I support this petition but only under very clear and limited circumstances with restrictions that would be clearly defined in the regulations and would only apply to counselors employed in exempt settings. At exempt agencies/organizations, counselors can be hired to work without a license.  After working for one of the Community Services Boards for 18 years, I know that it’s possible that someone could be hired as a counselor in an exempt setting who chooses not to pursue licensure because it’s not required by their job, but who might change their mind later.  If they have been supervised by an LPC or LMFT who is listed as an approved clinical supervisor on the Virginia Board of Counseling website (i.e. has met the requirements to supervise), if the counselors work hours (ancillary and direct) hours can be documented, if the supervision hours can be documented, and if the supervisor is willing to report these on a Verification of Supervision form, it would be reasonable that a portion of the 200 hours of supervision could be applied towards licensure (for example, 50 hours). Again, I’m suggesting this would only apply to exempt settings and not for counselors working in a private practice (either someone else’s practice or their own).  When considering this petition, it’s important to keep in mind that in Virginia, social work supervisees when fully licensed often have the same kind of clinical practices as do LPCs & LMFTs but are only required to have 100 hours of supervision over less total and direct time. It seems unlikely the SW Board will increase the required hours for licensure and based on the results of a recent petition, unlikely that the Counseling Board will reduce the required LPC/LMFT hours.  So, giving those working in an exempt setting a break on their requirements seems fair.