To the Commonwealth of Virginia Board of Professional Counseling:

I write as a Virginia LPC to express my concern about the proposed change to supervisor requirements for counselors-in-training and residents (i.e., new professionals) and urge the Board to reject this proposal. Qualified LPC supervisors must have a deep understanding of the counseling profession's unique philosophical views and ethical standards.

Ethical standards in counseling guide our professional practice and ensure the welfare and dignity of those with whom LPCs journey (§A.1.a, 2014 ACA Code of Ethics). Supervisors must deeply understand these standards to guide new professionals effectively, and many of these standards are unique to professional counselors. This level of understanding is best found within our profession, ensuring that supervisors are well-versed in the specific ethics and challenges we face.

Additionally, the 2014 ACA Code of Ethics mandates gatekeeping and remediation for supervisors and counselor educators (§F.6.b.). This accepted standard of care would not apply to practitioners from other disciplines, such as social work.

The proposed amendment could dilute the quality of supervision and, by extension, impede required continuing professional development of future counselors. Supervision is a specialized intervention that focuses on embedding an ethical framework in the next generation of practitioners. Only those fully immersed in the counseling field can ensure this critical aspect of training is met.

Rejecting this proposal does not reject the value of interdisciplinary consultation or collaboration. Rather, rejecting this proposal strengthens professional counseling, and protects the citizens of the Commonwealth by fostering ethical counseling.

Restricting the supervision of counselors-in-training and residents (i.e., new professionals) is crucial for upholding our standards and the integrity of our work. Please consider other measures to recruit more qualified LPC supervisors, rather than simply extending privileges to practitioners from other professions.

John Duggan, EdD, LPC, LSATP