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]
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7/11/19  1:57 pm
Commenter: Cynthia Miller

Oppose
 

I am opposed to this petition.  The possession of a doctoral degree does not automatically prepare one to supervise someone for licensure.  Many doctoral programs allow students to go directly from their master's degree to a doctoral degree without having to acquire a license to practice.  While a doctoral program may require another internship, it is quite possible for someone to receive a doctoral degree having only had around 1200 hours of experience - with far less than 1,000 hours of direct service to clients.  Moreover, at the doctoral level the internship may involve more teaching and supervision of practicum students than actual clinical work.  This is not sufficient experience to begin providing supervision for licensure.

There is no substitute for experience when it comes to providing supervision for licensure.  A supervisor needs to have worked with many clients facing many different issues and preferably in multiple settings before being ready to supervise someone for licensure.  I believe the requirement that someone have at least two years of post-licensure, independent practice is a good minimum standard to become a supervisor for licensure and should not be watered down.

 

CommentID: 73512