I support this petition for LMFT, as well would like for it to be considered for LPC and LCSW applications. While the laws require for professional counseling services to be provided by those that are licensed or registered for licensure supervision, many, if not most positions where supervisees are able to provide clinical counseling services towards licensure do not have job responsibilities where they cannot be doing any clinical responsibilities during the time period where licensure supervision has been applied for but in the pending process.
Given the current arrangements of the Board for limited reviews during the months, with stated waitlists due to increased volume that they have acknowledged and limited staff available, in addition to increased review of detail and lack of clarity for new applicants on what specific details the Board is seeking in their reviews of job descriptions or whether educational programs will have been approved or not, people are hired or placed in job positions where clients are in need of counseling services, however, the staff may either provide the clinical services without the registered supervision in the meantime, and not receive credit for the hours once later approved, or are providing sub-par clinical services in order to not be accused of “counseling” without having the registered approval from the Board during the time period while pending and since it will not be back-dated when later approved.
I understand the concern of the Board, that they do not want to set a standard of expectation for backdating, in that it then gives counselors and employers the ability to say staff are providing counseling services, when there is a risk that the Board in their review process may find the applicant is not able to meet the requirements for approval, such as the degree program not meeting DHP requirements even if the job description does, or that counselors may lose more money getting started with a supervisor to later find out they are not approved for a similar reason, rather than having waited.
Perhaps the Board could allow a new designation for applicants who have submitted an application for residency supervision but the application is still in the review process, such as “Resident in MFT – pending” (and preferably similarly for LPC and LCSW as well), as a way of demonstrating to clients the current status of the individual, but allowing individuals who have a supervisor believing they will be approved to provide the clinical counseling services that clients in their position need, and document them as such, as well as to have the supervision they are receiving in the meantime backdated, such as to 30 days from application date. For those who are determined by the Board to not meet criteria, then they would have lost their money with risking supervision approval in advance, and the “Resident in MFT – pending” status and counseling duties would need to end at notification, but those approved would be able to continue to have their clients receiving actual counseling services rather than the lower level needing to have waited the full DHP approval process until that time.
Practically, many employers and individuals do not have a luxury of waiting 3-9 months to start a particular job duty that is needed for the approval process. Employers that do provide multiple levels of service to clients and can offer client services but wait until approval for the staff to provide the “counseling” services is leaving the client with a lower level or incorrectly labeled service in the meantime, while the client is likely referred to that particular service/provider due to other options being less appropriate for them at that time.
Allowing a “Resident in MFT – pending status” (as well as for other DHP professions) while the application is pending, with backdating the approval to a date such as 30 days (a more reasonable wait period for an individual in counseling services position to be able to begin counseling with clients) could assist with addressing the concerns of supervisees, provider services, and clients.
(submitted second time since notes not retained on 1st comment attempt)
