I strongly oppose the proposed amendment to 18VAC115-20-52(C), which would allow licensed clinical social workers to supervise residents in professional counseling. While both are professionals in their own rite, licensed clinical social workers and professional counselors are absolutely and irrefutably distinct disciplines. Moreover, licensed professional counselors are unable to supervise residents in clinical social work, so why would the reverse be allowed?

Allowing licensed clinical social workers to supervise counseling residents is analogous to allowing epidemiologists to supervise residents in medical training.

While epidemiologists are trained to formulate the general picture of disease in a given population, and may even possess the capability to provide resources and data toward positive health outcomes in a given population, they do not treat patients/clients as medical practitioners do. Would you like for an epidemiologist to treat your medical condition, or would you prefer a trained medical physician to treat it? The next time you schedule a doctors appointment for your child, or your spouse, or yourself, consider the implications of being seen by an epidemiologist as opposed to being seen by a trained medical physician.

Likewise, would you like for a social worker to treat your mental health condition, or would you prefer a trained mental health counselor to treat your mental health? You may have or may have not seen a professional counselor or social worker. If you ever need to see one or the other, I guarantee beyond a shadow of a doubt, you will benefit more from seeing either one or the other because they are two distinct disciplines, with distinct trainings.

Again, I strongly oppose amendment to 18VAC115-20-52(C), which would allow licensed clinical social workers to supervise residents in professional counseling.