The VACSB would like to respond to the petitions regarding 18VAC115-20-52.c.3 regarding the petition to change the Qualifications of Supervisors for the Board of Counseling.
At a future time in the course of Virginia’s licensed workforce, this may be an idea to consider. For now, the VACSB would oppose this change suggested for the following reasons:
·There are not enough LPCs now in all portions of Virginia who are qualified to act in the supervisor’s role and such a change will serve to exacerbate this very real problem.
·DHP already has sizeable back-logs in processing applications for residency for both professional counselors and licensed clinical social workers. Until this back-log is more fully addressed, there should be a moratorium on changes. It is extremely difficult for applicants to keep track of changes and make adjustments in their applications with what is in place now. Additional changes will once again intensify the issue and create more turmoil in the field.
·Health care reform is going to increase the problem and require even more licensed professionals. While Virginia wants to assure that licensed professionals have the necessary qualifications and experience, changes that will not serve the Commonwealth at this time should be forgone.
·Should any change be considered, it is our hope that the Boards and DHP will choose to work on the very important issues regarding educational credentials and explore ways to better define and refine that process so that students enrolling in accredited universities can be more assured of their degrees meeting the requirements for licensure.
Thank you for the opportunity to respond and please feel free to contact me with questions regarding this petition.
