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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3/12/24  9:33 pm
Commenter: William Moncure, M.A. in Clinical Counseling; Doctoral Student

Support - Improve Reciprocity, Embrace Interprofessionalism, Consider Options for Implementation
 

I want to start off by stating that I know, and have worked with, a number of extremely talented Clinical Social Workers. My experience with them began as I was completing my Internship during my Master's degree in Counseling. I learned a ton from them, including things about case management that I believe I would not have had a chance to learn otherwise. They were all well qualified, as all LCSWs must have 60+ hour Master’s degrees, pass a licensure exam, and have years of post-degree experience in order to become licensed. 

Some commenters here may express that LCSW supervision is not “needed” because there are enough LPCs to supervise all LPC Residents in Virginia. Personally, I do not see this argument as convincing for two reasons: First, I am unconvinced that all LPC Residents are able to find supervision so easily. There are rural areas of Virginia where there are not many LPCs, but perhaps there is an LCSW in the area. Even with online supervision, not everyone wants to be supervised online from someone outside of the practice where they work. Personally I would rather be supervised in person by an LCSW I work with than an LPC halfway across the state on Zoom. If you feel differently feel free to make that choice for yourself, but it should be a choice. Second, even when there are LPCs who can provide supervision, there may be LCSWs who have special training that a Resident is interested in. Counseling claims case management as part of our scope of practice, and who better to learn it from than an LCSW? Perhaps you want to learn TF-CBT, EMDR, or some other specific modality and there just happens to be an LCSW in your area who specializes in that. Why not allow a Resident to pursue their career with that training if they want? I do not see this matter as a question about whether supervision by Social Workers is “needed” - I think it can be desirable in certain circumstances.

In an era where different mental health disciplines are working on compacts to work across state lines, trying to improve access to mental healthcare, and trying to increase the number of educational programs producing our graduates, I think it is crucial to acknowledge that the Board's recent decision to stop allowing hours supervised by LCSWs to count towards licensure has impaired licensure portability. There are many cases of individuals, who are licensed as Counselors in other states, lamenting online that none of their supervised hours in their home state were accepted by our Board due to their hours having been supervised by an LCSW. These are fully licensed individuals who have been practicing in their home states for years (where these hours were accepted) who moved to Virginia wanting to serve our population’s mental healthcare needs. Yet, they have to start over. 

On a similar note I believe it was only in 2019 that the Board decided to stop allowing LCSWs to supervise Residents in Counseling in Virginia. Are we to believe that all of the Counselors supervised by LCSWs before 2019 were somehow not properly trained, or lacked an identity? Many of those Counselors practice competently today. 

On the subject of Counselor Identity, I would point out that Virginia already requires appropriate Counseling coursework to have been completed for Licensure, as well as a Master’s degree, and adherence to the regulations of this Board. This protects Counseling’s identity, licensure status, and scope of practice. Residents in Counseling who are supervised by LCSWs will still be LPCs with appropriate Master's degrees who have to adhere to the rules of our profession.

I encourage other Counselors, and the Board of Counseling, to consider several options and compromises for how this measure might be implemented. For example, many states allow Residents in Counseling to receive at least a portion of their hours under supervision of a Social Worker. Although I see no issue with allowing LCSWs to supervise in general, we could at least allow up to half of a Resident in Counseling's hours to be under the supervision of an LCSW. In addition, the Board might consider limiting LCSW supervision of Residents in Counseling to only those LCSWs who have a certain amount of experience - for example a Doctoral degree in their field, or three years post-licensure experience. That’s just an example, but would ensure they have far more experience in practice than the Resident they would be supervising.

Finally, I understand the desire for the Board of Social Work to reciprocate and allow their own supervisees to be supervised by LPCs. I agree, and even commented on a similar petition to their Board saying I felt LPCs should be able to supervise Social Workers who are accruing hours towards their license. I also feel that, when the Board of Psychology begins to have Master’s-level practitioners, they should also be able to be supervised by LPCs and LCSWs, and I have contacted legislators to that effect. However, even if these other disciplines do not comply with these wishes, I do not think the answer is to take our ball and go home in reaction, denying our Residents the opportunity to be supervised by an LCSW if they so wish. Instead, allow LCSWs to provide at least some supervision for LPC Residents, and continue reaching out to these other professions in good faith. Advocate for interprofessionalism instead of reacting and driving our disciplines apart. In the midst of an opioid epidemic, a mental health crisis, and rising political division our clients need us to work together and do the right thing. Thank you for considering my thoughts.

CommentID: 222290