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 Resident license
Stage Proposed
Comment Period Ended on 11/13/2020
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10/26/20  6:09 pm
Commenter: Dr. Melanie Burgess

Audio Hours
 

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. 

CommentID: 87389