I am writing to express my strong opposition to the proposed amendment to 18VAC115-20-52(C) that would permit licensed clinical social workers to supervise residents in professional counseling. While I appreciate the need for flexibility within the mental health profession, this particular amendment raises significant concerns regarding the quality and appropriateness of supervision provided to counseling residents.

Licensed clinical social workers and professional counselors possess distinct training, expertise, and professional competencies. Allowing licensed clinical social workers to supervise counseling residents blurs the lines between these professions. It could potentially compromise the quality of supervision and the standard of care provided to clients.

Professional counseling is a specialized field that requires specific knowledge and skills in areas such as psychotherapy techniques, assessment, diagnosis, and treatment planning. While licensed clinical social workers undoubtedly have valuable experience in mental health practice, their training may not fully align with the comprehensive skill set required for effective counseling supervision.

Instead of diluting the standards for supervision, we should prioritize ensuring that counseling residents receive high-quality training and supervision from professionals who are specifically trained and experienced in the field of professional counseling. Maintaining clear and rigorous standards for supervision is essential to upholding the professionalism and ethical standards of the counseling profession and safeguarding the welfare of clients.

In conclusion, I urge you to reject the proposed amendment to 18VAC115-20-52(C) and uphold the integrity and standards of the counseling profession. Thank you for considering my concerns.