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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4/1/24  4:14 pm
Commenter: Wendy F Rood, Resident in Counseling

Opposing this petition
 

LCSWs should not be supervising LPC-track residents in counseling. My reasons are below:

  • There is very little commonality in coursework. An LCSW has not received the same education as an LPC.
  • The above should preclude LCSWs from supervision of residents, as current Virginia law (18VAC140-20-50-C4) states that a social work supervisor “Provide supervision only for those activities for which the supervisor is qualified by education, training, and experience” They are not qualified by education or training – it’s too different.
  • State law (18VAC140-20-50-C3) also states that LCSW supervisors “Provide supervision only for those social work activities for which the supervisor has determined the applicant is competent to provide to clients”. Residents in counseling are not doing social work activities. For an LCSW to supervise would be out of their scope of practice and against Virginia legal code about their practice.
  • Counselor identity differs for the mental health professions, and this distinction is regularly made in school. Residents are aware of this from school and training, and need a supervisor who can support them from that viewpoint.
  • If a resident in counseling wanted to be trained and supervised in social work, they would have gone to school for social work.
  • Having the professions governed by separate boards is problematic for the proposed situation. There would be a lack of oversight. If there is a problem, where does the complaint go to?
  • The requirements to become a professional counselor (2000 hours of face-to-face, 200 hours of supervision) are much higher than the requirements to become a LCSW (1350 hours of face-to-face, 100 hours of supervision). It inequitable to require that much more of the resident than of a supervisor.

 Although social workers play a valuable role, it is a different role. Counselors at a pivotal point in their training need proper support. It would be my hope that, instead of this petition’s effort towards having social workers as supervisors, more effort could be put into making it easier for residents in counseling to obtain supervision from LPCs.

CommentID: 222466