Why would it be reasonable to allow LCSWs to supervise LPC residents when their requirements for licensure are below the standard set for LPCs?  Why would it be acceptable to allow someone whose licensure requirements are lower to supervise someone whose requirements are more rigorous and who are held to a higher standard?  I’m concerned that the differences are not well known even in our own field.  Have you read the Social Work licensure regulations?

Do you know that:

LCSWs are required to have only 100 hours of supervision

LPCs are required to have 200 hours of supervision

LCSWs are required to have only 3000 hours of supervised work experience

LPCs are required to have 3,400 hours of supervised work experience

LCSWs are required to have only 1,380 hours of supervised face-to-face work experience

LPCs are required to have 2000 hours of supervised face-to-face work experience

LCSW supervisors are required to only have 14 hours of clinical supervision training

LPC supervisors are required to have 20 hours of clinical supervision training

LCSW regulations do not accept continuing education hours from NBCC (National Board for Certified Counselors)

LPC regulations accept continuing education hours from National Association of Social Workers

LCSW supervised experience is:

“…in the delivery of clinical social work services and in ancillary services that support such delivery.”

LPC supervised experience is:

“…in the consultation and review of clinical counseling services.”

LCSW and LPC examination requirements are not the same

I understand that often LCSWs provide the same services as LPCs, but there are many instances in which they do not.  There are often differences in approach (per the regulations):

LCSWs: “…application of social work principles and methods…[regarding] social environment, social justice and policy..."

LPCs: provide “Clinical counseling services…assessment, diagnosis, treatment planning, and treatment implementation.”

Previous respondents have discussed the differences in the “identity” of each profession.  If we are expected to believe there are no differences in the work, education, approaches, and identities of the two licenses why then do we have two? If this request to change the regulation were to be accepted, then maybe it should be accompanied by other changes to make the licenses more equitable.  How about requiring LCSWs to have 200 hours of supervision or reduce the LPC requirement to 100 hours?  It’s extremely burdensome to LPC residents who may not be able to find supervision free of charge at their workplace and who must pay thousands of dollars for those additional 100 hours that LCSW supervisees are not required to have.  How about allowing LCSW supervisees to by supervised by LPC supervisors.  All these would make the licenses more equitable and maybe then, LCSWs could supervise LPCs and LPCs supervise LCSWs.

In general, why isn’t there reciprocity between the two licenses?  It seems to only go in one direction: i.e. social work strictly maintains it’s integrity, but this petition doesn’t allow LPCs to maintain their own integrity.  It’s important that an LPC resident have supervision from someone who is knowledgeable about the LPC regulations and has gone through the process themselves.

I think there are better options to having enough supervisors available to supervise residents, some of which have already been addressed in previous comments.  Here’s another option: allow residents to accept payment directly from their clients rather than their income having to pass through their supervisor.  This has been a major deterrent for supervisors who would otherwise supervise residents. Since residents must inform their clients and, in every instance, must note on all paperwork and advertising that they are a Resident in Counseling and under supervision, there is no question that the resident is an independent practitioner.

Then, let’s take into consideration one more need to maintain the integrity of the counseling profession: the Counseling Compact which only applies to LPCs across the U.S. This legislation has passed in 33 states to date.  It allows LPCs to request a privilege to practice in another jurisdiction…it does not apply to social workers.  This further differentiates the two licenses and supports maintaining the integrity of the professional counselor field of practice. 

In conclusion, there are better options than to dilute the integrity of our counseling field by allowing LCSWs to supervise LPC residents. I provide a 20-hour Clinical Supervision Training and have trained many supervisors since 2009, so I know they’re out there.  Let’s implement some of the suggestions to make it easier for LPCs to supervise residents rather than to bring LCSWs as supervisors back into the mix..

Sharon Watson, LPC, LMFT, LSATP, NCC, ACS
    Providing Virtual: Supervision, Supervision Consultation,
   Clinical Consultation, Clinical Supervision Trainer