I have mixed feelings on this petition. I am concerned that it blurs the lines between graduate training and the Temporary Licensure (Residency) period. That temporary license period is incredibly important to assess a counselor’s ability to practice independently. That cannot be confused with internship hours, which serve a similar but different purpose of assessing the minimum competencies for beginning supervised practice. However, the Residency requirements that address the additional hours which may be brought in from CACREP accredited programs could use some additional clarity (18VAC115-20-52.B.6).

Virginia requires 3400 hours of supervised experience to be completed during the residency, and 2000 of those hours must be face-to-face with clients. This roughly maintains the typical 40% “Direct Services” standard that is required of CACREP accredited programs (2000 hours represents 58.8% of the total 3,400). The merit I see in the petition is to clarify the regs to allow that the additional 300 hours which can be earned within a CACREP accredited program, may bring in up to 120 Direct hours within those 300 hours (again 40%) applied toward the residency.

Anything more than that becomes exceedingly problematic. 3,400 hours represents 85 weeks of full-time work. That means that a supervisor has a total of seven quarterly reports to complete within the residency period to assess whether a resident is sufficiently skilled to become an independent practitioner, and fully licensed counselor.  The additional 300 allowed within CACREP programs means we are down to six quarterly evals, to assess a great deal of knowledge, skills, and abilities, most notably the ability to uphold the legal and ethical requirements for client care.

Because the petition suggests lifting the ratio entirely, with no upper limit, the ability of supervisors to adequately assess counselors skills would be impaired, and I cannot support that. If, however, the Board wanted to use this opportunity to clarify the requirements of 18VAC115-20-52.B.6 to allow 120 of those hours to count as direct hours, I believe that clarity would be beneficial.