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]
Previous Comment     Back to List of Comments
8/16/22  5:27 pm
Commenter: Ethan Kaste, Resident in Counseling

Original Petition
 

I would like to propose that we allow Resident in Counseling professionals to use the title Licensed Professional Counselor - Resident (LPC-R), Licensed Resident Professional Counselor (LRPC), or another similar form for a few reasons:

  1. Provides consistency and accuracy of terms in Virginia’s regulations  

The Virginia Board of Counseling defines “Resident” to mean, “An individual who has a supervisory contract and has been issued a temporary license by the board to provide clinical services in professional counseling [emphasis added] under supervision” (18VAC115-20-10.B). This regulation implies that residents are licensed individuals that are able to provide professional clinical services, affirming that the resident has the capacity to provide services in a professional capacity. However, 18VAC115-20-52.B.10 states that “Residents may not [emphasis added] call themselves professional counselors, directly bill for services rendered, or in any way represent themselves as independent, autonomous practitioners or professional counselors”. The former regulation suggests that residents provide professional services but the latter seems to deny that. Further clarification on the definition of “professional counseling” may be needed, but instead of rewriting or redacting those regulations, the use of the title Licensed Professional Counselor - Resident (LPC-R) or Licensed Resident Professional Counselor (LRPC) be the designated title since it more accurately represents Residents in that they are supervised licensed individuals who provide professional services.

  1. Uniformity in supervised licensure titles among other states.

Many states in the counseling profession are utilizing the terms “professional” and “licensed” for those who are graduated supervised individuals working towards. Alabama, California, Colorado, DC, Maryland, Georgia, and Hawaii are just some states that utilize various titles such as Associate Licensed Counselor (ALC), Licensed Associate Counselor (LAC), Licensed Associate Professional Counselor (LAPC), Licensed Graduate Professional Counselor (LGPC), Limited Licensed Professional Counselor (LLPC), Licensed Graduate Professional Counselor (LGPC), Provisional Licensed Professional Counselor (PLPC), and Licensed Professional Counselor Associate (LPCA).

https://www.counseling.org/knowledge-center/licensure-requirements/state-professional-counselor-licensure-boards

  1. Ease of use

I personally do not consider it necessary to change the name, I just simply think it makes more sense to utilize Licensed Professional Counselor - Resident (LPC-R) or Licensed Resident Professional Counselor (LRPC) for the aforementioned points. Lastly, and perhaps the least important point in this petition is the abbreviated use of a resident title such as LPC-R or LRPC is more simple to use than “Resident in Counseling”.

 

I want to thank everyone for their comments, I was looking forward to learning and hearing everyone’s different opinions! It is my first time operating in a regulatory capacity (however small it may be) so I was somewhat excited and honored to be a part of it. I am still a Resident in Counseling myself so I understood that there were going to be some perspectives that I had not considered. I also wished I had seen these comments earlier, I noticed that much of my reasoning for the petition was left out. So I would have posted this comment earlier in order to further clarify my reasons for suggesting the petition. I apologize for that.

CommentID: 127275