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]

5 comments

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6/26/19  6:53 pm
Commenter: Dr. Suzan Thompson

Disagree
 

I completely disagree with this proposal! Most doctoral students have very little clinical experience already, so to permit them to supervise with even less than is required (2 years is not much time all-in-all!) would not serve our profession nor Residents. Although doctoral students MAY have more supervision training, that training MUST be accompanied with significant clinical experience to understand the depth and capacity of the counseling process. 

CommentID: 72760
 

6/28/19  6:26 pm
Commenter: Laura Fisher, LMFT

Opposed
 

I oppose this petition, despite residing in rural Southwest Virginia, near Virginia Tech's Ph.D. MFT program, which would allow a greater number of licensing supervisors for this area.

This petition places the value of education far above clinical experience. Despite the necessity of both to be successful and effective in this field, both as a counselor and supervisor. While additional education can be beneficial, the amount of time served in obtaining a doctoral degree does not make up for a lack of clinical experience. Clinical experience cannot be taught.

Allowing these individuals to supervise others without having at least 2 years of post-licensure clinical experience themselves is setting up a failing system for future counselors and therapists. Across the country, Virginia has a reputation for its high standards and I do not want to see that reputation diminished through selectively decreasing the amount of clinical experience necessary for some to supervise others.

CommentID: 72778
 

7/11/19  1:57 pm
Commenter: Cynthia Miller

Oppose
 

I am opposed to this petition.  The possession of a doctoral degree does not automatically prepare one to supervise someone for licensure.  Many doctoral programs allow students to go directly from their master's degree to a doctoral degree without having to acquire a license to practice.  While a doctoral program may require another internship, it is quite possible for someone to receive a doctoral degree having only had around 1200 hours of experience - with far less than 1,000 hours of direct service to clients.  Moreover, at the doctoral level the internship may involve more teaching and supervision of practicum students than actual clinical work.  This is not sufficient experience to begin providing supervision for licensure.

There is no substitute for experience when it comes to providing supervision for licensure.  A supervisor needs to have worked with many clients facing many different issues and preferably in multiple settings before being ready to supervise someone for licensure.  I believe the requirement that someone have at least two years of post-licensure, independent practice is a good minimum standard to become a supervisor for licensure and should not be watered down.

 

CommentID: 73512
 

7/12/19  5:14 pm
Commenter: Lynne Jonson

Opposed
 

     I also live in southern Va where qualified licensed professionals are not readily found. However I found that in my supervised 2 years of experience was essential in fully understanding the responsibility of practice and developed my clinical skills.                                  In my local area we have varied level of skills, education and abilities with QMHPs. I face daily challenges with QMHPs failing to continuing education/knowledge requirements as a direct result of lack of mandated  continuing education and they are not bound by a code of ethics to practice. I mention this as an example of the potential clinical level of experience most doctoral candidates have. Without practical experience the "practice" of our profession is based in real practice with a working knowledge of a code of ethics-ethics and legal requirements are not theory. 

 

CommentID: 73524
 

7/12/19  5:17 pm
Commenter: Lynne Jonson

Opposed
 

I also live in southern Va where qualified licensed professionals are not readily found. However, my supervised 2 years of experience was essential in my fully understanding the responsibility of practice and developed my clinical skills. 

I find varied level of skills, education and abilities with QMHPs. I face daily challenges with QMHPs failing to continuing education/knowledge requirements as a direct result of lack of mandated continuing education and they are not bound by a code of ethics to practice. I mention this as an example of the potential clinical level of experience most doctoral candidates have. Without practical experience the "practice" of our profession is based in real practice with a working knowledge of a code of ethics-ethics and legal requirements are not theory. 

 

CommentID: 73525