Please consider allowing (at least a portion of) hours provided via audio to be counted toward heir hours.  If DMAS is allowing for reimbursement for both Audio/Visual and audio only telehealth sessions, then these hours should be considered to count by the BHP as well.

Please allow audio telephonic services to be allowed to count toward licensure hours.  DMAS allows both visual and audio services to be billed.

Please allow audio telephonic services to be allowed to count toward licensure hours. When the pandemic hit we didn't stop "counseling" just because we had to use precautions to keep our communities and selves safer! We kept going, assisting our clients, and had to adapt to keep them stable through this pandemic without accidental exposure. Please don't make all the work and struggles we had to endure because of this pandemic mean nothing. We kept fighting because we were "essential", but doesn't that mean our work is important regardless if it's on the phone, in an office, out in the community, or somewhere else? Please allow these hours to count, they matter to us just as they mattered to our clients who received them when they were in need and couldn't/were too scared to leave home. Thank you.

These unprecedented times have required all (DMAS, DBHDS, clinicians) to be flexible and adaptable in an effort to meet the behavioral health needs of all. To echo others who have also commented, DMAS's flexibilities allow for both audio/video AND audio alone. This swift adaptation in billing/documentation and telephonic options has not only benefited service recipients as they did not experience an interruption to much needed services during a time of increased anxieties, but also Residents in Counseling, who with this invaluable experience, are paving the way in the field of behavioral telehealth. Not counting audio hours would imply that their service was not worthy of recognition and would be a disservice to an ever changing field. 

It is absolutely reprehensible that in times when counselors are in higher need than ever, we are penalizing residents by not allowing them to use audio hours to count towards their 3,400 hour residency. Despite much of the economy being in turmoil, one business that has picked up more than ever is mental health services. Now, more than ever, providing mental, behavioral, and emotional support is crucial as Virginians navigate their way through a seemingly never-ending pandemic, further complicated by job loss, schooling/childcare complications, and increasing political tensions. With counselors being essential during this time, it seems absurd that Virginia would place such a detrimental restriction on residents becoming licensed. Within the context of the four-year completion requirement, considering that at least one year is going to be telehealth (if not more, depending on what 2021 has in store), this is postponing the licensure of many hard-working residents and potentially putting them in a position where they will be required to petition the board for more time.

Virginia is well-known in the counseling world for having stringent requirements for becoming an LPC, which has helped showcase the high quality of counselors that are educated here. However, removing the ability to count audio-only sessions toward licensure--sessions which are being billed and accepted by insurances, by the way--is not something that will continue ensuring counselors have the best training, and does not seem to be anyone's benefit. It is only an unnecessary and, in these times, frankly cruel, further roadblock toward becoming professionals in an already under-funded, under-appreciated, and very difficult career field.

The COVID-19 pandemic has brought forth many challenges for a variety of different fields.  Not only has the mental health field adapted to these challenges, but the number of people seeking out mental health treatment has increased since this pandemic has started.  Resident's in counseling are being provided an opportunity to grow with this field and to grow as clinician's in ways that many of them probably never saw coming. They have had to adapt to different forms of providing therapy, many of which most residents would probably consider more challenging than the typical face-to-face format, which is what they were trained for. To be prevented from being able to utilize these hours would be like being told that their efforts have gone unnoticed and the hard work they are doing is not worthy of moving forward in their careers.  Residents did not ask for this pandemic to happen, but they are doing the best they can do adapt to that and they should not be punished for this. 

I strongly urge you to include audio hours towards residency licensure hours. Especially during a pandemic, counseling is an essential service that is effectively improving the lives of clients, regardless of the format (e.g., audio, video, or in-person modalities). Counselors have been flexible to adapt to the needs of their clients during an unprecedented pandemic; therefore, it is shocking that this barrier is being intentionally placed between mental health residents achieving well-deserved licensure. 

Failing to count audio hours toward licensure makes the audacious and faulty assumption that audio hours are not worthy of recognition. This could not be further from the truth. Behavioral telehealth services are rescuing lives during unrest, turmoil, and existential crises related to this pandemic. Failure to recognize audio hours as worthy towards total residency licensure hours is disgraceful and appalling. 

Please allow audio services to count toward residency hours. 

As someone who's mother has PTSD and cannot complete in-person treatment with a health professional, it seems apparent, if not necessary, to not allow residents making their way into the mental health professions the ability to procure hours toward licensing requirements by means of audio communication. While perhaps not suitable to ascertain analysis of in-person modality with a patient, you cannot expect all individuals, depending upon which part of the state they are in, to be able to fulfill these requirements amidst a pandemic. If not applicable, perhaps a cut-off or a codified timeframe in which audio is counted and then back to in-person requirements? At the minimum until the end of 2021, in hopes of a vaccine, whenever that will come to culmination. I am unjust in stating I understand all of the implications leading up to the conclusion to keep audio hours out of the legislation, but I implore you to reconsider. Even a phone call has shown exemplary aid in my mother's overall mental wellbeing. I am sure residents are eager to begin work during these tumultuous times, as they are utmost vital to combat the understated hardships of the pandemic. Please give them equal opportunity in all modalities of modern communication.  

Many of my family members are professional counselors.  It is imperative that emergency regulations make it easier for them to work during this pandemic.  Emergency regulations for the issuance of temporary licenses to individuals should be granted.  With this pandemic and its effects on health, now more than ever, changes and reforms must be accepted.  Audio meetings should also count toward licensure hours.

At a time of pandemic, with the country in various states of quarantine, and with the dire need for mental health counseling in all its delivery modes made obvious, it is only just and fair, and respectful of these essential workers, to give them all credit towards licensure. This should be obvious, not something requiring petition. Anything less causes harm to all, including state government.

I cannot impress enough to the Board how imperative telephone counseling has been for my rural, lower SES, immunocompromised, and disabled clients during this pandemic.  As resident counselors, we have had to embrace flexibility to meet the myriad of mental health needs that have been exacerbated by the uncertainty of these times we are living in.  We are truly working in a proving ground, and to disallow the hours we have put into helping others amid a pandemic due to a lack of an electronic interface does not feel adaptive, but restrictive.  If DMAS is allowing for reimbursement via telephone contact, how can not including those same hours in pursuit towards licensure be considered?  Telephone counseling has a precedence - Suicide Hotlines save lives.

In the light of the current pandemic, it has become necessary for supervisees and residents to do their contact via video chat and telephone. Many of our consumers, especially in impoverished areas, do not have access to computers, etc. Residents in Counseling need to be able to count their contact hours toward licensure, including telephone contacts.