I’m not sure everyone who commented read the entire petition, so I’m copying it here: “To allow all face-to-face client contact hours accrued during the supervised graduate internship in excess of the minimum required 240 direct client hours to be counted towards the 2000 total required direct client contact hours required for residency.”

The petition states “IN EXCESS” of 240 direct client hours.  That seems entirely reasonable given that the Virginia Board of Counseling decided several years ago to reduce the total number of work hours required for licensure from 4,000 to 3,400 which I expect was to accept the 600 hours of an internship as an acceptable equivalent in a residency. In addition to that, the regulations state “A graduate-level internship in excess of 600 hours…may count for up to an additional 300 hours towards the requirements of a residency” which would reduce the total hours required to only 3,100 hours.

In addition, the regulations state that up to 20 hours of supervision during an internship, if provided by an LPC can count towards the 200 hours of supervision required for licensure.

So, if internship work hours and internship supervision hours are considered acceptable towards licensure, why shouldn’t direct client contact hours also be acceptable?  In fact, why shouldn’t all the hours of client contact in an internship be acceptable?  I believe they should.

I would also like to point out something that everyone may not be aware of: both Boards (social work and counseling) require 60 graduate credits for licensure; however, social workers are only required to have 100 hours of supervision over 3000 hours of total work and 1,380 hours of direct client hours; and lastly, LCSW supervisors are required to only have 14 hours of Clinical Supervision Training, whereas LPC supervisors are required to have 20 hours of training.  Considering the fact that the licensure requirements for social workers are significantly less than for counselors, allowing some of the client contact hours in an internship would still mean counselors have more residency hours in every category than social workers.  So, I disagree with what another commenter suggested, that accepting these hours as “blurring the boundary of education and practice.” I believe it would have only a minor impact on the residency process.

Therefore, I support this petition.