I am unaware of any empirical evidence that holding the LPC or LMFT credential makes a supervisor superior to one who holds another credential relevant to mental health counseling (such as licensed psychologist, board-certified psychiatrist, etc.).  Limiting supervision of LPC and LMFT candidates to ONLY similarly credentialled supervisors severely limits the pool of potential supervisors, and limits the number of candidates who could become licensed professional counselors or marriage and family therapists during a time when Virginians need MORE access to quality mental health services, not less.  The administrative convenience of limiting such supervisors to individuals who are under the control of the counseling licensure board (for disciplinary purposes) does not justify such a regulation when there are viable alternatives.  Even if a supervisor has a license under another professional licensure board, the counseling licensure board can definitely report any unethical or dangerous behavior to that relevant board for that board's action, to protect the public.  Assuming that the counseling licensure board is the only entity that could appropriately sanction unethical or dangerous behavior by a supervisor licensed by another board is illogical.  This proposed change in required supervisor credentials should NOT be made to the regulations; the original language should stand, allowing supervision by an appropriately diverse set of professionals who hold licenses allowing the practice of mental health counseling.

The increased cost to LPC or LMFT licensure candidates seeking supervision would also be an inappropriate result of this regulation change.  The announcement of the proposed regulation states that "There are no disadvantages to the public."   However, it later states that "To the extent that this change limits the pool of available supervisors, costs for supervision may increase, and it may take longer for residents to obtain supervision and complete their residencies."  That delay in completion of residencies (and possibly, complete inability for some candidates to complete the residencies at all) would DEFINITELY be disadvantageous for the public, who would have delayed or reduced access to qualified mental health professionals.