I strongly agree with the above petition to credit those who have been providing clinical services under supervision prior to the formal “resident” status. The need for clinical oversight, hours of face to face contacts, and years of practice is vastly different in a seasoned clinical professional than a new graduate. 
Additionally, not all who are eligible for residency to gain licensure are able as this may be costly, both to apply and to pay for ongoing supervision if not offered through employment. This barrier creates limitations for underprivileged populations and limits the much needed diversity of practitioners in the field. In order to promote equity and gain inclusion, considerations for change in rule making are necessary. 

I agree with the Petition and the comments made thus far.  Virginia licensure has a long reputation for stringent criteria, presumably because we want to ensure that those becoming licensed to help others are the cream of the crop.  I have worked with and around very talented & solid clinicians with years of supervised clinical experience who had not pursued licensure for one reason or another.  But people's minds and opportunities change.  An exception should be made to consider these hours/years of clinical work because they did happen.  The act of applying for a temporary license does not miraculously bring someone with little to no clinical experience into line with someone having 5+ years of it.  In this case,  the starting point for the experienced clinician is unnecessarily stringent, discouraging, and seems illogical.  

I support this petition. 

I agree with this petition for rule making. 

I fully support this petition. This isn’t about lowering or changing the criterion for the residency hours requirements. Instead it is about ensuring that all those who have met the Board’s criteria for supervised residency hours receive credit for doing so. The end result is more highly qualified LPCs serving clients in Virginia.

I agree with this petition.

When beginning the process toward licensure, my first supervisor told me completing the paperwork to get licensed was half the battle. The licensure process was daunting. Changes have been made to make the process easier and more obtainable. I support this petition for rulemaking. It makes sense that hours completed while working in the role of a professional counselor, under the supervision of a LPC would count toward the required 2,000 hours of face-to-face client contact. 

Supervision in general employment or training contexts is not equivalent to supervision toward licensure. Residency supervision is a Board-regulated process that requires supervisors to be vetted for qualifications, experience, and ethical standing before overseeing a resident. This distinction is critical because it ensures that candidates are trained under consistent, structured standards designed to prepare them for independent practice. Allowing hours completed outside this process would erode the integrity of the licensure pathway, as there would be no assurance that the supervision was provided by a qualified supervisor or aligned with the Board’s requirements.

The residency requirement is a deliberate safeguard to protect the public and maintain equity across all licensees. Supervision outside of the Board’s oversight lacks the same accountability and may not include necessary evaluation of competence, structured feedback, or adherence to ethical and professional standards. Granting exceptions would create inconsistencies in training, undermine the progression of licensure, and set a precedent for weakening regulatory requirements. The public trusts that licensed counselors in Virginia have undergone rigorous, Board-approved preparation, and preserving this trust depends on upholding established residency standards without exception.

Supervision in non-licensure contexts cannot be presumed to meet these standards. For these reasons, the petition to amend 18VAC115-20-52 should be denied.

I am trying to understand the comments in opposition from DH.  They state, “Supervision in general employment or training contexts is not equivalent to supervision toward licensure”.  I don’t see “supervision in general employment or training contexts” anywhere in this petition. I do see clinical supervision provided by a licensed clinician that meets the standards set by the Board. 

Also, is DH saying that a licensed clinician providing supervision wouldn’t do as good a job of supervising a clinician if the clinician wasn’t registered with the Board? Wouldn’t/shouldn’t they do their best with every clinician under their supervision? Again, just trying to understand these comments. 

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.

I think the Board should allow this, provided that the individual can document their supervised experience well, and gets a letter from their supervisor confirming the number of hours they completed. The number of hours that can be counted could also be limited. The spirit of the requirement for supervised hours is to ensure that Counselors are properly trained and prepared for independent practice. There is nothing magical about the resident license that makes their learning experience better, or more effectively preparatory, than experience they gain shortly before becoming a resident while under supervision.

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.

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.