I oppose this petition as currently written - it's too vague. It doesn't state the circumstances under which one would even be providing clinical counseling services. It would leave a huge loophole that could be abused by a future not-yet-resident-person or their employer. Is this referring to QMHPs? People waiting to continue their residency where they did their internship? 

Even if the circumstances are legitimate and properly specified, it should have a cap on the hours - similar to the rollover hours from internship. Otherwise, an individual could conceivably complete a large portion of their hours for licensure without even being under the oversight of board of counseling. 

I do agree with those who have noted the much more stringent requirements for LPCs compared to social workers, and don't begrudge there being a way of making the process easier for a resident in counseling while still making sure there's proper supervision. It's simply that the petition should not be moved forward unless the circumstances are fully fleshed out.