As a retired social work educator and practicing clinician I have clear ideas about the intended goal of the educational experience for persons preparing for human service professions and the goal of supervised practice toward licensure/certification.

As preparation for practice, human service professionals of any discipline successfully complete an academic program, overseen by each professional's certifying organization which is designed to provide students with a background in the history of the discipline, the context and systems in which services are provided, the systems impacting potential clients, their unique qualities, strengths, and challenges along with a theoretical understanding of helping within that discipline. Students focus on learning all aspects of service provision from engagement to intervention to termination utilizing one or more theories. Internship in the academic program challenges the student to integrate the didactic learning with the applied skills required to successfully meet their learning goals. Students work each week toward the development of and improvement in learning objectives toward their goals. Learning in internship, as in any learning environment is uneven. Confidence builds slowly as well. Internship, at its most successful prepares the student to begin to engage consumers under supervision beyond the shadowing or close supervision of internship.  

Internship's goals are educational and developmental. They are not synonymous with practice, even beginning practice. Any blurring of the boundary of education and practice shortchanges not only the student's opportunity to learn but most especially the clients served. For this reason I would not suggest internship hours be credited toward contact hours for licensure or certification. 

I support this petition 

I whole heartedly support this petition

Dr. James 

I support this and believe it to be very reasonable and logical.

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.  

I am in support of this.

Marie Harris, MS, LMHP-R

A small but totally positive step toward modernization of our licensing standards

As a counselor educator who understands the rigorousness and extensiveness of supervision provided to counseling interns as part of their master's degree programs, I support this petition.  As mandated by our accrediting body (CACREP, and previously CORE), counseling interns receive both weekly individual supervision and group supervision, provided by both faculty members and on-site clinical supervisors.  Students in such accredited programs are monitored for professional competencies.  Those who do not demonstrate those competencies engage in remediation/development plans, designed to improve the necessary competencies.  If those remediation/development plans are not successful, the students are not allowed to progress through the internship process, and will be removed from the program.  This gatekeeping function ensures that students who complete an internship and graduate from an accredited program demonstrate the required competencies, and have satisfactorily completed extensively supervised internship experiences.  Those supervised experiences should count toward the supervised experience requirement for the Licensed Professional Counselor credential in Virginia.  

This slight reduction in the number of additional supervised counseling hours would have a very positive benefit for people in the Commonwealth of Virginia, because it would reduce a barrier to providing more qualified counseling practitioners into the workforce at a time when they are desperately needed.  The sooner we can increase the number of appropriately qualified LPCs to address the needs of Virginians, the better.

This slight reduction in the number of additional supervised counseling hours would have a positive benefit on people in Virginia, both counselors and clients alike. The sooner we can increase the number of appropriately qualified LPCs to address the needs of Virginians, the better. Especially in this time of increasing demand.

I support this petition whole heartedly! Please let's ensure this comes to fruition. 

Allowing more of the internship direct hours to count towards licensure has some merit. I would be opposed to counting “all” hours. Internship hours are different from supervised practice hours, and oversight/supervision is of a different quality. I agree with the analysis from Dr. Lawson and support further discussion. I oppose this petition at this point.

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.

Good morning. I would like to post my support for the above petition #341 *. As a LPC supervisor counseling residents this is an important change that should be supported and passed. The recent pandemic crisis highlights the Nations ongoing and urgent demand for more counselors to help those in mental health need. Thank you  

Anne McKay LPC NCC CCMHC - Clinical Supervior 

* Credit for client contact hours during internship in counseling” which states “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.

It is exceedingly difficult for a student to accumulate their needed hours during the pandemic and the addition of intern hours would allow more counselors, to get into the trenches earlier. They would eventually get to their 2,000 hours, but given the mental health crisis, should they be held back?