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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9/1/25  2:29 pm
Commenter: Patricia Parham, Ph.D., LCP

In support of petition
 

Another respondent to this petition stated “supervision in general employment or training contexts is not  equivalent to supervision toward licensure.”  I do not agree that this can be assumed true across the board, particularly with regard to supervision provided during employment. The specific employer or agency, the nature of the individual’s clinical duties, and qualifications of the supervisor(s) are important determinants in the quality of supervision that should not be discounted. If it is incumbent upon the LPC applicant to provide documentation demonstrating that their on-the-job supervision meets the Board’s standards, these applications should be considered.  Two thousand hours is a very stringent requirement, and given the shortage of mental health professionals in the state we need to be focused on supporting pathways to licensure rather than maintaining obstacles.

CommentID: 237081