-- I agree that a supervisor should document clinical rather than administrative work experience in order to be a supervisor.  I disagree that the experience should be extended to 5 years before being allowed to supervise.  There are other alternatives to addressing supervisor competency.

-- First, I would like to explain how I’ve come to my response to this petition: I have been a supervisor in Virginia for over 20 years and I am a provider of the 20 hours of Clinical Supervision Training required for LPCs and LMFTs to supervise residents and as such have trained many supervisors over the years.  I have been the Supervision Chair of Northern Virginia Licensed Professional Counselors (NVLPC) for 6 years, a NVLPC Resident Support Group leader for several years, and have researched and written multiple NVLPC newsletter articles on Virginia supervision topics.  In these volunteer positions I have assisted many supervisors and residents in navigating the process of attaining licensure.  (Note that the opinions I express here are my own and do not reflect the opinions of NVLPC.)

-- I have heard about many situations of inadequate supervision based on ignorance, misunderstanding, and/or misinterpretation of the regulations by supervisors (and residents).  So, I understand the need for amendments to the requirements.

-- However, I believe that extending the requirements for supervising from two years to five years is too extreme at the present time. There are currently about 8,700 LPC residents and about 300 LMFT residents according to the Board with the caveat this number may be inaccurate. There are about 2000 supervisors listed on the Board website which I also think is not accurate, but in lieu of any other numbers, I’m using them. That’s a 4 to 1 ratio.  With more students graduating every year there are already not enough supervisors to meet the need and there would be a shortfall during a 3-year extension period.  I’ve been told multiple times by graduates that it has taken them months to find a supervisor because those they contact don’t return their calls and if they do, say they have no openings.  Extending the time-frame to 3-5 years of experience can be revisited when there are more licensed clinicians available to provide supervision. 

-- I believe the answer to assuring quality supervision is in the supervisor training requirement itself. My recommendations are: 1. Require only in-person post-graduate Clinical Supervision Training in Virginia because graduate courses and on-line training (which are currently allowed) are generic and not state specific and therefore don’t address the Virginia requirements; 2. Require that the Clinical Supervision Training concentrate at least 5 of the 20 hours specifically on the Virginia regulations and requirements, review of the Virginia forms, and navigating the Board of Counseling website; and 3. Require a new supervisor to have a specific number of supervision of supervision hours (for example, 10 hours) from a supervisor who has 5 + years of supervision experience or who has the ACS (Approved Clinical Supervisor) credential.  An alternative to #3 would be to require that LPC/LMFT supervisors take a minimum of 5 hours of the yearly required 20 continuing education hours specifically on the topic of supervision every year.

-- Lastly, the 2-year requirement should be defined more clearly.  I recommend that the experience be redefined and based on 2 years of full-time, 40 hours a week, clinical experience or the equivalent if part-time (for example, 4 years if the experience is half-time clinical work).