Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Counseling
 
chapter
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]
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9/2/18  2:20 pm
Commenter: Rita Chi-Ying Chung, George Mason University

Opposed restriction to only LPC and LMFT
 

I am the 2013 State Council of Higher Education for Virginia (SCHEV) Outstanding Faculty Award recipient and I strongly oppress the current proposed regulation of restricting supervision by only Licensed Professional Counselors (LPCs) or Licensed Marriage and Family Therapists (LMFTs). I believe this proposed regulation will do a great disservice to the Commonwealth of Virginia’s citizens/the public and the counseling profession. The reasons why I strongly oppose the proposed regulation are as follows: 

  1. VA has approximately 4,575 LPCs (VA LPC, 2016) and 850 employed LMFTs (U.S. Bureau of Labor Statistics, 2017), with approximately 40% of LPCs nationally 55 years and older who may be due for retirement in the near future. The study conducted by VA LPC (2016) reported that 7% of the LPCs will retire within the next 2 years and 24% are projected to retire in 10 years. With the growing society’s tension and pressures encountered by citizens that is frequently reported by mainstream news media and supported by empirical research, issues such as the opioid crises, race relations, xenophobia, interpersonal violence, gun violence, poverty, etc., there is and will be a growing demand for mental health counselors.With multiple factors such as 36% LPC who work in sole or group private practice (VA LPC, 2016) may allow this group limited opportunities to provide supervision; the projection of LPC retirements; and the proposed regulation to limit supervision to be done by only LPCs and LMFTs creates diminished supervisory opportunities for counselors working towards their license in Virginia and hence the reduction and delay of training the numbers of LPCs needed in the field to address these social issues.

  2. This proposed restrictive regulation of only having those who are LPCs and LMFTs will further reduce VA public/citizens access to counseling by LPCs for those who come from diverse and/or underserved populations and communities.

  3. The counseling profession, similar to other mental health professions, overlaps with various mental health professions and yet all these professions have acknowledged, understand and accepted their unique identities and those of other professions. The non-inclusive approach limiting supervisors for LPCs to only LPC and LMFT supervisors sets precedence for divisiveness within the mental health profession, by suggesting which mental health professionals are more qualified to provide clinical supervision for others.In a time where there are great mental health needs in Virginia and nationally with a high demand for mental health professions to assist with society’s social problems, I strongly believe that this regulation would foster divisiveness within the mental health professions and create harm to the population we serve.

Therefore, I strongly oppose to proposed regulation to restrict supervision of LPCs to only those who hold LPC or LMFT. I strongly urge an inclusive rather than restrictive supervision policy.

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CommentID: 66900