 days after submission of supervisor registration.  So much can be said in favor of this petition, and there is not even a compelling reason against it, in my opinion!  This is a "win-win" for all parties involved, not just residents.  It benefits recipients of Marriage and Family Therapy services, organizations recruiting licensed therapists, and the profession in general.  It involves no slackening of the rigor of requirements whatsoever.  This will even benefit the Board itself, because it will not add any workload burden on the Board and will even alleviate pressure on the Board in cases where they need to take longer to respond.  Approving this petition is a step in the right direction and an obvious one.  Frankly, a compelling argument could be made in favor of an even more ambitious petition, and the bar truly could be raised on the part of the Board in several domains.  It is my hope that, in addition to approving this petition, the Board will also endeavor to make other much-needed improvements in actual response times (for all included professions, not just MFT), in the consistency of reviewers' interpretations of academic requirements for licensure, and in the ease with which someone waiting for correspondence from the Board can do a simple status check (such as through electronic query).  It is reasonable to insist on the Board's improvements in these areas, which can be feasibly done through simple improvements in efficiency and consistency in workflow, even by a staff of such limited size. 

I speak as someone who had to wait of two years since my supposed completion of requirements to take the licensure exam due to cumulative delays in the Board's responses to my communications about contested academic requirements before these were finally accepted.  This could have been resolved in a matter of a month or two if responses had been reasonably timely.  The fact that the coursework had to be contested at all also evidences the issues around the subjectivity and inconsistency of the review process. 

CommentID: 23775