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]
Action Periodic review
Stage Final
Comment Period Ended on 8/24/2016
spacer
Previous Comment     Next Comment     Back to List of Comments
8/24/16  11:26 pm
Commenter:  

Restriction of supervisor license restricts opportunity for and quality of training
 

As a counselor educator in the neighboring state of Maryland (whose students frequently go on to practice in Virginia), I urge the Board NOT to adopt restrictions on the type of license required for supervisors of LPCs. and MFTs.  Any such restrictions will inevitably limit training and employment opportunities, while there is no evidence (only conjecture) to suggest that the effects of the limitations will be positive.  Student training and career opportunites are likely to be especially impacted, negatively, in underserved areas and with underserved populations, regardless of the absolute number of LPCs in Virginia.  Agencies that do not have an LPC supervisor on staff would not be able to take trainees, and are very unlikely to hire the new counselor who needs supervision.  On the other hand, many high power training facilities (consider teaching hospitals) are staffed with excellent clinical social workers and psychiatrists -- some leading educators in mental health treatment -- who would be ineligible to provide training to students and supervision to early career LPCs.  This sort of restriction does nothing to promote the public welfare, and arguably harms the public by limiting accessibility to quality care.  Psychiatrists, social workers, and psychologists, as well as LPCs are excellent mental health providers -- there is absolutely no data to suggest that one group is superior to another.  To rule out diversity among supervisors of MFTs and LPCs does a disservice to the all of the professions.  Training in mental health treatment is strongest when it draws from the all of the specialties and the breadth of experience in the field.  Training and working in one narrow "silo" serves no one except the MFT and LPC supervisors who stand to profit from increased business (supervision being very a very lucrative enterprise).   Beware of regulations that have no demonstrable basis other than serving narrow and financial interests of those promoting them!

CommentID: 50822