I do not agree with getting rid of the 20 hours of supervision that can count towards licensure during internship. If the board wants to stop counting this 20 hours of supervision, I recommend they reduce the total required supervision to 180, or further reduce it to 100 to reflect the requirements that the board of social work has and make those align. When we have a shortage of counselors, I'm not sure why the state would want to potentially add 20 more weeks of supervision to someone's residency. I also don't understand how we're calling this a reduction of residency requirements but also possibly adding twenty more weeks of supervision. 

While the revisions are described as a “reduction” in total hours, they actually increase the supervision requirement by removing the ability to count the 20 hours of internship supervision toward the 200-hour residency supervision total. In practice, this change adds additional supervision hours — and therefore additional cost and time — to the licensure process. Most residents pay for supervision out of pocket, and the removal of these internship hours would increase both financial burden and the duration of residency, despite the stated goal of reducing barriers to licensure. Internship supervision is already provided under close oversight from qualified supervisors and academic programs. Those hours represent legitimate, structured supervision that directly contributes to a resident’s professional development. Excluding them diminishes the value of accredited internship training and creates an unnecessary redundancy in supervision. This proposed change would disproportionately affect new graduates, lower-income residents, and those working in rural or underserved areas, where finding and affording qualified supervisors is already challenging. It also risks discouraging new professionals from entering the counseling field at a time when access to mental health care in Virginia is critically needed.

I respectfully urge the Board to reconsider this portion of the proposal and to continue allowing the 20 hours of internship supervision to count toward the 200-hour residency requirement. Maintaining this provision would support new professionals, uphold training quality, and better align with the stated intent to streamline and modernize the licensure process.

I do not agree with not letting individuals utilize the 20 hours of supervision that counts towards licensure. I find it very confusing that the board of social work only requires 100 supervision hours and the Board of Counseling requires 200 and potentially 20 more hours? I am genuinely not understanding this desire within the Board of Counseling as the Board of Social Work says that with 100 hours of supervision a resident is able to meet requirements to be fully licensed. LCSW's are able to be counselor's just as LPC's are, yet the requirements for LPC's including overall required direct and in-direct hours are significantly higher. With this in mind, I do not see why the board would present this as a reduction in hours for supervision, yet it is actually an increase of hours. I want to be transparent in saying that I fear a lot of individuals seeking LPC licensure in regards to their future career will switch their desires from becoming an LPC. With that being said, I would not want this to happen, especially as the need for more counselors within our society is fast growing. This change, including not having the same requirements as the Board of Social Work, will significantly impact the mental health field and the needs of residents within the state of Virginia seeking mental health treatment. 

I do not agree with the plan to not count 20 hours from supervision during internship towards the total hours needed to become an LPC. If you were to do this, then the total number of required supervision hours should be reduced to 180. The Board of Counseling already makes it more difficult to obtain licensure compared to Board of Social Work requirements. I am finding more people want to pursue their MSW instead of the counseling tract. I think this will be detrimental to the field of counseling.

The requirements for licensure for counseling is already high in comparison to required hours for social work licensure. The hours required are already an obstacle for individuals looking to obtain licensure in the field. Individuals seeking counseling licensure who may be already facing financial obstacles when paying for their education in the field are required to work many hours without pay in order to obtain their licensure. The increase in hours required will only further increase the strain, deterring them from trying to obtain their counseling licensure. Mental Health services are such a huge need nationwide. Continuing to increase access to mental health services should be top priority.  Creating additional obstacles, such as increasing hours for licensure, will only decrease the individuals who will pursue a career path in counseling. In turn, this decreases available services to residents in the state of VA seeking mental health assistance. In order to continue to encourage LPC's, I suggest continuing to allow the 20 supervision hours to count towards licensure. Reducing obstacles for licensure will increase access to mental health services. 

For people paying for the residency supervision, this could add a huge cost increase to how much they're having to pay towards getting their license. 

I am asking the Board to consider the mathematical impact of removing the indirect or ancillary hours from the computation of hours ratio of supervision per clinical experience. I recommend new parameters of supervision per direct client hours be a maximum of 1:7 and a minimum of 1:25. Maintaining the current maximum rate (or pace) of supervision at 4:40, or 1 hour of supervision per 10 direct client hours, will ensure that nearly every resident will be required to go beyond 200 hours of supervision and 2,000 direct client hours in order to get licensed.

Mathematically, if the required overall supervision rate is 1:10 (200: 2,000), and the maximum rate is also 1:10, a resident ever falls behind this ratio has no way to “catch up” by going faster than 1:10 at some point. This will add months to residency and cost nearly every resident in the state thousands of dollars in extra supervision cost and in delayed full licensure, probably by several months.

Please consider this realistic example. In the old system, a resident’s quarterly report could state 200 direct client hours and 100 ancillary hours for a clinical experience of 300, and 15 hours of supervision. This is a 15:300 ratio or 1:20 which is perfectly allowed, yet the resident is 5 hours “behind” their overall ratio of 1:10 supervision; they should have done 20 hours of supervision for 200 direct client hours, but they only did 15. This has been no problem if in the next quarter they again do 200 direct client hours, 100 indirect hours, and now do 25 hours of supervision. This is a 25:300 ratio or 1:12 which is perfectly allowed, and the resident now has completed 400 direct client hours and 40 hours of supervision. Perfect. This back and forth rhythm was always allowed and matched the realities of clinical life and the shifting availability of supervisors, vacations, bad weather, client attendance, months of short finances, etc., and most residents could arrive at 200 and 2,000 within the same month.

With the same realistic example of two quarters under the new system, the resident will have 400 direct client hours but only 35 supervision hours will be counted by the Board. Why? Because in the first quarter you are now only counting their direct hours, and 15:200 is a 1:13 ratio and is allowed. But in the next quarter the resident did 25:200, a ratio of 1:8 which is NOT allowed, and the Board will only give the resident credit for 20 hours of supervision for 200 direct client hours, since the maximum, or fastest, ratio is 1:10. So now they have 35 hours of supervision and 400 direct client hours, still behind. If they try to catch up the next quarter, or in any quarter, by doing 25 supervision hours for 200 client hours, the Board will never count more than 20 supervision hours for the 200 direct client hours, even though they keep doing 25.

In the past, if a resident did 5 quarters of “5 hours behind” in supervision and 5 quarters of “5 hours ahead” in supervision, they arrive at 200 and 2,000 no problem. Now, this same rhythm that occurs in real life will result in 2,000 direct client hours completed but only 175 hours of supervision counted by the Board, and now the resident must do and pay for an extra 25 hours of supervision. Of course, at a maximum rate of 1:10, now they must also do an additional 250 direct client hours, about 4 months of extra residency. The resident will actually be required to do 225 hours of supervision and 2,250 direct client contact hours in order to complete residency.

After 17 years of doing clinical supervision and 10 years of training supervisors, I predict very few supervisors will be willing to spend less than 1 hour of supervision per every 25 direct client hours, as protection of clients and clinician development become lost in the flurry of hours. The previous (current) minimum rate of 1:40 worked because 15-20 of those 40 hours were ancillary hours, and only 20-25 were direct client hours. Under the new rules, the minimum rate needs to be adjusted to the new reality of applying only to direct client hours. Likewise, a maximum ratio of 1:7 would allow a resident doing 200 hours in a quarter to count 28.5 hours of supervision, creating space for “catch up” without going so fast that supervision becomes “check the box.”

My proposed change also supports the common practice of accelerated supervision in the first 6-12 months, providing supervision at a slightly faster rate when the resident needs it most, and then supervision can slow down in the last 6-8 months when the resident needs it less. Of course, every quarter falls within the prescribed limits.   

As one might recognize, the Board’s new rule will only work if the resident reports exactly a 1:10 ratio in every quarter of residency, never getting even 1 hour ahead or behind. I doubt anyone is able to choreograph this kind of ratio in real life.

Thank you for considering my recommendation to adjust the supervision ratio to a maximum ratio of 1:7 and a minimum ration of 1:25 for each quarterly report.   

Dear Virginia Board of Counseling, 

I am echoing Dr. David Mikkelson's mathematical concerns concerning the new change in residency supervision ratios. 

I am asking the Board to consider the mathematical impact of removing the indirect or ancillary hours from the computation of hours ratio of supervision per clinical experience. I recommend new parameters of supervision per direct client hours be a maximum of 1:7 and a minimum of 1:25. Maintaining the current maximum rate (or pace) of supervision at 4:40, or 1 hour of supervision per 10 direct client hours, will ensure that nearly every resident will be required to go beyond 200 hours of supervision and 2,000 direct client hours in order to get licensed.

Mathematically, if the required overall supervision rate is 1:10 (200: 2,000), and the maximum rate is also 1:10, a resident ever falls behind this ratio has no way to “catch up” by going faster than 1:10 at some point. This will add months to residency and cost nearly every resident in the state thousands of dollars in extra supervision cost and in delayed full licensure, probably by several months.

Please consider this realistic example. In the old system, a resident’s quarterly report could state 200 direct client hours and 100 ancillary hours for a clinical experience of 300, and 15 hours of supervision. This is a 15:300 ratio or 1:20 which is perfectly allowed, yet the resident is 5 hours “behind” their overall ratio of 1:10 supervision; they should have done 20 hours of supervision for 200 direct client hours, but they only did 15. This has been no problem if in the next quarter they again do 200 direct client hours, 100 indirect hours, and now do 25 hours of supervision. This is a 25:300 ratio or 1:12 which is perfectly allowed, and the resident now has completed 400 direct client hours and 40 hours of supervision. Perfect. This back and forth rhythm was always allowed and matched the realities of clinical life and the shifting availability of supervisors, vacations, bad weather, client attendance, months of short finances, etc., and most residents could arrive at 200 and 2,000 within the same month.

With the same realistic example of two quarters under the new system, the resident will have 400 direct client hours but only 35 supervision hours will be counted by the Board. Why? Because in the first quarter you are now only counting their direct hours, and 15:200 is a 1:13 ratio and is allowed. But in the next quarter the resident did 25:200, a ratio of 1:8 which is NOT allowed, and the Board will only give the resident credit for 20 hours of supervision for 200 direct client hours, since the maximum, or fastest, ratio is 1:10. So now they have 35 hours of supervision and 400 direct client hours, still behind. If they try to catch up the next quarter, or in any quarter, by doing 25 supervision hours for 200 client hours, the Board will never count more than 20 supervision hours for the 200 direct client hours, even though they keep doing 25.

In the past, if a resident did 5 quarters of “5 hours behind” in supervision and 5 quarters of “5 hours ahead” in supervision, they arrive at 200 and 2,000 no problem. Now, this same rhythm that occurs in real life will result in 2,000 direct client hours completed but only 175 hours of supervision counted by the Board, and now the resident must do and pay for an extra 25 hours of supervision. Of course, at a maximum rate of 1:10, now they must also do an additional 250 direct client hours, about 4 months of extra residency. The resident will actually be required to do 225 hours of supervision and 2,250 direct client contact hours in order to complete residency.

I predict very few supervisors will be willing to spend less than 1 hour of supervision per every 25 direct client hours, as protection of clients and clinician development become lost in the flurry of hours. The previous (current) minimum rate of 1:40 worked because 15-20 of those 40 hours were ancillary hours, and only 20-25 were direct client hours. Under the new rules, the minimum rate needs to be adjusted to the new reality of applying only to direct client hours. Likewise, a maximum ratio of 1:7 would allow a resident doing 200 hours in a quarter to count 28.5 hours of supervision, creating space for “catch up” without going so fast that supervision becomes “check the box.”

My proposed change also supports the common practice of accelerated supervision in the first 6-12 months, providing supervision at a slightly faster rate when the resident needs it most, and then supervision can slow down in the last 6-8 months when the resident needs it less. Of course, every quarter falls within the prescribed limits.   

As one might recognize, the Board’s new rule will only work if the resident reports exactly a 1:10 ratio in every quarter of residency, never getting even 1 hour ahead or behind. I doubt anyone is able to choreograph this kind of ratio in real life.

Thank you for considering my recommendation to adjust the supervision ratio to a maximum ratio of 1:7 and a minimum ration of 1:25 for each quarterly report.   

I have concern about the adjustment in ratio of supervision hours per hours. With the elimination of ancillary or indirect hours, which I support, I believe this can adversely impact the developmental needs of residents, as well as extend their residency unnecessarily. 

Under what is proposed in 18VAC115-20-52 Resident license and residency requirements section B3a, it says, "Supervision shall occur at a minimum of one hour and a maximum of four hours per 40 hours of work experience during the period of the residency." This would indicate that the maximum ratio of 4:40 (supervision hours to direct hours, since indirect hours will no longer be counted). Or, more simply, the maximum ratio is 1:10. 

As stated in Dr. David Mikkelson's comment, one concern that I share is that if a resident falls behind in supervision, it seems that there is no viable way to "catch up," on supervision hours if direct hours completed exceed that 1:10 ratio. Furthermore, especially in the first quarter or half of residency, having an "extra" amount of supervision hours can often be essential for appropriately addressing the developmental needs of the resident. 

As a supervisor who plans to supervise residents, I greatly value having the appropriate amount of supervision for residents at the appropriate times in their development, and I would not want them to unnecessarily have insufficient hours early on, or have unnecessary hours to complete once they near the end of residency. As such, I also recommend changing the supervision ratios to 1:7 maximum and 1:25 minimum in order to provide the flexibility to best meet the supervision needs of residents.

Thank you for your consideration on this matter.

To the VA Board of Counseling,

I currently have a strong group practice in Fairfax City focusing on the training of Students and Residents. This past year, I have recommended 9 Residents to the VA Board of Counseling for full licensure under my supervision. I fully support Dr. David Mikkelson's request to make the maximum ratio of supervision to direct hours at 1:7. This will help give a buffer for missed supervision sessions whether the Resident or the Supervisor has the need to cancel. Life happens and the 1:10 maximum cuts it way too close for many supervisees who are gaining their hours at a full time rate. I agree with Dr. Mikkelson that Residents will necessarily have their Residency extended as a result of the maximum 1:10 ratio.

In addition, I want to add my wholehearted agreement to removing the need to count ancillary hours and to making the 200 hours of supervision post graduation. This aligns with many other states and hopefully...not in my career lifetime...we can move towards a federal license or at minimum...get closer to the Counseling Compact working.

Dr. Mikkelson's proposal:

I have had the privilege of supervising both graduate students and residents and I see the presented changes as having a negative impact on both populations and insufficiently addressing the primary need of improved supervision standards. My following comments address the current proposed changes but are based on the foundation for a call to improved supervision standards.

Graduate Students: Many graduate students find themselves with limited options for sites and the positions at sites often result in an excess of direct hours and at times, excess supervision hours. Setting December 18th as the day that change are made will significantly impact students who anticipated and intentionally worked towards excess internship hours to apply to their residency. I would recommend that if graduate students will not be able to count their internship hours towards residency, that these changes not go into effect until May 2026 so that students can have time to adjust their plans or amount of time they are devoting to achieving hours to count towards residency. 

If the Board would be willing to accept a change, I would recommend a cap on the number of direct and supervision hours that could be used for residency. I would advocate that no more than 100 direct hours and 10 supervision hours (5% of required hours for residency) in excess of Internship hour requirements be applicable to residency. Allowing for some hours eases the burden of costs associated with residency, will help minimally reduce the length of time spent in residency, and also allows for meaningful supervision and clinical growth in residency.

Residents: I would like to echo the comments of Dr. David Mikkelson. Allowing for a lower minimum ratio of 1:7 and a maximum of 1:25 for every quarter affords supervisors and residents the opportunity to provide meaningful and stabilizing supervision in the early stages of residency. 

I am concerned with the proposed removal of allowing excess hours accrued during internship to be counted toward residency. These hours are performed under supervision, and allowing up to 300 excess internship hours to be applied to the total hours required for residency would further encourage the fast track licensure these regulations aim to support. 

As others have stated, no longer allowing supervision hours accrued during internship creates a significant barrier in earning the required supervision hours in residency. 

My mother is a Licensed Professional Counselor in the State of Virginia. This proposal gives her mixed feelings for the fact that she had to work very hard to obtain her licensure and is frustrated by the fact that it could've been easier for her. At the same time, however, she feels very overwhelmed at her current job at a community agency because she is currently the only LPC handling counseling for clients at the office. She handles anywhere from 40 to 50 clients at one time on her caseload. In order to encourage more people to pursue becoming an LPC, I support reducing residency requirements so that the already overwhelmed system will be able to have more support as well as the ability to help more of those who are in need. The current demands for mental health, especially in rural areas, greatly exceeds the availability of counselors.

I had missed the proposal to remove the ability to count 20 hours of a supervised internship towards the 200 required supervised residency hours for an LPC. I don't think this specific suggestion will encourage more people in the psychology field to work towards being an LPC, especially because internships in this field from my knowledge are unpaid. My mother worked unpaid internships during her time in graduate school. Without having some incentive to work the internship, it will push more people away from trying to be an LPC, which is exactly the opposite of what reducing residency hours should be causing. This amendment to the ruling should be removed for the sake of every Virginian's mental health. 

I hope you will consider Dr. David Mikkelson's excellent point tha the carefully described with specific mathmatical examples.  He pointed out that the new ratio will cause a resident to more than likely have to do more hours directly beyond the 2000 in order to reach the proper amount of supervision, if they were to get behind the rigid ratio.  I love that Dr. Mikkelson brought up the ebb and flow of catching up and getting behind on supervision of the current system.  In real life residency if we are doing both a group supervision and individual supervision, there can be variation in these hours.  It seems too rigid to keep a 1:10 ratio consistently and doesn't allow for flexibility.  It may also incur extra costs just to get supervision hours which can be prohibitive for residents.  

I agree with removing ancillary hours while upholding the 200 hours of supervision requirement for residency.  However, I would like to echo Amy Bullin’s concluding comment: “I respectfully urge the Board . . . to continue allowing the 20 hours of internship supervision to count toward the 200-hour residency requirement. Maintaining this provision would support new professionals, uphold training quality, and better align with the stated intent to streamline and modernize the licensure process.”

Finally, I would strongly support Dr. David Mikkelson’s comments and rationale leading to his insightful recommendation “to adjust the supervision ratio to a maximum ratio of 1:7 and a minimum ration of 1:25 for each quarterly report”.   

Thank you for your consideration.

In the PDF of "Key Regulations Changes Effective 12/18/25", under the row "Residency Requirements", it describes "Residents are no longer required to complete the residency requirements within four years; however, residents must complete at least half of their residency hours within two years immediately preceding application for licensure as a professional counselor (LPC).  A minimum of 1,000 of the required 2,000 hours of face-to-face client contact; and 100 of the 200 hours of supervision. hours of in-person supervision."    Another place of the redlined "Proposed Text" under 18VAC115-20-52; B4 reads "4. The resident will complete a minimum of 1,000 hours of face-to-face client contact and 100 hours of supervision within two years immediately preceding application to the board for licensure as a professional counselor. "

My question is about the definition of "application for licensure" - is this referring to "application for residency" or the final stage of residency after all hours are accumulated and when one is applying for a full LPC (once all residency and supervision requirements are met). 

The answer to this question will significantly change the interpretation.  On the one hand, if it is "within two years of application of residency" I would count the 1000 hours after I initially started my residency.  On the other hand, if it is referring to "two years preceding application for FULL licensure as LPC" then regardless of the length of time it took to accumulate hours, I would need to make sure that the 1000 hours and 100 hours of supervision are within two years of applying for full LPC.   Please help to clarify this.  Thank you.