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.