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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4/9/24  8:16 am
Commenter: Anonymous

LPC Residency and Supervision Hours Amendment

I am in support of these changes. I feel it will help those individuals transferring from other states whom are not independently licensed as an LPC since every state board has different requirements to obtain licensure. Being we are a military heavy community, I feel this could also benefit military spouses whom may be currently working in the field and pursuing licensure as LPC or are looking into beginning a career as a helping professional since the length of their spouse’s tour is limited.





CommentID: 222501

4/10/24  6:53 am
Commenter: Anonymous

Please review these proposed changes

According to a qualitative study called “United We Stand: Narrative Study to Aid the Counseling

Profession in Developing a Coherent Identity”, "In the area of supervised experience, a majority 62% (n=2) of the states require 3000 total hours of post-master’s supervised counseling experience (ACA, 2016). Ten other states come close ranging from 2400 to 3600 hours, and five states require 4000 total hours. A majority of states, 62% (n=31) require 100 hours of supervision. Six percent (n=3) require 180-200, 8% (n=4) require 120-150, another 8% (n=4) require between 50-80, and 17% (n=9) do not specify a number of hours of supervision” (Bohecker and Eissenstat, 2018).

With the upcoming counseling compact, why does Virginia continue to be in the minority for supervision requirements?  Licensure portability is changing for the good.  Can we also address the vast differences in supervision requirements alongside these changes?  If 62% of the U.S. finds 3000 total hours of supervision sufficient, what's happening in Virginia which requires 4,000 total hours with the graduate level internship The state of Virginia projects a shortage of licensed mental health providers. However, many professionals cannot stay in the field and continue their licensure process due to the constraints of low pay, work conditions, and supervision costs. Therefore, setting new residents on a sustainable path to licensure is difficult. Lastly, MSW supervisees often work alongside LPC residents yet are required a minimum of 3,000 hours of supervised post-masters degree experience in the delivery of “clinical social work services” and “ancillary services” meet with your supervisor for 1-4 hours per week for a total of 100 hours of individual face-to-face supervision Meet with clients face-to-face a minimum of 1,380 hours while providing clinical social work services.” (Virginia Department of Health Professions Board of Social Work, 2023). MSW's have a much broader scope yet less requirements. It's time to review, adjust and bridge the gap. I agree with this petition and the need for revision.

References: Eissenstat, S. J. and Bohecker, Lynn, "United We Stand: Narrative Study to Aid the Counseling Profession in Developing a Coherent Identity" (2018). Psychology E ducat or Scholarship. 24.

CommentID: 222504

4/11/24  1:01 pm
Commenter: Jessica Johnson

Residency Requirements

I agree with the proposed changes considering the state's recent acceptance of compact licensure. This will also reduce the pressure and expedite completion of the required face-to-face hours because services can be provided in a hybrid or solely telehealth model of care.

CommentID: 222509

4/12/24  11:36 am
Commenter: Anonymous

Petition to reduce/change hours

I agree with this petition about the need to change the number of hours needed to earn LPC licensure. Mental health counselors are critically needed. As a veteran teacher of 30 years that is transitioning to the field of Clinical Mental Health Counseling, I see students struggling with mental health every day. I also hear stories of students waiting for months on a waitlist to get help because of shortages. Some families struggle to afford counseling services for their children. Even though these families may have insurance coverage, Resident Counselors pursuing their LPC can only accept insurance clients based on their supervisor's credentialing. This creates a situation where a Resident in Counseling may be available to counsel but the family cannot afford to "self pay" because the counselor cannot accept their insurance. 

I fully understand the state of Virginia wanting counselors to be highly qualified. But, the excessive hours are beyond what is needed to be highly qualified.


CommentID: 222511

4/13/24  9:56 am
Commenter: Anonymous

Adopt recommended changes

I agree with the proposed amendments to licensure hour requirements. As a Resident in Counseling I have seen first hand the difficulties imposed on both clients and licensure candidates due to current exorbitant hour requirements. Reducing the hours would make Virginia more in line with other state requirements, reduce resident burnout, and improve mental health services access to our communities. Thank you for your consideration.

CommentID: 222512

4/13/24  2:22 pm
Commenter: Anonymous

Supervision Hours

The reduction in hours of direct client-contact to be more in line with comparable state's requirements makes sense. However, I disagree with the need to change the structure of supervision requirements. Residents typically have access to at least once per week, but often if a resident is only pursuing licensure at part-time rates, then supervision once per week does not make financial sense for either the resident or the supervisor if it is included in an employment contract. The full 200 hours could potentially be reduced. However, that conversation is much more nuanced than simply removing the overall requirement. 

CommentID: 222513

4/21/24  1:58 pm
Commenter: R. Fines

Beneficial changes

These changes would be highly beneficial for aspiring counselors. It allows them to gain practical experience more efficiently, which can lead to earlier entry into the workforce. The reduced supervision hours provide flexibility and ensure that they are adequately supported while developing their skills. This streamlined approach can help counselors reach licensure faster and start positively impacting clients sooner.

CommentID: 222519

4/22/24  3:19 am
Commenter: Very Concerned Client

Ethics Issues

There is a significant issue going around with Licensed Counselors for some years being non--factual with information and making records corrections/adjustments/amendments exceptionally difficult. Most agencies/personnel with whom I have worked regarding my disabled child will notate whatever they want, and then IF they provide the required opportunity to address/amend/correct records, they provide a LOT of resistance, and then only maybe agree to 'amend'/correct records with an 'attachment' which is not guaranteed nor monitored. Records amendments/adjustments/corrections MUST be able to be made on Original Documentation in a way that it CANNOT be separate/d. At times I've seen agencies in collusion together to determine what THEY want (mostly in terms of billing) and document things in a way that benefits THEIR billing, and NOT what's in the best interests and/or honesty for the client. This practice needs to be stopped with STRONG policy language, CLEAR outlines/examples of violations which can constitute licensure revocation, suspension, cancellation and non-renewal. Enforcement is necessary for the safety, welfare and medical recordation for other providers and in files for collaborative services FOR the best interests of each client.

CommentID: 222520

4/23/24  9:52 am
Commenter: Justin Jordan PhD LPC LSATP

I trust the board to weigh the positive and negatives of this change


As others have stated, this is a very nuanced issue for counselor training. Weekly supervision throughout the residency is beneficial in ensuring client issues and resident development issues don't "fall through the cracks", but also creates some inequity and difficulty for residents who are working to become counselors on a part time basis. 200 hours is a high bar for the residency period, but we should be holding our residents to a high bar for learning how to do this work. I am proud to be licensed in Virginia, where I know my fellow counselors have had those hours in supervision to learn and grow and tackle new situations that are unfamiliar. I am opposed to changes designed to "just make it easier" to get licensed quickly. It seems that the current set up in which residents must have one hour of supervision per 40 hours of work time seems fair to residents and supervisors. Most of all, I hope the board will be thoughtful in ensuring that Virginia maintains a high training standard for residents pursuing their LPC, especially with the Counselor Compact legislation expanding our opportunities to serve clients in other states in the years ahead. 


Justin Jordan PhD LPC LSATP

CommentID: 222524

4/24/24  1:00 pm
Commenter: Anonymous

Accompanying Jurisprudence

While I agree wholehaeartedly that the number of hours a person completes under supervision is not a direct signe of comptency and can be modified in an appropriate manner, I strongly believe that additional measure need to be intituted to ensure that new and continuing therapists are competent. While additional testing may not be the answer, I would recommend some form of skills based jurisprudence be instituted to support this change with minimal risk to consumers. 

CommentID: 222531

4/29/24  7:58 pm
Commenter: Anonymous

Maintain the requirements to uphold professional standards

Maintaining rigorous requirements for counselor licensure is crucial for upholding professional standards and ensuring the provision of high-quality mental health care. These standards not only safeguard clients' well-being but also promote continuous professional development among counselors, fostering a culture of excellence in the field. By upholding stringent requirements, we safeguard against subpar practitioners, thereby preserving the integrity and effectiveness of counseling services. 

CommentID: 222552

4/29/24  8:04 pm
Commenter: Anonymous

Maintain requirement for direct hours

While I recognize the process to be cumbersome, it does help to ensure that a resident is prepared should they choose solo practice. I believe that the 2000 direct hour requirement helps to provide that competency.

CommentID: 222553

4/29/24  8:47 pm
Commenter: Anonymous

Proposed Changes to Residency and Supervision Requirements

As a current supervisor who has been a supervisor since 2011 in PA and since 2019 in VA, I want to share that for various reasons there are residents who can only obtain supercision hours on a biweekly basis as they are caring for family members, working full time jobs ,  and as there are natural breaks when holidays roll around, people are ill, or when life happens. To say that supervision would have to take place only weekly is a diservice to these individuals who cannot access supervision weekly.

Please consider having flexibility about the structure of how residents obtain supervision hours as there are many who can only participate in supervision activities biweekly.

I am opposed to the decrease in the requirements as proposed here. I strongly believe in  holding our profession to the highest standards as we are in a position of providing vital specialized care to others.  I see what supervision provides and equips new counselors with, how it supports the development of a high quality skillset, and feel that adequate hours and effective supervision helps new counselors and reach higher standards. To lessen the number of direct client hours required  or to change the structure of supervision to "weekly" sessions will weaken the attainment of a strong clinical skillset and reduce what supervision provides  new professional counselors who are just starting out.   The quality of licensed professional counselors should be held in highest regard, and therefore so should their training requirements.   The current requirements as they are now are effective in ensuring that newly licensed professional counselors are well equipped to practice on their own or in a group practice, and that they provide a high quality standard of care to their clients. 


CommentID: 222554

4/29/24  9:08 pm
Commenter: Anonymous

Residency Hours and Supervisors

I feel as though the hours to obtain for licensure should be reduced and mirror in both LPC and LMFT programs. The direct client time should also be reduced as well. Supervisors should be made to take a cultural competency course and do retraining’s after 5 years to ensure they meet the standards as a supervisor. 

CommentID: 222556

4/29/24  10:24 pm
Commenter: Anonymous


Looking at the DHP case decisions between 1/1/23 and 4/29/24, one will quickly find that counseling far outweighs other mental health fields (i.e., Psychology and Social Work) in ethical violations and sanctions. I don't think we are in a position to lower our standards. Further, while I agree that the process can be tedious and can feel as if it will never end at times, I think there is something to be said for meeting a certain metric when it comes to competent practice. Reducing the 3400 to 3000 may make sense, as ancillary hours can be easily met. However, I don't think direct hours should be reduced. Finally, the proposed supervision requirement is unrealistic and creates additional barriers. Not all residents see 40 clients within a week, and it is impossible to account for sickness, reschedule, and guarantee adequate coverage if a supervisor cannot meet that week. Further, supervision comes at a financial burden to the Resident - even when it is "covered" by the agency, it is how the egregiously low pay tends to be justified. I urge the board to keep the direct hours and supervision requirements as currently written. Perhaps efforts should be made to improve the requirements and training of supervisors themselves. 

CommentID: 222558

4/29/24  10:34 pm
Commenter: Anonymous

Supervision needs to be better

These adjustments reflect the evolving landscape of mental health care and acknowledge the need for flexibility in training programs. However, as we advocate for these changes, we must ensure that ethical responsibility and comprehensive training remain at the forefront.

While reducing total required residence hours and residency client contact hours can make the path to licensure more accessible, it's crucial to maintain the integrity of the counseling profession. Adequate training and supervised experience are fundamental to providing quality care to clients. Therefore, I suggest incorporating specific language within the amendments that emphasize the importance of ethical practice and ongoing professional development. To that end, real change would be improving requirements and training for those in supervisory positions.

Furthermore, while transitioning from a minimum of 200 hours of supervision to a requirement for weekly supervision with no minimum might streamline the process, I think a clearly defined minimum requirement should be attainable and realistically met. The proposed one is not. 

CommentID: 222559

4/29/24  11:26 pm
Commenter: Anonymous

Standards for LPC's should remain high to compete well with other disciplines.

Having been in the helping profession for over 35 years now, I have seen a huge lack of respect for LPC's, especially from the field of social work. We are already not taken as seriously as LCSW's and are grossly under utilized in some arenas. For example, as far as I know, we are not utilized by Medicare or Tricare/military yet. In a world where there is currently a pressing need for more therapists, we are still not seen as "good enough" compared to LCSW's. I would hate to give them one more reason to think we don't measure up. Our training is essentially the same as theirs at the moment (equal but different with some subjects), it's just laid out differently. The LCSW internship is longer, but our residency is longer. So shortening any of it may put us in question. Sometimes I wish the two disciplines would merge into one, helping is helping, therapy is therapy. The whole Hatfield & McCoy feud thing is getting old.


CommentID: 222560

4/30/24  7:44 am
Commenter: Jill A. Hagen, LPC, LSATP

Lower standards?

I have been in the counseling field since 1974. I have always found that extensive supervision and practice makes for better service. Reducing minimums of residency and supervison will likely result in decrease in skills and increase in major oversights on the part of the Counselor. Having taught and supervised Counselors (both paraprofessional and graduate level),  they are usually under prepared for the hard and sensitive work even at the current required levels. I have always been concerned that residents only need to meet minimum standards. Reducing requirements will result in deaths and LPC status undermined. 

CommentID: 222561

4/30/24  8:20 am
Commenter: Anonymous


I am more recent in coming into the profession than some of those who have commented. I have concerns with reducing required hours. Just as we would want our medical professionals to have as comprehensive and through training as possible, as mental health professionals, I feel that we need the same. I find reduced requirements concerning. 

CommentID: 222562

4/30/24  9:05 am
Commenter: Shante Williams

Support for changes

I am in support of changing the residency and supervision requirements for LPC Residents.  

CommentID: 222563

4/30/24  9:13 am
Commenter: Anonymous


As a current graduate intern, I have found the hours to be overwhelming. I have questioned if I even want to move forward due to the time, effort, energy, and money that I will have to invest (only to be told that those going into the field should be more focused on helping others instead of making a decent livable salary). I don't think reducing the residency hours will have that great of an impact. Nor will the reduction of supervision hours. One has to remember that in addition to the residency, most (if not all) will have to had complete an internship with their program which includes supervision hours and direct contact hours as well. A potential LPC has them and those hours of experience working in a professional capacity. While the requirements are there to ensure adequate training, they are also a barrier for those who want to enter the field. Reducing the hours is not going to create a new generation of LPC's who are not ready or unable to provide quality ethical services. However, it may encourage those who are thinking about getting into the field to move forward with the process. 

CommentID: 222564

4/30/24  9:32 am
Commenter: Anonymous

Do no harm

Why would we lower our standards in a field where harm could be done. Our profession handles life and death situations, and it is proposed that inexperienced or new clinicians need less experience and supervision? That is outrageous. This proposal needs to be denied for the safety of our clients. 

CommentID: 222565

4/30/24  9:48 am
Commenter: Anonymous

Agree Do No Harm

I agree with the comments of Do No Harm. As a licensed supervisor I observe mental heath counseling is a highly nebulous field, as in no 2 cases are the same, and it is not as easy as an antibiotic, so to speak, prescription to cure. Even the best prepared  LPCs on gaining licensure are still very green. Very green with much to learn. I absolutely disagree with lowering any LPC entry standards or requirements across-the-board. 

CommentID: 222566

4/30/24  9:52 am
Commenter: Anonymous

Lowering hours lowers opportunities for multi-state licenses

From what I understand VA has some of the most stringent licensing hours, so this can be viewed as a bad thing for those entering the field, but  it also allows for us to more easily apply for licensing in other states. This is beneficial for expanding our businesses or if we need to move at some point in our lives. I find it a relief to know that when the counseling compact comes in to play that all the hours I spent for licensing will most likely be enough to gain more state licenses without having to gain more hours. I rather have done what’s necessary in the beginning of my career rather than later. I would table this decision until the counseling compact has been fully integrated and we have a clear understanding and of the process. 


CommentID: 222567

4/30/24  10:01 am
Commenter: Anonymous

No!! Gatekeeping is there for a reason...

This is ridiculous. As a multi-state licensed trauma therapist, looking at the caliber of residents and supervisees that are coming into the field after receiving their training online during COVID, residents/supervisees need MORE supervision, not less. What happened to being the "gatekeepers" of the profession? We are the LOWEST paid medical professionals that are held to the HIGHEST standards of care and we want to reduce supervision? This petition is the reason we are not taken seriously in the greater medical community! 

I firmly DISAGREE with lowering our standards further. 

CommentID: 222568

4/30/24  10:14 am
Commenter: Anonymous


I do not agree that lowering hours is a good idea - we need all the training and support we can get as  we enter into a field as demanding and challenging as counseling. However - I would propose we make WEEKLY supervision a thing while keeping 200 hours of supervision as a requirement. BOTH AND.

CommentID: 222569

4/30/24  10:38 am
Commenter: Anonymous

Agree, makes the licensure process comparable to other states.

I highly encourage folks to check out licensure requirements for LCSW, and LPCs in other states-to include MD and DC. VA has extremely rigorous requirements. Residents typically pay for supervision as well; making it an expensive investment as well as a time consuming one. Many residents work other jobs while working to obtain licensure because the sites they work at do not pay a livable wage. 

According to white paper completed by Motivo Health—57% of graduates never even complete the licensure process! Which means the massive crisis we are facing with the shortage in clinicians is starting as soon students leave grad school. “

My own journey toward licensure has taken many years longer than my graduate school peers because the counseling jobs I needed to work to get hours did not pay enough for me to live in Northern VA as a single person. I’ve been working full time in my daytime career unrelated to counseling and then part time as a therapist to get my hours—it’s exhausting and expensive and time  consuming! This is the reality for many of us who do not have family to support us or live in dual income homes. 

I think this would be a welcome change to people who really are passionate about this field but have been challenged by the financial burden of getting toward licensure. 

CommentID: 222570

4/30/24  11:02 am
Commenter: LPC for 25 years

NO!!!! Against the changes...

With the current world falling apart and changes occurring by the second (not good ones , mind you), being a therapist has become more and more challenging. Once we had the "walking wounded", now, there is a plethora of very serious and deep issues therapists have to deal with . Do no harm. And to live by that , the rules need to stay the same....maybe even add more...for quality training.  Would you go to a surgeon that had less training?

Where is this coming from? Is this the new generation that has had things handed to them and now want it easy? Poor babies...well, tough toenails....WE ALL PAID THE DUES, PUT IN TIME AND HAD FINANCIAL BURDENS!!!   And somehow we managed....WE DID IT AND SO CAN YOU!!    Time to grow up.

CommentID: 222571

4/30/24  12:04 pm
Commenter: Suzan K. Thompson, Ph.D., LPC

LPC since 1996

Every profession evolves, hopefully for the better with each iteration. I am honored to have a license from Virginia -- the first state to license COUNSELORS separately from psychologists and social workers! As a former full-time faculty member, current LPC supervisor and private practice counselor, I believe it is time for Virginia to align with the majority of states in its requirements, especially with the Counseling Compact in effect now AND the shortage of qualified LPCs. Times have changed and regulations have changed slowly -- now it's time for Virginia to make appropriate changes to requirements to earn the LPC.

CommentID: 222572

4/30/24  12:43 pm
Commenter: Sophia Sills-Tailor

Time for Change

I agree that these changes need to be made.

CommentID: 222573

4/30/24  1:46 pm
Commenter: LPC, LCPC of 12+ years

Keep the requirements.

2,000 direct hours is an average of 9.6 hours per week over 4 years. Or, an average of 19.23 hours over 2 years. A full time caseload for most independently practicing therapists is typically considered 20 hours per week. So, essentially we are asking residents to work an equivalent of two years' worth of full time direct clinical hours in order to minimally consider them as competent and independently licensed.

I think that's beyond reasonable. Especially in a field where our scope of knowledge is so broad, and more and more we're realizing our clients are multi-faceted and often co-occurring. Depression, anxiety, ADHD, Autism, OCD, psychosis, substance abuse, trauma, eating disorders, peri/postpartum, etc. We should not be rushing through the process. Too often I see clients who have been ineffectively treated in the past due to a lack of general knowledge by previous therapists to simply screen for various conditions and refer out as needed. We're not expected to be experts in everything, but I am not convinced that LESS experience and supervision is appropriate or wouldn't cause harm.

I also think that the current board's requirement for a minimum ratio of 1 hour of supervision per 40 hours of experience is appropriate. Realistically, with holidays and time off, the actual calendar week equivalent is less than 1 hour per week when averaged out, so there is flexibility there (it's just messy to calculate/track). A work week looks different for different providers, whether part-time or otherwise, so I strongly advise against the petitioner's recommendation for a flat 1 hour of supervision per week.

For those referencing the desire for residents to be less financially burdened and be free of their dependence on toxic workplaces, I will say I completely understand from personal experience. However, that is another matter to address independent of the need to ensure competent therapists ready to practice independently upon issue of their medical license.

CommentID: 222574

4/30/24  2:33 pm
Commenter: Anonymous

Times Have Changed

As a current Resident in Counseling I am in favor of lowering the amount of required hours for licensure. The number 3,400 seems arbitrary and is not indicative of someone's ability to work with clients effectively. Not to mention there is a shortage of therapists nationally and more than 50% of potential clinicians who start residency are not able to complete it. 

CommentID: 222575

4/30/24  2:59 pm
Commenter: Shelby DeBause

Long time supervisor, and I do not support these changes

As a person who has been supervising for 8 years, I typically see that residents need the full amount of hours of experience, hours, and supervision that are the current standards. I understand that the road to licensure is seen by many as long and challenging, but frankly, it is meant to be so that only those truly dedicated and ready to serve pass through the gates into independent licensure. I would hate to see our profession fall into lowering our standards, and urge people to think about the reputational damage this may have on counseling long term. To protect clients, clinicians, and the field itself, I warn against these changes. 

CommentID: 222576

4/30/24  3:52 pm
Commenter: William Moncure

Mixed - Current Supervision Hours Excessive, Consider Slight Reduction

Currently, if a Resident receives one hour of supervision a week, it would take them nearly four years to finish their hours. If they work 40 hours a week with one hour of supervision, they would end up with 8,000 total hours before finishing their supervision hours. Even if they receive two hours of supervision per week, they would end up with 4,000 total hours, which is in excess of current requirements (regardless of whether they are reduced as this petition requests). I have known many Residents who have finished all of their clinical hours, but have to stay as Residents for months (costing them thousands of dollars) only to complete supervision hours. I think we should consider 150 supervision hours as a requirement instead of 200.

In addition, graduates of CACREP Doctoral programs can count their Internship hours for "up to 900 hours of the residency requirement and up to 100 of the required hours of supervision". One option that would help out some people would be to also count the same number of Practicum and Internship hours from non-CACREP accredited Doctoral degrees in Counseling and related fields, provided that the individual applying for licensure already has a Master's degree that meets the Board's requirements for licensure as an LPC. This change would help recognize already obtained valuable experiences these individuals have and help increase access to mental healthcare in Virginia.

I have more mixed feelings about reducing total hours and direct hours, but I do know that our requirements are much higher than some other states.

Some commenters here have mentioned that our current standards make it easier to become licensed in other states, but an accurate understanding of the Counseling Compact is that one only has to be licensed in their home state to practice under the Compact - the goal is that we do not need to meet licensure requirements in other states. With that said, even with some of these changes, such as the number of supervision hours, we would still have higher requirements than the vast majority of states. Thank you for considering my thoughts.

CommentID: 222577

4/30/24  7:15 pm
Commenter: Suzanne Nixon

in support

I support these changes. VA requirements are not in alignment with other states, and I believe the hours are overly extensive. 

CommentID: 222578

4/30/24  7:45 pm
Commenter: Anonymous

Easier for clinicians moving from out of state

Hello! The requested change of requirements would match other states. I am moved to Virginia from Tennessee and am licensed in TN. I have not reached the 2 year mark for post licensure, so I am having to do extra supervision to reach Virginia’s standards. I think it makes more sense for all states to generally have the same requirements.

CommentID: 222579

5/1/24  7:21 am
Commenter: Anonymous

Petition comment

To Whom It May Concern,

I am writing today to support some of the changes and wish that the rules would read this way:

For the comments 1 and 2, I believe that the Supervisor should be required to approve the acceleration for the individual resident.  Mechanically the requirement would remain 3400 hours and 2000 hours respectively.  Yet, the supervisor could petition the board when the resident reaches 2800 & 1300 hours to recommend the resident be approved at 3000 and 1500 hours.  Not all residents are prepared for an early release of hours, but most/many will and therefore should be allowed to become fully licensed.

3. I think this change is critical as sometimes its difficult to manage schedules to ensure the "When" of a supervision hour occurs and all hours by a resident should be counted even if illness/vacation etc delay a supervision appointment.  Also, a smart resident will increase their supervision in the beginning of residency when its truly needed, and relax the supervision frequency near the end of residency.  They should be granted the opportunity to do what's best and right for their needs. 

CommentID: 222580

5/1/24  11:19 am
Commenter: Anonymous


I think adjusting based on current times is appropriate. We spend so much money to get the degree and then sometimes have to pay absurd amounts for supervision. That's another area that should be governed. We're not saying make it so that anyone can decide to get licensed however, make it doable. 

CommentID: 222581

5/1/24  12:12 pm
Commenter: Sharon Watson, LPC, LMFT, LSATP, NCC, ACS

Strongly support with a caveat

There are several reasons why I support this petition with one caveat: change the “weekly” requirement for supervision to 100 hours which can still be a combination of individual and group supervision and change . 


I have supervised many supervisees/residents since 1995 in the public system in various roles, in private practice as employees, and those in their own private practices.  As I continue to do so, my recommendation is:

  • 3000 hours total work
  • 1500 hours face-to-face/direct work
  • 100 hours of supervision with a minimum of 1 hour per 40 hours of work
  • Supervision provided only by a trained LPC supervisor


#1. LCSWs in Virginia are only required to have 100 hours of supervision, 3000 hours of work experience with 1,380 hours of face-to-face supervised work experience. If the Virginia Department of Health Professions feels that’s adequate for social workers, they should be adequate for professional counselors. It would be interesting to find out why the requirements were made so much more rigorous for counselors in the first place.  Was it because, as the first state in the U.S. to license counselors they wanted to be sure they could support the requirements for licensure?  Or could it have been that at the time there were no specified graduate programs (like CACREP) that would make the training consistent over the various graduate programs and they wanted to be sure counselors were adequately trained?  In any case, that is no longer an issue.  For that reason, the current imbalance of requirements between LCSWs and LPCs is extremely unfair because it: a.) burdens LPCs with the additional extreme financial expense of paying for twice as much supervision and b.) with the higher total work time requirement it postpones the resident’s licensure and ability to take insurance (if wanted) in order to earn a livable wage? 


#2. Understandably there are some who may suggest that we, as LPCs, want to have a higher standard for counselors than social workers.  However, in the real world, is the public (our clients) making the choice of social worker vs counselor for therapy because of the licensure requirements?  It’s unlikely that the public has any idea about the difference. The way to maintain a high standard and consistency in our field is for LPC supervision to be provided only by LPC supervisors and not LMFTs who have different educational requirements or LCSWs (as was suggested in a recent petition to be an option again), who have even a greater difference in educational requirements and educational focus.   


#3. As was outlined in a previous comment, many states require much less than 200 hours of supervision for LPCs with most only requiring 100 hours. The fact that the Counseling Compact (which includes Virginia) will allow only LPCs (not LMFTs) to request and be granted a privilege to practice in another Compact state, it’s important for us to maintain the integrity of professional counselor licensure.  This is another reason to eliminate LMFTs as LPC supervisors.  So, changing Virginia’s licensure requirements to be more in line with many other states would be a timely and welcome change.


Lastly, the reason supervision should not be based on a weekly schedule is because some residents work part-time or very limited hours.  It would be unreasonable to expect, for instance, someone working 10 hours per week to be required to have the same one hour of supervision as someone working 40 hours per week. Some residents who have difficulty finding clients, especially when starting their practice, shouldn’t have to pay for the same amount of supervision as a resident who has a full caseload and works full time.

CommentID: 222582

5/1/24  1:23 pm
Commenter: Anonymous

Maintain standards

I agree that the 200 hour requirement for supervision can be challenging to meet within a reasonable timeframe if you consider 1 hour of weekly supervision over the course of residency. Lowering the required hours of supervision makes sense to me. 

Lowering the required hours of client contact however, makes no sense to me given how much there is to master over the course of a residency to truly serve various client populations well. Over the 20+ years that I have been in the field I have seen the complexity of the issues clients are presenting with only grow and being thoroughly trained and equipped to work with these clients is essential for those who want to be mental health counselors. 

CommentID: 222585

5/1/24  2:26 pm
Commenter: Anonymous

Support change

I am in support of the proposed changes. 

CommentID: 222586

5/1/24  7:16 pm
Commenter: Anonymous

Agree with the proposal except for the weekly supervision meetings

I support the proposed changes except for the weekly supervision meetings.  The number of supervision hours should be reduced but not all residents are working full time and some will have to have a break in their schedule because of maternity leave, caring for an ill or dying family member, or recovering from surgery.  You may not be able to get in any hours or you may be able to get in a few hours during this time.

CommentID: 222587

5/2/24  2:40 pm
Commenter: Anonymous

Support in part

I don't support decreasing the total required hours, but I do support decreasing the direct supervision hours. I'll be starting my residency next month. I could get my 3,400 hours and 2,000 direct hours in 85 weeks, but to get 200 direct supervision hours in 85 weeks, I'd have to get about 2.5 hours of supervision weekly. That's hard to do. Change it to one hour minimum per week, regardless of the length of the residency.

CommentID: 222591

5/2/24  9:48 pm
Commenter: Anonymous


I worked in schools as a licensed school counselor for 12 years then began my LPC residency. I have been working on that for over two years so far and still have half a year to finish the hours. If required direct hours are reduced then qualified residents can be done much sooner and make a living wage. Residents don't make enough money to support themselves much less purchase health insurance. I support the proposed changes.

CommentID: 222592

5/3/24  10:46 am
Commenter: Student

Please change requirements

I am in support of the following:

  1. Reduce the total required residence hours from 3,400 to 3,000;
  2. Reduce residency client contact hours from 2,000 to 1,500; and
  3. Change supervision requirements from a minimum of 200 hours to a requirement for weekly supervision with no minimum.

Having received my master's in counseling, professional experience in the field and now taking three more courses to pursue my residency in the state of VA, the current requirements seem unnecessarily high.  If programs are CACREP approved students should be receiving the education and experience they need.  Graduate students also receive supervision during their 600 hours of internship.  

If requirements stay the same, supervision should be free and counselors in residency should be paid a livable salary. Thank you.

CommentID: 222593

5/5/24  4:09 pm
Commenter: Anonymous

In full support

Removing the minimum hours for supervision means since residents have to remain under supervision the entirety of the residency anyway.  No matter how many hours per 200 they accrue. Also, my residents work multiple jobs to get face face hours. Many are burnt out before they get the LPC and are thinking about other avenues of work.  So reducing hour requirements for face to face and total hours sounds fair. 

CommentID: 222594

5/6/24  10:45 am
Commenter: Pedro A

In full support.

I am in full support of modifying the requirements for full licensure. I do not believe it will compromise the quality of care. Moreover, it will help expedite fielding much needed licensed practitioners. 

CommentID: 222595

5/6/24  5:08 pm
Commenter: Jasmine Johnson, The Up center


I support!

CommentID: 222598

5/6/24  6:03 pm
Commenter: Graduate Intern

Support Petition for changes

Let me start off by saying that if I did not think this was my calling, I would not be attempting to complete this whole process. When I initially looked at the requirements, I put of enrolling in school for a year because I wasn't convinced the payoff would be worth the sacrifice. I have had to quit a well-paying job to find a way to incorporate my internship hours. And now I'm hearing about the discord around counselors being told they shouldn't get into the field for money??? So, after racking up student loans and literally working years to get licensed we shouldn't expect to make a livable salary?? This is why people are not looking at getting into this field. Students get burned out before we are even able to have the benefit of saying we have a license and then we get slapped on the hand if we mention that we would like to be able to afford our necessities, but work/life balance is preached from the rooftops-but not for us. I know friends who have left the field to pursue jobs in IT or other fields that pay way more and have less stress. And that will continue to be the case if things are not changed. There is already a shortage of mental health professionals, and it is projected to only get worse in the next couple of years. 

Those who have commented that they have been in the field for decades and that they were able to figure it out and make it work, well done. That was then. However, just because that is the way it was does not mean that is the way it needs to remain. If the petition had been made then to reduce the hours, I'm sure some would have jumped at it but don't be bitter because it wasn't, and you had to suck it up. This "generation" isn't lazy. We aren't lacking work ethic. We have been provided the opportunity to look at a requirement that may be more detrimental than beneficial to bringing good talent into the field. A reduction in hours does not automatically mean an influx of unqualified LPC's. Are we saying that other states that have less direct contact/supervision hours are producing subpar LPC's? I have met some counselors who have gone through the process and are horrible at their job but stay because of the money and time invested. It is the person doing the work. Either they have a passion, or they don't. If changes are not made, the outcome will be a loss of talent and those who do "suck it up" will be coming in burned out and questioning their life decisions. With these changes, no one is being handed a license on a silver platter. Time, effort and energy will still have to be invested so please stop gatekeeping. 

CommentID: 222599

5/6/24  8:27 pm
Commenter: Anonymous

Do not support

Like all health professions residency allows for the necessary training to become proficient in the field. We should not lower LPC standards as this does not benefit clients. Lower the standards will increase liability.

CommentID: 222600