I am opposed to this proposed change for a number of reasons.

First, I feel this proposed change would cause undue burden on the vast majority of individuals attempting to find the placements that will allow them to gain the supervision hours required to get licensed in VA. Many individuals in this situation find themselves having to pay up to $100 an hour out of pocket to fulfill the requirement as it stands now. With the current standard, qualified individuals from closely related disciplines can provide up to half of the necessary hours, which allows those seeking LPC licensure strong interdisciplinary background yet still more than suficient exposure with an LPC. In many agenices, people with social work backgrounds are much more prevalent, and therefore are often the ones available to provide supervision, generally on par with supervisors of any other discipline.

If the goal of this proposed change is to ensure that LPC's are trained sufficiently, then I strongly feel that the current setup works best and provides a multi-dimensional bastion from which LPC's can enter the diverse health-care marketplace. Further, it seems that LPC's do not dominate the mental health marketplace and this change would place undue burden on residents and be counterproductive to long-term growth in the field.

Another major issue is that review and approval of paperwork related to approving supervisors is seriously compromised. Oftentimes, turnaround time is a minimum of three months (even though processing of fees occurs immediately), further delaying the accumulation of hours.

In summary, this proposed change seesm to place more burden on trainees in residency, seems short-sighted and not likely to produce significant gains in the quality of LPC training, and it promulgates continued administrative woes... all factors combined, perhaps driving quality individuals to other health-care fields.