I was on the Board of Counseling when we decided to remove LCSW from the list of supervisors.  The reason was that we were wanting to strengthen the professional identity of LPC's.  The Board of Social Work did not have LPC's supervising social work residents for the same reason.  When the LPC license started, social workers, nurses, etc were included on the list of supervisors because there were not enough LPC's to do the supervision, however, in the Commonwealth now there are several thousand LPC's.  Maybe there should effort to try to get more LPC's to supervise.  This was the same reason that the board was looking at the credentials of professors that were teaching students in the Master of Counseling programs.  The whole idea was to develop a distinct professional identity that is different from social worker and psychologists.   I am glad to see that the Board of Psychology is finally exploring having a master level license because this was a huge problem a decade ago, having MA in Psychology trying to become LPC's.  I was glad when the change was made 10 years ago to remove LCSW's from the list of supervisors and I think it should continue now.  

I completed my clinical training and residency in Virginia and wish to voice my support for the current petition. I believe there are an overabundance of benefits to making this change in the rules given the need for clinical mental health professionals and relevant training opportunities across disciplines. There is a great deal of overlap among the licensed mental health professions and the differences become even less pronounced once individuals enter formal post-degree practice. In fact, I believe the mental health professional is only strengthened when training, consultation, and supervision occur across professional parties. It is this level of us-them mentality that has created power struggles between professions for far too long (The APA lobbying against the NASW lobbying against the ACA, etc). The most recent approval of LPCs to accept Medicare is an indication that we are moving away from outdated license-specific lobbying efforts in the government and toward creating more ways for the general public to access care. While this specific petition is about supervision and not insurance reimbursement, I believe doing away with such unnecessary rules at this level in the clinical training sets up new professionals to have a more impactful multidisciplinary approach to mental health care. I do not believe it is under the purview of the board to ensure that counselors are being supervised by counselors for the purposes of "professional identity development." Such advocacy efforts should be left up to organizations such as the American Counseling Association which can help counselors connect with counselors, and, more importantly, assist those counselors in better serving those who need our help. 

LPCs supervise Residents in Counseling as a means to support and protect the unique identity of the profession.  Neither the Board of Psychology nor the Board of Social Work permits LPCs to supervise psychologists or social work residents for the same reason.  As a previous commenter noted, “When the LPC license started, social workers, nurses, etc were included on the list of supervisors because there were not enough LPC's to do the supervision, however, in the Commonwealth now there are several thousand LPC's.”   Counseling programs are completely separate from social work and psychology programs and while each of these professions borrows theories from the others, we each also have distinct professional identities. If there is a need for more supervisors, then there should be education offered to existing LPCs about the benefits of becoming trained to supervise and in providing supervision.

I am writing to express my support for the petition, however, I do have some concerns. While I agree that having more options for supervision and differing counseling backgrounds from which to draw clinical guidance from is needed, my expectation is that there would be reciprocity between the board of social work with regard to their supervisor requirements as well. As an LPC, I think this is a generally positive step to expanding opportunities for our residents to gain experience, but i hope that it’s not at the expense of finding ways to encourage current LPC’s to become supervisors and strengthening our professional identity through a robust and engaged Board of Counseling. 

Candidates for licensure as licensed professional counselors should have supervision options expanded beyond just other licensed professional counselors.  Both licensed clinical social workers and clinical psychologists should be able to provide appropriate supervision.

Supervision options for candidates aspiring to be licensed professional counselors should be expanded beyond the scope of licensed professional counselors alone. Both licensed clinical social workers and clinical psychologists should be able to provide appropriate supervision. This would allow for a diverse range of professional perspectives and knowledge bases to be incorporated into the supervision process, promoting a more well-rounded approach to counseling education and training.

Supervision options for candidates aspiring to be licensed professional counselors should be expanded beyond the scope of licensed professional counselors alone. Both licensed clinical social workers and clinical psychologists should be able to provide appropriate supervision. This would allow for a diverse range of professional perspectives and knowledge bases to be incorporated into the supervision process, promoting a more well-rounded approach to counseling education and training. Our communities need more professionals who can provide supervision, and this would help address that gap. 

I want to start off by stating that I know, and have worked with, a number of extremely talented Clinical Social Workers. My experience with them began as I was completing my Internship during my Master's degree in Counseling. I learned a ton from them, including things about case management that I believe I would not have had a chance to learn otherwise. They were all well qualified, as all LCSWs must have 60+ hour Master’s degrees, pass a licensure exam, and have years of post-degree experience in order to become licensed. 

Some commenters here may express that LCSW supervision is not “needed” because there are enough LPCs to supervise all LPC Residents in Virginia. Personally, I do not see this argument as convincing for two reasons: First, I am unconvinced that all LPC Residents are able to find supervision so easily. There are rural areas of Virginia where there are not many LPCs, but perhaps there is an LCSW in the area. Even with online supervision, not everyone wants to be supervised online from someone outside of the practice where they work. Personally I would rather be supervised in person by an LCSW I work with than an LPC halfway across the state on Zoom. If you feel differently feel free to make that choice for yourself, but it should be a choice. Second, even when there are LPCs who can provide supervision, there may be LCSWs who have special training that a Resident is interested in. Counseling claims case management as part of our scope of practice, and who better to learn it from than an LCSW? Perhaps you want to learn TF-CBT, EMDR, or some other specific modality and there just happens to be an LCSW in your area who specializes in that. Why not allow a Resident to pursue their career with that training if they want? I do not see this matter as a question about whether supervision by Social Workers is “needed” - I think it can be desirable in certain circumstances.

In an era where different mental health disciplines are working on compacts to work across state lines, trying to improve access to mental healthcare, and trying to increase the number of educational programs producing our graduates, I think it is crucial to acknowledge that the Board's recent decision to stop allowing hours supervised by LCSWs to count towards licensure has impaired licensure portability. There are many cases of individuals, who are licensed as Counselors in other states, lamenting online that none of their supervised hours in their home state were accepted by our Board due to their hours having been supervised by an LCSW. These are fully licensed individuals who have been practicing in their home states for years (where these hours were accepted) who moved to Virginia wanting to serve our population’s mental healthcare needs. Yet, they have to start over. 

On a similar note I believe it was only in 2019 that the Board decided to stop allowing LCSWs to supervise Residents in Counseling in Virginia. Are we to believe that all of the Counselors supervised by LCSWs before 2019 were somehow not properly trained, or lacked an identity? Many of those Counselors practice competently today. 

On the subject of Counselor Identity, I would point out that Virginia already requires appropriate Counseling coursework to have been completed for Licensure, as well as a Master’s degree, and adherence to the regulations of this Board. This protects Counseling’s identity, licensure status, and scope of practice. Residents in Counseling who are supervised by LCSWs will still be LPCs with appropriate Master's degrees who have to adhere to the rules of our profession.

I encourage other Counselors, and the Board of Counseling, to consider several options and compromises for how this measure might be implemented. For example, many states allow Residents in Counseling to receive at least a portion of their hours under supervision of a Social Worker. Although I see no issue with allowing LCSWs to supervise in general, we could at least allow up to half of a Resident in Counseling's hours to be under the supervision of an LCSW. In addition, the Board might consider limiting LCSW supervision of Residents in Counseling to only those LCSWs who have a certain amount of experience - for example a Doctoral degree in their field, or three years post-licensure experience. That’s just an example, but would ensure they have far more experience in practice than the Resident they would be supervising.

Finally, I understand the desire for the Board of Social Work to reciprocate and allow their own supervisees to be supervised by LPCs. I agree, and even commented on a similar petition to their Board saying I felt LPCs should be able to supervise Social Workers who are accruing hours towards their license. I also feel that, when the Board of Psychology begins to have Master’s-level practitioners, they should also be able to be supervised by LPCs and LCSWs, and I have contacted legislators to that effect. However, even if these other disciplines do not comply with these wishes, I do not think the answer is to take our ball and go home in reaction, denying our Residents the opportunity to be supervised by an LCSW if they so wish. Instead, allow LCSWs to provide at least some supervision for LPC Residents, and continue reaching out to these other professions in good faith. Advocate for interprofessionalism instead of reacting and driving our disciplines apart. In the midst of an opioid epidemic, a mental health crisis, and rising political division our clients need us to work together and do the right thing. Thank you for considering my thoughts.

The range of supervision options for aspiring licensed professional counselors should extend beyond solely licensed professional counselors. Both licensed clinical social workers and clinical psychologists should be eligible to provide supervision, facilitating a diverse array of professional perspectives and knowledge bases. This broader approach to supervision would enhance counseling education and training by incorporating a wider spectrum of expertise.

I am writing to support the expansion of professionals who are able to supervise prospective LPCs to inclusion LCSWs. 

I am writing to support the expansion of Licensed Clinical Social Workers to provide clinical supervision to counseling residents. 

Several of the other comments on this petition explain that The Board of Counseling originally excluded LCSW’s due to wanting to keep professional counseling as a separate professional identity. 

I would urge The Board to carefully consider this question: What is more important now in 2024? Is it more important that Professional Counselors work towards setting ourselves apart as a profession, as it was in the past? Or should we open up the path for more supervisor options so residents will encounter less barriers when attempting to get licensed in Virginia, a state that already has notoriously rigorous licensing standards? 

While there are certainly more LPC supervisors now, counseling residency in Virginia is still made exponentially more difficult because of the supervisory limitations that are currently in place. In a time where competent mental health professionals are needed more than ever, consider how these roadblocks to LPC licensure impact not only residents but our communities at large. 

LPCs and LCSWs share most theories, philosophies, ethics, and best practices, and they share many careers and workplaces. Allowing an LCSW to supervise an LPC resident and vice versa would greatly expand collaboration between the professions and the professional options for these two greatly short staffed professions. 

If we are going to have LCSWs supervise residents in counseling, why don't we just nix the LPC track and have us all become LCSWs? I understand in the past RNs and LCSWs were able to supervise residents in counseling. as an RN who is fully aware of the lack of mental health education in nursing school, this is horrifying. LCSWs are a wonderful and needed part of the mental health system, as a jack-of-all-trades. LPCs are the only license that focuses solely on counseling. There are thousands of licensed counselors in the state of Virginia. Why do we not instead incentivize LPCs to become supervisors? I have supervised residents before and it is a hefty undertaking, with minimal-to-no support from the board. I have asked clarifying questions via email before regarding my role, and gotten vague and unhelpful responses in return. Residents are working under my license, I am dedicating time each week to supervision, and while I did it because my job at the time asked me to, there was little I got in return except personal satisfaction in helping my residents to get their hours and increase their knowledge. Why not subsidize stipends for LPC supervisors, so that residents do not have to pay? Provide a more formalized (but optional) free supervision workbook that can be utilized? There are plenty of other alternatives besides letting a completely different degree/license supervise LPC residents.

I believe the following is excellent except the date limitation and the exclusion of psychiatrists as an option.  If other disciplines don't allow LPC.LMFT supervision, that's their limitation.  It doesn't have to be ours. 
Current Code:  "At least 100 hours of the supervision shall be rendered by a licensed professional counselor. Supervisors who are substance abuse treatment practitioners, school psychologists, clinical psychologists, clinical social workers, or psychiatrists and have been approved to provide supervision may continue to do so until August 24, 2017."

I am in support of allowing other licensed clinical providers to supervise LPC. Supervision should be expanded beyond the practice of licensed professional counselors alone. LPC has a defined professional identity that has not been hindered in the past by LCSW's providing supervision. In some areas there are more available LCSW professionals than LPC and persons suffer when they cannot get supervision or have to go a greater distance to receive supervision. Even at some state agencies you have more LCSW than LPC and that hinders and is time consuming with persons being able to get supervision in a timely manner. This would also allow for a diverse range of professional perspectives and knowledge bases to be incorporated into the supervision process. This promotes a well-rounded approach to counseling education and training. We need more professionals and that should be the goal. 

I am a recent LPC licensee.  During my residency period I worked under the additional tutelage of an LCSW while also being supervised by my assigned LPC supervisor. I feel I gained valuable knowledge by being able to discuss things with the LCSW provider. The two credentials share similarities, and one would wonder why the opportunity for valuable insight, additional perspectives, and shared growth would be actively stunted. The various mental health field credentials seem to be engaged in a tit for tat spat of trying to slight one another or hinder the progression of candidates in one credential over another. More supervisors offer more opportunities for learning and professional growth. I can't see a downside to this potential. 

I am in agreement with Dr. Curry's petition. Both licensed individuals should be able to provide the required hours of supervision whether it is supervising someone who is working towards their LPC or LCSW. This should not be about semantics. This issue should be about providing knowledge and guidance to individuals that want to make a change in their community. There is a shortage of competent clinicians as it is, I have patients complaining that they have had to wait up to six months to be seen due to the shortage of providers in the area. Again, this topic shouldn't have to be about which license is more valuable or not. The goal is to help and if that allows providers of different backgrounds to become licensed in a timely manner so that they can then help the community should this really be an issue?

Allowing LCSWs to supervise LPC licensing candidates can foster greater collaboration between the behavioral health disciplines.

In order to protect vulnerable citizens, it's imperative that counselors-in-training be supervised by licensed professionals that fall under the auspices of the Board of Counseling.  Certainly, exposure to other branches of the mental health field is beneficial to the Resident in Counseling but those other licensees (social work, psychology, medical doctors, nurses, etd) report to their own respective Boards.  If the Board of Counseling is to provide oversight in the process of licensing of Counselors, it needs to have authority over supervisors of those Counselors.  The day may come when all the mental health specialties merge under one Board but that's not the state of things now.

First of all, thanks for considering the changes for residency. The Boards proposal would prevent burnout and compassion fatigue if the residency hours were reduced to 3000; 1500 face to face. Kindly

Counselors-in-training must receive supervision from professionals within their own respective field to maintain fidelity to disciplinary standards and practices for which they are seeking licensure. The ethical requirement under our professional code of ethics, which the VA Board of Counseling adopted in 2010, mandates gatekeeping and remediation for supervisors and counselor educators (ACA Code of Ethics, 2014, F.6.b.). While other related helping professions (e.g., social work) do not include this mandate within their ethical guidelines, they do refrain from authorizing LPCs to supervise residents. Allowing cross-disciplinary supervision risks diluting this distinct ethical guideline and counselor identity, potentially affecting the competency and preparedness of aspiring counselors. Additionally, intermixing supervision across disparate disciplines could lead to confusion regarding ethical standards, potentially jeopardizing client welfare. Therefore, to safeguard the quality of counseling training in Virginia, maintaining supervision requirements specific to the counseling profession is imperative to ensure our professional standards and counseling ethics are maintained and to protect future clients with whom these aspiring counselors will independently work in the future.

As every branch of the Behavioral Sciences is specialized, it is vital that supervision of Residents who are seeking to obtain a Professional Counselor license, remain with Licensed Professional Counselor Supervisors during their residency.

While an LPC and LPSW may have things in common, they are distinctively different in methods as well as populations served. Please do not alter the current guidelines which require each profession to supervise and guide their own Residents. 

Respectfully,

Dr. Cynthia Doney

Because other states require that LPCs be supervised by LPCs who hold specific qualifications, as set forth in states' licensing rules/codes, how might VA's change of this license rule have a detrimental effect on the soon-opening Counseling Compact? 

Residency supervision is a critical time for counselor identity development. A large part of the supervision process involves mentoring and conversations around advocacy and professional roles. For this reason, it is important that the mentor in the relationship share the same professional identity. While I value interdisciplinary collaboration very much, that will inevitably happen on treatment teams and in the work place. Those conversations will be useful - and having a supervisor from the same discipline to discuss them with is the best case scenario. Psychology and Social Work do not allow Counselors to supervise entry level professionals for these same reasons.

It is not a sign of anything beyond a desire for these young professionals to be clear about who they are as a part of a distinct profession. Being clear about professional identity allows us to bring our different strengths and skills together as working professionals.

There is a reason why we are distinct professions with different requirements for training and licensure. 

It is not apparent how this amendment is to the benefit of the counseling profession. This change would allow individuals who have not had the same educational preparation (such as those outlined by CACREP standards), who do not adhere to the same Code of Ethics, who share a different professional identity, and are governed by a different board to supervise emerging counselors during a period where they receive some of their earliest and most practical experiences. Their supervision should be done by experienced counselors as that is what residents-in-counseling are preparing to be.

If the concern is a lack of LPC supervisors for residents-in-counseling, this amendment only seems to further desensitize individuals from pursuing a career in supervision through counseling as they could now do that as an LCSW.

The observable fact that comments on the parallel petition regarding LPCs to be allowed to supervise social workers (linked below) express near universal opposition should provide further evidence that LCSWs see themselves as distinct from LPCs, and that this change serves to benefit LCSW supervisors at the expense of the counseling profession.
https://www.townhall.virginia.gov/L/Comments.cfm?petitionid=402

The Board of Counseling has worked diligently to define the LPC as a profession. This includes overseeing clinical supervision for licensure. Previous regulations eliminated the practice that allowed other licensed professionals to supervise LPCs, to maintain the identity, relevance, and quality of supervision. As an LMFT, I supervise LPC and LMFT Residents for licensure. Even so, I can provide only half of the hours an LPC needs for licensure. This ensures the integrity of the supervision and the profession. I would object strongly  to LCSWs supervising any LMFT Residents, as it also a singular, distinct profession. I object strongly to this proposal.

The various helping professions each have their scope of practice (not to mention philosophies, approaches, regulatory and accreditation boards, etc.) and thus warrant supervision solely by those within their own profession. Should social workers gain supervisory rights over professional counselors, would the reciprocal be similar (professional counselors supervising social workers)? And then we could loop psychologists and psychiatrists into the mix and allow all helping professions to supervise one another…It’s a really bad idea for any and all of the helping professions. 

This proposed amendment should be rejected because these are distinct professions involving different theoretical bases and different intervention strategies. An examination of required training will clearly reveal this.  For details about how drastically different the training requirements are, see pages 7-9 of the accreditation requirements for social workers at https://www.cswe.org/getattachment/Accreditation/Accreditation-Process/2015-EPAS/2015EPAS_Web_FINAL.pdf and see pages 12-22 of the accreditation requirements for clinical mental health counselors at https://www.cacrep.org/wp-content/uploads/2023/06/2024-Standards-Combined-Version-6.27.23.pdf.

One of the challenges of the Counseling profession has been to establish a strong professional identity. The profession took a huge step towards that goal by limiting supervision hours for licensure to only LPCs. Allowing this proposal to pass would set the profession back in a way that would be difficult to ever recover from. 

For folx arguing that we need to be interdisciplinary--NO WE DON'T! At least not in this area as we would be shooting our professional identity in the foot. There is nothing that precludes interdisciplinary work in the mental health profession, it's just that supervision hours can't count towards licensure. That's a rule that the LCSWs and LCP follow, so what's good for the goose must also be good for the gander. 

I do NOT support this proposed legislation.

I noticed another commenter here claiming that "SW Supervision of LPC" would contradict the Counseling Compact. As such, I decided to actually reach out to the Executive Director of the Counseling Compact Commission to ask for clarity about this issue. Although I do not want to get into a back and forth in these comments, I think that this information is relevant for others to know so I wanted to share it. Although I can not attach a picture of that email here, I do have permission to share the information.

The Executive Director confirmed that the Counseling Compact has no rule against individuals in other professions being able to supervise Counselors towards licensure as long as it is allowed by the state they are licensed in. He also noted that it is common practice in many states to allow for at least some supervision to be provided by professionals in other disciplines. The text of the email was as follows:

"William,

Accessing high quality supervision in residency continues to be challenging for LPC residents.

Allowing for a percentage of supervised hours to be done by closely-related interdisciplinary professionals may increase access, therefore expanding workforce development across the commonwealth. An increase in well-trained LPCs in the commonwealth benefits all stakeholders.

If LPC residents could seek supervision from LCSW’s for, say, 25% of their total supervised hours, that would greatly help facilitate the number of residents able to earn their LPC’s in a reasonable amount of time. This would be 50 hours of supervision out of the total 200 required for residency.

I would also suggest that reciprocity should be allowed and LPCs should be able to supervisor LCSWs for a portion of their necessary hours.

The benefits would be increased access to supervisors and perhaps a less logistical barriers to obtaining a license. 

Perhaps we also need to focus on the quality of supervision being offered as well. Supervision from a poorly trained supervisor is detrimental, regardless of the specific type of license. Conversely, supervision from a person providing high quality supervision reduces burnout, promotes ethical practice, and elevates effective clinical treatment. 

If this motion were to pass, it might be also important for the Board to expect LCSW’s to have the same 20 hours of supervision training as LPCs. (right now that total is only 14).

As a field, we should consider – how do we promote access through more available supervisors offering high quality supervision??

More options for clinical supervision is a good thing -- we have a severe shortage of mental health professionals in this state. 

Dear Virginia State Board of Counseling:

On behalf of Chi Sigma Iota Counseling Academic & Professional Honor Society International (CSI), we are writing to you to express our views on the proposed amendment to requirements for supervisors to include licensed clinical social workers. As the international honor society for professional counselors, many of our members are current or future Licensed Professional Counselors (LPCs), and we are dedicated to preserving the professional counselor identity of LPCs. CSI has 19 chapters in the state of Virginia.

CSI strongly opposes this proposed amendment. Only professional counselors should supervise counselors-in-training because this is critical to protecting the unique identity of the counseling profession, including its unique teachings and theories. For the same reason, neither the Board of Psychology nor the Board of Social Work permits LPCs to supervise future psychologists or social workers. Likewise, we believe that future LPCs should be supervised by experienced members of their own profession.

If you have any questions or would like to discuss this matter in detail with LPCs practicing in Virginia, we encourage you to reach out to CSI’s CEO Dr. Holly Hartwig Moorhead at holly.moorhead@csi-net.org.

Sincerely,

The Chi Sigma Iota Executive Council

The Chi Sigma Iota Leadership & Professional Advocacy Committee

As a current student working towards licensure and completing a master’s program in Clinical Mental health, it is evident there are differences in educational focus and training between clinical mental health and social work. LPC training focuses more on individual psychological processes and interventions creating personal change, while social work training tends to focus on social and environmental factors.  The differences in level of depth would not allow sufficient supervision for LCSW’s working with current and incoming LPCs. Additionally, what will be the measure of competency in supervision, if this becomes reciprocal with other helping professions? This proposal would blur the lines of ethical boundaries and limitations of supervisory roles and the ability to ensure effective training for helping professions within their specific fields.

Please consider this letter, on behalf of the faculty at the Old Dominion University Counseling Program

Dear Virginia Board of Counseling:

The faculty in the ODU Counseling Program strongly oppose the proposed change of having LCSW’s eligible for the supervision of counseling residents. It is critical that LPCs supervise counselors in order to maintain and advance counselors’ unique professional identity. This is not just hyperbole, as the coursework between master’s level social workers and master’s level counselors varies dramatically.

Despite the fact that both master’s degree counselors and social workers both work intensively with individuals, couples, and families with mental health disorders and problems, their training differs dramatically. Let me delineate.

• Whereas a counseling program has a spiral curriculum, that reinforces critical skills and culminates in practicum and internship, social work program immerses students into clinical settings early, with little content knowledge, hoping the students learn along the way through supervision.

• Counseling programs are unique in their training of micro counseling skills, which ensures clinical expertise early in their program. Social work programs do not have this as a mainstay approach and a supervisor would not be able to reinforce some of those skills.

• Coursework in counseling is different than in social work programs, as per their accreditation programs. For instance, counseling programs must offer course content in assessment, career counseling, counseling theory, human development, a “growth group” experience, and other practices that social workers are not required to be take.

• The scope and focus of supervised clinical training, as well as supervision training in counseling programs, is different than what is taught in social work programs.

• Professional identity, especially relevant to history, approach to clients, and most importantly ethics, is different (see the ACA and NASW ethics code). A social worker supervisor does not know the history of counseling, the practice of counseling, or its ethical code.

There are also many other differences, but in short, the nine social work competencies vary dramatically from CACREP’s eight core content areas. See the table below.

If not familiar with the breakdown of these competencies within counseling and social work, I urge you to review the standards of both degrees and I am confident you will find major differences in these common-core standards. In addition, counseling programs also require specific standards in clinical mental health counseling which I am sure social work supervisors know little or nothing about. To have a social worker supervise a counselor, does little to reinforce the existing, and important, content knowledge and professional identity of the counselor.

Due to these differences, I encourage the board to not allow LCSWs to supervisor counselors in residence.

Sincerely,

Ed Neukrug, Ed.D., LPC, Endowed Chair of Counseling

Professor of Counseling and CACREP Coordinator

Old Dominion University

As a licensed professional counselor and a counselor educator, I am strongly opposed to this petition as this could dilute the unique professional identity that is of a counselor. Cross profession supervision, should not be permitted as it could do harm to the counseling profession. LCSW and LPC do not undergo the same training nor do they hold the same identity. 

Dear Virginia LPC Board,

As someone who was initially licensed in Virginia and continues to maintain my licensure, I firmly oppose this proposed amendment. I believe that professional counselors should be responsible for supervising counselors-in-training because this is critical to protecting the unique identity of the counseling profession, including its unique teachings and theories. I also recognize that neither the Board of Psychology nor the Board of Social Work permits LPCs to supervise future psychologists or social workers - why is this the case? Since this is not a bidirectional relationship/expectations with other mental health professionals in Virginia, I strongly believe that future LPCs should be supervised by experienced members of our own profession. 

I hope you will reject this proposal and any such proposals that might emerge in the future. 

Thank you, Dr. Harrichand, LPC-S

No, this is not a good idea, and as a practicing professional in Virginia, I do not believe this amendment is wise toward the supervision of aspiring counselors. Social workers and counselors, although their efforts and goals share some similarities, are not trained in the same way, nor do the end results compare. For those overseeing this petition, please respect the nature of the counselor's work and have aspiring counselors train with those supervised in counseling to do so. 

Hello,

I am writing to express my views on the proposed amendment to supervisory requirements to include licensed clinical social workers. 

I oppose this proposed amendment. Only professional counselors should supervise residents-in-counseling because this is critical to protecting the unique identity of the counseling profession. For the same reason, neither Boards of Psychology or Social Work permit LPCs to supervise future psychologists or social workers. Likewise, experienced members of the counseling profession should supervise residents. 

Sincerely,

Emily Chew

This proposed amendment is only going to decrease efficacy towards the profession of counseling and a failure of proper training can result in serious public health consequences. Please keep the counseling profession held to a proper standard and reject this petition as it can cause serious harm. 

With unequivocal conviction,

Philip Saphos

Only professional counselors should supervise counselors-in-training because this is necessary to protect the unique identity of the counseling profession, including its unique teachings and theories. For the same reason, neither the Board of Psychology nor the Board of Social Work permits LPCs to supervise future psychologists or social workers. Likewise, we believe that future LPCs should be supervised by experienced members of their own profession.

To the Commonwealth of Virginia Board of Professional Counseling:

I write as a Virginia LPC to express my concern about the proposed change to supervisor requirements for counselors-in-training and residents (i.e., new professionals) and urge the Board to reject this proposal. Qualified LPC supervisors must have a deep understanding of the counseling profession's unique philosophical views and ethical standards.

Ethical standards in counseling guide our professional practice and ensure the welfare and dignity of those with whom LPCs journey (§A.1.a, 2014 ACA Code of Ethics). Supervisors must deeply understand these standards to guide new professionals effectively, and many of these standards are unique to professional counselors. This level of understanding is best found within our profession, ensuring that supervisors are well-versed in the specific ethics and challenges we face.

Additionally, the 2014 ACA Code of Ethics mandates gatekeeping and remediation for supervisors and counselor educators (§F.6.b.). This accepted standard of care would not apply to practitioners from other disciplines, such as social work.

The proposed amendment could dilute the quality of supervision and, by extension, impede required continuing professional development of future counselors. Supervision is a specialized intervention that focuses on embedding an ethical framework in the next generation of practitioners. Only those fully immersed in the counseling field can ensure this critical aspect of training is met.

Rejecting this proposal does not reject the value of interdisciplinary consultation or collaboration. Rather, rejecting this proposal strengthens professional counseling, and protects the citizens of the Commonwealth by fostering ethical counseling.

Restricting the supervision of counselors-in-training and residents (i.e., new professionals) is crucial for upholding our standards and the integrity of our work. Please consider other measures to recruit more qualified LPC supervisors, rather than simply extending privileges to practitioners from other professions.

John Duggan, EdD, LPC, LSATP

I strongly oppose this proposed amendment.  As a counselor educator, supervisor, and LPC,  I believe it would be a very poor decision to include LCSWs as supervisors.  Developmentally,  counselors-in-training are still solidifying their professional identity and need the mentorship of LPC.  While I support residents being collaborative with colleagues across disciplines in their work (and there will be plenty of opportunity), an LPC can help help the resident navigate the differences that abound.  As a counselor educator I have seen the challenges and confusion students can experience in their practicum and internship  when working under an LCSW site supervisor, even in understanding of clinical skills.  In this context, the counselor-in-training also has the faculty supervisor (LPC) for support and direction.  This is just as important in residency.   Overall, here is importance in maintaining consistency in the training established through the MA programs and CACREP; social work is distinctly different and does not represent the same framework and focus.  

The counseling profession is unique, including its philosophy and teachings. For the same reason, neither the Board of Psychology nor the Board of Social Work permits LPCs to supervise future psychologists or social workers. Likewise, we believe that future LPCs should be supervised by experienced members of their own profession.

Sincerely, 

Rhonda Ladd, PhD, LPC

Reject this proposal 

If licensed social workers are be allowed to provide supervision for LPC, then licensed psychologists should also. Both provide counseling. I cannot imagine that a licensed social worker would be approved to supervise but not licensed psychologists.  What would be the rationale for that? I would say either both or none.  We are supposed to be doing what makes sense, not what doesn't make sense! I agree that registered nurses and substance use counselors do not have the level of mental health education that licensed professional counselors, licensed social workers, and licensed psychologists have and they have not received the level of supervision and licensure themselves that would truly qualify them to provide adequate supervision for LPC residents.

It would be up to the LPC resident to know other states requirements for supervision.  There seems to be a shortage of LPC supervisors. Realistically, allowing licensed psychologists and licensed social workers to supervise LPC residents, would promote growth of the counseling profession.

I oppose this amendment.

As a seasoned counselor educator for four decades and a member of Chi Sigma Iota, I do not agree that Social Workers should supervise counselors. LPC needs to supervise counselors. LPC cannot cross the line to supervise social workers so you need to reconsider this and leave counselors to supervise counselors. We have the training expertise and experience to do just this. Do not cross the professional line. Social Workers are not professional counselors  Reconsider this and please back off on this 

Thank you

Dr Mary Olufunmilayo Adekson 

Faith Diversity Consulting

Virginia

Dear Virginia State Board of Counseling:

On behalf of Chi Sigma Iota Counseling Academic & Professional Honor Society International (CSI), we are writing to you to express our views on the proposed amendment to requirements for supervisors to include licensed clinical social workers. As the international honor society for professional counselors, many of our members are current or future Licensed Professional Counselors (LPCs), and we are dedicated to preserving the professional counselor identity of LPCs. CSI has 19 chapters in the state of Virginia.

CSI strongly opposes this proposed amendment. Only professional counselors should supervise counselors-in-training because this is critical to protecting the unique identity of the counseling profession, including its unique teachings and theories. For the same reason, neither the Board of Psychology nor the Board of Social Work permits LPCs to supervise future psychologists or social workers. Likewise, we believe that future LPCs should be supervised by experienced members of their own profession.