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]
Next Comment     Back to List of Comments
8/12/25  12:31 pm
Commenter: Sarah Espinosa

Agreement with petition for rulemaking
 

I strongly agree with the above petition to credit those who have been providing clinical services under supervision prior to the formal “resident” status. The need for clinical oversight, hours of face to face contacts, and years of practice is vastly different in a seasoned clinical professional than a new graduate. 
Additionally, not all who are eligible for residency to gain licensure are able as this may be costly, both to apply and to pay for ongoing supervision if not offered through employment. This barrier creates limitations for underprivileged populations and limits the much needed diversity of practitioners in the field. In order to promote equity and gain inclusion, considerations for change in rule making are necessary. 

CommentID: 237011