Virginia Regulatory Town Hall
Department of Health Professions
Board of Counseling
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]


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7/18/22  4:21 pm
Commenter: Elizabeth Engelhorn

Post Test

If an individual has passed their test and is in supervision with a licensed provider who is qualified as a supervisor, I am in agreement with this. However, I believe that they need to have passed their test. 

CommentID: 122734

7/18/22  5:28 pm
Commenter: Ruth Ann Ott

Petition for LPC-R

Wondering what the difference would make? They still would have the same stipulations placed on them, but with a shorter version for signatures. As long as they have passed their counseling board exams and are still being supervised for licensure, I am okay with the change.

CommentID: 122738

7/18/22  9:46 pm
Commenter: Prof. Michael Moates, MA, LP, LCMHC, LBA

Comment Against Petition

Hello and thank you for taking the time to read my comment.

I have grave concerns about doing what the petitioner is asking. I believe that this will cause confusion to consumers and other entities by presuming that someone has a full license to practice.

The term resident in the medical field typically refers to a medical doctor who has reached a point of their career where they are refining their skills but have a full independent licensure to practice medicine.

The Board of Counseling currently has a good way of differentiating between when someone is in training and when someone has full licensure. There is no reason to change it especially in a way that can confuse consumers. Further, I do not agree with the other commenters that there should be a pre and post test title. Someone either has a full license to practice or they are in training. There should be no wiggle room.

The petitioner just graduate this year and it seems like he is trying to jump the gun. There is a requirement before getting the LPC title for a reason. Mr. Kaste is charging $185-230 well above the average for a therapist in training and the concern by me is that this would seek to add legitimacy (implying full credential) to a not yet fully licensed practitioner. See

Further under the authorizing statute § 54.1-3500. Definitions. it says that ""Professional counselor" means a person trained in the application of principles, standards, and methods of the counseling profession, including counseling interventions designed to facilitate an individual's achievement of human development goals and remediating mental, emotional, or behavioral disorders and associated distresses that interfere with mental health and development." You are not fully trained until you complete the educational, experiential, and examination requirements. Thus, it is my belief that this would not be in line with what the legislature intended.

Thank you.

Prof. Michael Moates, MA, LP, LBA, LCMHC

CommentID: 122753

7/19/22  8:50 am
Commenter: Charlotte Markva, LPC, LMFT, CSAC, NCC

Potential for Public Confusion

I am concerned that if you use the title LPC-resident, you are sending the message to consumers of experience and qualifications met that are not the case.  The current regulations are clear as to the experience level of the therapist.  Already I perceive that consumers project onto residents having more experience that what many of them actually have.  I don't think labels should be changed that could further confuse the general public.

CommentID: 122761

7/19/22  9:21 am
Commenter: Cinda Caiella, LMFT

Against this unnecessary petition

The proposed change is unnecessary and would be a source of confusion. The title is a recognition of achieving full status as an LPC, with education, training, time under supervision, that is clearly defined and outlined in the relevant statutes. What would be gained, apart from a personal conceit? Counselors and the Board of Counseling have worked diligently to promote and defend this License and protect the public.


CommentID: 122762

7/19/22  10:09 am
Commenter: Cynthia Miller, Ph.D., LPC

Purpose needs clarification

This petition, while perhaps well-intentioned, blurs the distinction between what it means to be a resident and what it means to be licensed.  The title "Licensed Professional Counselor" is protected by law and is indicative of a counselor who has a credential to practice independently.  A resident is someone who has permission to practice, but only under the supervision of a Licensed Professional Counselor.  In other words, the resident is not permitted to practice independently.  Creating a designation of "Licensed Professional Counselor - Resident" blurs the very important distinction between who can practice unsupervised and who cannot.  The general public is unlikely to understand how an LPC differs from an LPC-R and that is a problem.  Potential clients should clearly understand whether their counselor is independently licensed or not.  

It does seem possible that a driving force behind this petition is the desire to bill insurance.  Private insurance companies generally do not reimburse services provided by counselors who are not licensed.  This is a problem and definitely creates additional barriers to treatment for people.  If the end result of creating a designation like LPC-R is to open the path to insurance reimbursement I could get behind this, but it should come with clear requirements that anyone with an LPC-R designation must explain their residency status to every client.

CommentID: 122766

7/19/22  11:12 am
Commenter: Joan Normandy-Dolberg, MA, MEd, LPC, Director, Family Counseling Springfiel

Against the change

This change is unnecessary and may (purposely?) mislead or confuse the public. 

CommentID: 122770

7/20/22  9:47 pm
Commenter: Heather Honaker, LPC

Against the petition

Strongly against this petition due to the possibility of public confusion. 

CommentID: 122831

7/21/22  9:53 am
Commenter: Holly Tracy LPC, LMFT, ACS, CTTS, RPT-S, CT, NCC

Strongly Against

The Board's mission is to protect the public. Part of that includes full awareness and transparency of a clinician's credentials. I believe LPC-R will further confuse the public and lead to a misunderstanding about credentials. Having spoken with clients and seeing how some Residents advertise, it is clear that clients are already confused. Let's not add to the potential for further misdirection.

CommentID: 122841

7/21/22  3:41 pm
Commenter: Anonymous

For the Title Change

I’m for the change in title. The scope of practice, responsibilities and ethical mandates per VA Board of Counseling, and ACA, do not change. Simply the title changes. The current resident handbook still mandates that residents post their provisional license in a conspicuous location, inform clients that they can not practice independently or directly bill for services. Residents in Counseling would still have to complete the NMHCE, 3,500 hours of experience and be under the supervision of an independently licensed, board approved supervisor during that time frame.

I do understand the concerns of confusing the general public on the change. However, it does not change the board regulations on scope of practice for residents. Plus, I would argue that the general population finds the current title confusing already. As residents, it is their (and their supervisor’s) ethical responsibility to provide psychoeducation on the limits of practice and trainee status in all of their public facing materials and all written communication.

Currently, in the state, a Certified Substance Abuse Counselor (CSAC) is a regulated bachelor’s degree level profession. How does this title differ in terms of public confusion? How does this title resonate with the public’s understanding? Of course, the CSAC is needed due to the substance use crisis, but let us look at the full picture in the state. Especially with the Counseling Compact gaining national traction. Clients want uniformity. Client’s want clarity. This can be a step in that direction. If you are concerned, consider the following ACA Ethical Codes:

C.4.a. Accurate Representation

F.1.c. Informed Consent and Client Rights

F.5.c. Professional Disclosure

CommentID: 122853

7/22/22  4:15 pm
Commenter: Anonymous


I am in agreement to allow Residence to sign their name as LPC-R. As someone who is in the hospital often seeing clients the term "Resident" sounds as if someone is in the medical field. It is very confusing for clients and I have had countless clients express this confusion. A Resident has been through a lengthy educational process, has obtained months of internship, and deserve the respect to have a title that all understand. Most of these Residence have been in the field for years. The title of "Resident" causes clients to assume that someone is uneducated in counseling. Many of the clients I see think that a Resident is either in a medical residency or is an undergrad student who have not yet obtained a BS or BA degree.  

CommentID: 122872

7/22/22  6:43 pm
Commenter: Prof. Michael Moates, MA, LP, LCMHC, LBA, LMHP


I have concerns that all of those that are in favor are anonymous. I would ask the board to compare the IP addresses and behavior of those who are commenting.

CommentID: 122873

7/22/22  11:01 pm
Commenter: Anonymous

For the Change

I believe that the credentials should read LPC-R. The R will be enough to show that the clinician is not fully licensed yet and is still in residency. 

CommentID: 122874

7/23/22  7:46 pm
Commenter: William

Wrong Answer for a Needed Change

I understand the desire for a change in designation for Counselors who are working on becoming licensed. I am graduating with my Master's in Counseling in a few weeks, so I am certainly invested in this issue.

I am inclined not to share some of the more extreme concerns here that this change is possibly intentionally designed to mislead the public, or that it would lead to mass confusion - at least not any more mass confusion than our current system. This leads to my next point.

I do agree that the terminology should change. The term "Resident" in general is confusing, and not used by other mental health professions aside from Psychiatry, which of course is medical doctors. We are confusing some members of the public into thinking our background is more like that of a medical doctor than a therapist. Again, an unintentional issue I am sure, but I think we do need a new term. I do not like this term because I agree with concerns from others that it is easy to think that LPC-R means fully licensed. Perhaps we could simply come up with another term. Perhaps Supervisee in Professional Counseling (SPC or S-PC), Professional Counseling Supervisee, Professional Counselor in Training, or Pre-licensed Professional Counselor (Pre-LPC). I believe these terms are more clear. I do appreciate the idea of a shorter abbreviation.

CommentID: 122881

7/24/22  2:52 pm
Commenter: Meredith Adams, MS, NCC

In Favor

As someone who currently serves as a Resident in Counseling, I am in favor of this motion. This motion does not change the scope of work that Residents in Counseling do nor does it change the supervision requirements, it simply allows Residents in Counseling to better market themselves to clients seeking care in a more transparent way to differentiate between LPCs and LPC-Rs. Residency is a rigorous process of growth and learning that differentiates itself from that of being a student which is worthy of further acknowledgement. 

CommentID: 122897

7/24/22  7:44 pm
Commenter: Anonymous

Strongly in Favor

I am strongly in favor of this motion and hope that the Board supports the petition. 

CommentID: 122905

7/24/22  9:28 pm
Commenter: J. A. Elliott, LPC

Strongly Against

I have serious concerns about this proposed change. I strongly believe that this will cause confusion to the general public and others by presuming that someone has a full license to practice. This confusion stems from the word Licensed being in the proposed title—which is misleading and could potentially break ethical codes to do no harm.


The Board of Counseling has a good way of differentiating between when someone is licensed and when someone is in their residency. There is not a good reason to change this distinction, especially in the way that the petitioner is asking. This proposed change can put people at risk of being exposed to harm due to the wording and the potential for misrepresentation by residents to clients. Further, this proposed change is confusing and potentially harmful to clients and the general public as well as the legitimacy of the profession and other entities/professions.


I agree with the concerns regarding the petitioner’s motivations brought up by Prof. Michael Moates, MA, LP, LCMHC, LBA. He stated, “The petitioner just graduate this year and it seems like he is trying to jump the gun. There is a requirement before getting the LPC title for a reason. Mr. Kaste is charging $185-230 well above the average for a therapist in training and the concern by me is that this would seek to add legitimacy (implying full credential) to a not yet fully licensed practitioner. See” Upon reviewing the provided link,, I second these concerns which further reinforces my aforementioned concern for the large potential for harm to clients and the misrepresentation of resident status by residents to clients.


Overall, I am strongly against this change and the potential harm it may cause to the profession, the field of mental health, and, most importantly, the general public—who are our potential clients/consumers.

CommentID: 122907

7/26/22  11:09 am
Commenter: Fran Schaller LPC, CSAC

Petition to allow residents in counseling to use the title "LPC - Resident"

I disagree with this proposed change.  It will lead to confusion in an already confusing system.

CommentID: 124032

7/29/22  1:41 pm
Commenter: Arlene Malone

Strongly Against

To not repeat the sentiments of my colleagues who have argued against the approval of this petition, I am strongly against this petition and echo the concerns previously stated by my colleagues.  It is already confusing for consumers, and approving a title of LPC-R will only add to that confusion, primarily because the word "licensed" is included in the title, which would be an incorrect and misleading characterization of the credential of a resident in counseling.  I agree that another title would be clearer, such as Counselor-in-Training or Pre-Licensed Counselor, but that is not the petition at this point.  LPC-R is not the answer.

CommentID: 124166

8/6/22  2:05 pm
Commenter: K

Must be licensed

If you aren’t officially trained and certified by State or university, then Licensed should not be used. 

CommentID: 127140

8/11/22  7:52 am
Commenter: ASHA GRAY LPC

In favor

I would be in favor of this switch. It's a reasonable simile of what is used now. It is also in line with what other states nearby use. Like DC's LGPC. It also makes it clear to clients what licensure this probationary licenced clinician is working towards. 

CommentID: 127190

8/11/22  10:01 am
Commenter: Anonymous

Response to ASHA GRAY LPC

ASHA GRAY LPC, your statement is false. Other states do not give the title LPC and add resident at the end. They have titles like associate counselor but that is not the same as being LPC - Resident. If the board elects to indulge this petition, I would request that the word "resident" must be spelt out. So it would be "LPC-Resident" rather than "LPC-R." I would also request that the resident be required to get a signed consent form explaining the details of their title and supervision requirements.

CommentID: 127191

8/16/22  5:27 pm
Commenter: Ethan Kaste, Resident in Counseling

Original Petition

I would like to propose that we allow Resident in Counseling professionals to use the title Licensed Professional Counselor - Resident (LPC-R), Licensed Resident Professional Counselor (LRPC), or another similar form for a few reasons:

  1. Provides consistency and accuracy of terms in Virginia’s regulations  

The Virginia Board of Counseling defines “Resident” to mean, “An individual who has a supervisory contract and has been issued a temporary license by the board to provide clinical services in professional counseling [emphasis added] under supervision” (18VAC115-20-10.B). This regulation implies that residents are licensed individuals that are able to provide professional clinical services, affirming that the resident has the capacity to provide services in a professional capacity. However, 18VAC115-20-52.B.10 states that “Residents may not [emphasis added] call themselves professional counselors, directly bill for services rendered, or in any way represent themselves as independent, autonomous practitioners or professional counselors”. The former regulation suggests that residents provide professional services but the latter seems to deny that. Further clarification on the definition of “professional counseling” may be needed, but instead of rewriting or redacting those regulations, the use of the title Licensed Professional Counselor - Resident (LPC-R) or Licensed Resident Professional Counselor (LRPC) be the designated title since it more accurately represents Residents in that they are supervised licensed individuals who provide professional services.

  1. Uniformity in supervised licensure titles among other states.

Many states in the counseling profession are utilizing the terms “professional” and “licensed” for those who are graduated supervised individuals working towards. Alabama, California, Colorado, DC, Maryland, Georgia, and Hawaii are just some states that utilize various titles such as Associate Licensed Counselor (ALC), Licensed Associate Counselor (LAC), Licensed Associate Professional Counselor (LAPC), Licensed Graduate Professional Counselor (LGPC), Limited Licensed Professional Counselor (LLPC), Licensed Graduate Professional Counselor (LGPC), Provisional Licensed Professional Counselor (PLPC), and Licensed Professional Counselor Associate (LPCA).

  1. Ease of use

I personally do not consider it necessary to change the name, I just simply think it makes more sense to utilize Licensed Professional Counselor - Resident (LPC-R) or Licensed Resident Professional Counselor (LRPC) for the aforementioned points. Lastly, and perhaps the least important point in this petition is the abbreviated use of a resident title such as LPC-R or LRPC is more simple to use than “Resident in Counseling”.


I want to thank everyone for their comments, I was looking forward to learning and hearing everyone’s different opinions! It is my first time operating in a regulatory capacity (however small it may be) so I was somewhat excited and honored to be a part of it. I am still a Resident in Counseling myself so I understood that there were going to be some perspectives that I had not considered. I also wished I had seen these comments earlier, I noticed that much of my reasoning for the petition was left out. So I would have posted this comment earlier in order to further clarify my reasons for suggesting the petition. I apologize for that.

CommentID: 127275