Supervision in general employment or training contexts is not equivalent to supervision toward licensure. Residency supervision is a Board-regulated process that requires supervisors to be vetted for qualifications, experience, and ethical standing before overseeing a resident. This distinction is critical because it ensures that candidates are trained under consistent, structured standards designed to prepare them for independent practice. Allowing hours completed outside this process would erode the integrity of the licensure pathway, as there would be no assurance that the supervision was provided by a qualified supervisor or aligned with the Board’s requirements.

The residency requirement is a deliberate safeguard to protect the public and maintain equity across all licensees. Supervision outside of the Board’s oversight lacks the same accountability and may not include necessary evaluation of competence, structured feedback, or adherence to ethical and professional standards. Granting exceptions would create inconsistencies in training, undermine the progression of licensure, and set a precedent for weakening regulatory requirements. The public trusts that licensed counselors in Virginia have undergone rigorous, Board-approved preparation, and preserving this trust depends on upholding established residency standards without exception.

Supervision in non-licensure contexts cannot be presumed to meet these standards. For these reasons, the petition to amend 18VAC115-20-52 should be denied.