I worry that this change will actually end up making it much harder for individuals in need of supervision for licensure to find an appropriate supervisor.  LPCs providing supervision for licensure are not easily found in some areas of the state.  In addition, residents often get their supervision provided as part of their employment.  If they are employed in an agency that does not have an LPC available to supervise them then the resident will have to incur significant cost in order to obtain supervision acceptable to the Board.  Furthermore, a resident may be employed in an agency where they receive individual supervision from an LPC but group supervision is led by an LCSW or clinical psychologist.  That resident would then be unable to count any of the group supervision hours which hardly seems fair.  Residents cannot control who is available to provide supervision at their place of employment and, if they are expected to get all of their supervision from an LPC, it could add unnecessary restrictions to their job search.  I also worry that this rule will make it harder for students to apply some of their internship hours towards the counseling residency.  Students are currently able to apply 600-900 hours of their internship towards their residency.  Many students complete internships at agencies where their primary supervisor is an LCSW or LCP.  Would these students be unable to have their internship hours accepted under this rule?  If so, then training programs are going to be very hampered in their ability to place students in appropriate internship sites in the future.

It is my understanding that the Board is worried that a resident's supervisor may not have any accountability to the Board if the supervisor is not licensed under the Board of Counseling.  I assume, however, that the supervisor would still have accountability to the board under which he/she is licensed and appropriate complaints could be filed with the appropriate board.  The regulation has allowed for no more than 50% of the supervision to be given by an allied professional for many years and it does not seem the board has encountered many problems under this arrangement.

Although I am supportive of efforts to strengthen professional identity, I also believe there is much to be gained from cross-disciplinary training and interaction.  Residents can have tremendous learning experiences with a supervisor from social work, clinical psychology, counseling psychology, or psychiatry.  They gain different perspectives, learn how professionals in different guilds think, and are exposed to new ideas.  I realize that the boards of social work and psychology do not recognize supervision provided by an LPC but I don't buy the argument that counseling should follow suit and refuse to recognize supervision from allied professionals.  I see more potential harm coming from this regulation than potential good.