I strongly support the changes proposed to Regulations Governing the Practice of Professional Counseling [18 VAC 115 - 20]. I think these changes will contribute to protecting the public and insuring client welfare by formalizing processes for professional counselors.

The aspect of this legislation that seeks to reduce the pool of supervisors to predominantly LPCs may have the unintended consequence of creating intellectual insularity in the field. A well rounded practitioner should understand the multiple perspectives of psychology, psychiatry, social work, and substance abuse counseling. Each of these displines have a unique contribution to make in deepening the understanding of human behavior; and every counseling resident should be able to choose among a wide range of qualified supervisors, based on their skill and wisdom as clinicians and not simply the initials that follow their name. If Carl Rogers, PhD were available to supervise in Virginia, this legislation would disqualify him as a supervisor.

Restriction of supervision to licensed counselors is not a good idea because there are other highly qualified individuals from other professions who are also licensed to serve the public in ethical and effective ways. There is no need to restrict supervision in this manner. Diversity within the profession of counseling is a good thing. There are agencies that would benefit from continuing to be able to have diverse supervisors (all highly trained and licensed within their respective professions). Also, there are training programs in Virginia that are actively training counselors who have qualified, licensed supervisors from other professions. There is no reason for this to change. It would be a poor use of resources in Virginia to limit, by profession, those highly trained and higly qualified individuals who would be eligible to supervise counselors. Professional diversity in supervision of counseling, as it currently exists in Virginia, is already serving the publc well. There is not a problem that needs to be fixed: the public is currently being served well, effectively, and in an ethical manner.

This legislation which seeks to restrict supervision of LPC and LMFT trainees to only licensed professional counselors would severely restrict the training opportunities available for mental health practitioners in the Commonwealth. Several other well-qualified disciplines, such as clinical psychology, have adequately supervised these trainees since the inception of the fields, and there is no documented emperical evidence to justify passing legislation that would prevent psychologists from supervising LPC and LMFT trainees. This legislation represents much more a "turf war" tactics than something that would be actually be beneficial to constituents with mental health issues in the Commonwealth.

Certainly the public is not served by unnecessary restrictions, particularly those motivated primarily by an unjust and unethical monopoly by one segment of our field. The vital need for quality mental health providers who represent an array of philosophic, theoretical, and diverse professional approaches to provide outstanding services to an already-underserved public has perhaps never been greater.

I am a counseling student in another state, so my experience may not translate perfectly to Virginia, but I have found that securing quality supervision can be a challenge, and that being able to receive supervision from LCSW's and licensed psychologists has made this search much simpler. In addition, having a wider range of choices gives me room to find a good fit or seek out a supervisor with a particular speciality that I want to pursue. Limiting these options seems likely to benefit only a few LPC's and LMFT's who might see their supervision loads increase while detracting from the profession overall. Thanks for your consideration of an outside perspective.

The proposed restrictions are not based on evidence but on politics. The nationwide movement toward evidence based decisions in education, training, and professional practice is designed to HELP the public, IMPROVE the quality of training received by providers, and IMPROVE the quality and effectiveness of services received by the public. Adopting these restrictions caters to a political and turf-driven agenda. A careful review of curricula and training requirements will show that a diverse group of professionals is well qualified to provide supervision, just as a diverse group of professionals has historically contributed to the training of high quality LPCs and LMFTs. The science of evaluating mental health interventions and prevention programs has never been better. Ignoring or sidelining the role of evidence in decision making is a step backwards.

While I understand the desire to limit supervision status to licensed mental health professionals who can adequately supervise masters level counselors, it is short sided to exclude licensed psychologists from providing such supervision. Licensed psychologists who are trained in clinical supervision are well qualified to supervise masters level counselors in the provision of counseling services. Limiting supervision roles will further fuel the difficulty masters level counselors in training experience in identifying appropriate practicum/internship/training sites or will force them to have to pay someone outside their agency to provide supervision just so it is accepted by the Board. This also poses a significant burden to military spouses like myself who continue to have difficulty getting an LPC license from state to state because states are unwilling to accept my substantial amount of clinical hours since they were supervised by licensed psychologists instead of LPCs. This same burden applies to other LPCs moving into our state. We essentially would be telling them to start their supervised hours over again just so they would count in VA in cases where these unlicensed professionals were unable to finish all of the LPC licensure requirements in another state before moving to VA. I think allowing psychologists to provide supervision is warranted, but not the others (e.g. Psychiatrists), since psychologists have the same foundational training, provide many of the same services, and have very stringent requirements for licensure. You can add a provision that psychologists who can demonstrate they are competent to provide clinical supervision (like with transcripts or continuing education) can be approved for supervision. 

This is a restriction of trade and there is no empirical evidence to support such a decision. This is politically biased in favor of CACREP and as a Licensed Professional Counselor I could not support the proposed change. There is too much scientific literature that demonstrates the effectiveness of psychologists and their ability to train counselors. There are supervision textbooks written by psychologist that are used in CACREP programs that train counselors. How can one restrict psychologist from supervising counselors?

it is completely ridiculous that licensed psychologists and psychiatrists and clinical social workers cannot provide clinical supervision to LPCs and MFTs.  completely and totally ridiculous.  there are not nearly enough LPCs and MFTs with supervisory experience and training to meet the demand for supervision for trainees as things stand today.  furthermore, this is insufficient notice for the appropriate organizations to provide comment on this matter.  counseling is counseling and LPCs and MFTs do not have exclusive ownership of this activity.

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.

It makes sense to have good supervisors for mental health clinicians of all kinds. This restriction is unncessary and restricts trade for eligible clinical, counseling, and school psychologists (who arguably may have more coursework and experience in supervision than LPCs and LMFTs). It also makes it more difficult to find qualified supervisors for those trying to get their practice up right out of graduation. All of this make the provision of needed mental health interventions to the people of VA less accessible. 

The problem with this proposed legislation is that it would limit supervision from qualified behavioral health professionals such as doctoral-level clinical and counseling psychologists.  As a result, supervisees and their clients would be at a disadvantage to achieve optimal health outcomes.  Many doctoral-level clinical and counseling psychologists are uniquely trained to deliver quality supervision based on prevailing science and theory in the behavioral health fields.  Thus, the proposed legislation would unnecessarily restrict access to such experts. Please consider enhancing inclusivity to well-qualified supervisors.  Thank you.

Unfortunately, this legislation, however well-intentioned, seems to be a result of a turf war between behavioral health providers from varying backgrounds.  Like many civil wars, it will be costly, will add to the ongoing rancor, and will not be settled amicably.  And the true losers will be those in desperate need of quality mental health care.  The need for such services is great and providers from a host of professions can and should provide guidance to those in training to serve this need.  Please put the health needs of the public above the animus of the Bickersons. 

The general problem with this legislation is that it limits the types of supervisors available to counselors. This is problematic because many allied professionals provide excellent supervision and having diverse perspectives and training orientations is beneficial not only to trainees but to clients themselves. We need as many different types of qualified supervisors for good training. Please broaden the options for supervision rather than limiting them. Thank you.

Without sound empirical evidence for doing so, limiting supervision to LPC's only is unnecessarily restrictive. I live in a rural area of Virginia that is underserved. I met with the director of the county social services agency a while back and during our conversation learned that they are already challenged in finding supervsion for staff - why make it harder. 

I urge the licensing board to strike the sections in the proposed regulations that allow only LPCs and LMFTs to supervise both counselors and marriage and family therapists. A simple increase in the number of LPCs and LMFTs does not mean there are sufficient qualified supervisors with those specific licenses. Moreover, there is no evidence that LPC and LMFT supervisors provide better or more ethical supervision than supervisors trained in allied professions. If this proposal is adopted, it is likely that the reduced number of supervisors would raise the cost of training, possibly deterring some from earning their licenses, and ultimately reduce the number of LPCs and LMFTs available to serve the people of the Commonwealth of Virginia. Ultimately, this will harm - and not help - the public, particularly in underserved communities.

This comment is to go on record opposing the limitation of residency supervision to LPCs and LMFTs.  I understand the rationale - that the board does not regulate licensed professionals from related fields and thus cannot provide due diligence in oversight if providers with other licenses are allowed to provide supervision of a portion of the time of residents (although actual problems resulting from this state of affairs appears to be limited).  But from outside the board, the effort appears to be oriented toward further establishing a counseling profession limited to a narrow vision of counseling.  It's too bad - the profession of counseling in Virginia once had a big tent philosophy, embracing a diversity in professional preparation and practice.  Now apparently largely in an attempt to establish perceived parity with other fields, the board has chosen to follow them down an exclusionary pathway.  There is limited if any solid evidence supporting this direction, and a strong argument to be made that professional counselors benefit from having diversity in training.  But the sadder part is that in so choosing, the board is limiting the future of professional counselors in Virginia largely to only those workplaces in which LPCs are already established as supervisors, because in sites that do not currently have LPCs as supervisors, there will be no developmental pathway for developing counselors to rise in the ranks to the level of supervisors who can provide supervision of future counselors.   Within the domain of rehabilitation counseling in which I work, damage is being done to a field that has long embraced professional counselors and psychologists working side by side, and it's ironic that professionals serving on the Virginia board who have long decried being snubbed by psychology have now turned around to do the same thing to the psychologists who have devoted their careers to stepping outside the exclusive domain of psychology and instead built careers in the field of counseling based on an appreciation that counseling recognized the value of diversity and colleagiality.

My previous comments came from a position of frustration at having seen the board not consider alternatives to the CACREP-only decision for licensure eligibility when 95% of hundreds of comments suggested opposition or posed alternatives to consider that I saw the board ignore or brush aside during their review.  I do think limiting residency supervision is a mistake, and an offense to those of us who originally came from outside the field of counseling but who have devoted our careers to developing counselors, and I do think that such a decision will necessarily limit the future growth of LPCs in Virginia to those sites where LPC supervisors already exist.  I hope the board will decide otherwise.

My previous comments came from a position of frustration at having seen the board not consider alternatives to the CACREP-only decision for licensure eligibility when 95% of hundreds of comments suggested opposition or posed alternatives to consider that I saw the board ignore or brush aside during their review.  I do think limiting residency supervision is a mistake, and an offense to those of us who originally came from outside the field of counseling but who have devoted our careers to developing counselors, and I do think that such a decision will necessarily limit the future growth of LPCs in Virginia to those sites where LPC supervisors already exist.  I hope the board will decide otherwise.

My previous comments came from a position of frustration at having seen the board apparently not consider alternatives to the CACREP-only decision for licensure eligibility when 95% of hundreds of comments suggested opposition or posed alternatives to consider that I saw the board seemed to ignore or brush aside during their review.  I do think limiting residency supervision is a mistake, and an offense to those of us who originally came from outside the field of counseling but who have devoted our careers to developing counselors, and I do think that such a decision will necessarily limit the future growth of LPCs in Virginia to those sites where LPC supervisors already exist.  I hope the board will decide otherwise.

My previous comments came from a position of frustration at having seen the board apparently not consider alternatives to the CACREP-only decision for licensure eligibility when 95% of hundreds of comments suggested opposition or posed alternatives to consider that I saw the board seemed to ignore or brush aside during their review.  I do think limiting residency supervision is a mistake, and an offense to those of us who originally came from outside the field of counseling but who have devoted our careers to developing counselors, and I do think that such a decision will necessarily limit the future growth of LPCs in Virginia to those sites where LPC supervisors already exist.  I hope the board will decide otherwise.

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!

Sorry. Not sure what happened there.