Archived: Thursday, December 15, 2022 8:53:29 AM

From: BPL-BoardSupport

Sent: Wed, 14 Dec 2022 20:20:15

To: MacIntosh, Weston (LARA)

Subject: FW: Boards and Committees: Attention: Departmental Specialist: Counseling Amendment Comments

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Attachments:

Thriveworks - MI Counseling rules Comments.pdf;

From: Thriveworks Legal <legal@thriveworks.com>

Sent: Wednesday, December 14, 2022 2:33 PM

To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>

Subject: Boards and Committees: Attention: Departmental Specialist: Counseling Amendment Comments

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Good afternoon,

Please see the attached comments regarding Administrative Rules for Counseling – General Rules. Thank you.

Stefanie Frank

Vice President, Associate

General Counsel | Thriveworks

Phone: 617-902-0019

Email: l e gal@thriveworks.com

Website: thriveworks.com

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Thanks for your understanding!

- Your friends at Thriveworks

Thriveworks

1000 Jefferson Street

Suite 2C

Lynchburg, VA 24504

Stefanie Frank

Vice President & Associate General Counsel

December 12, 2022

Department of Licensing and Regulatory Affairs

Bureau of Professional Licensing

Boards and Committees Section

P.O. Box 30670

Lansing, MI 48909-8170

BPL-BoardSupport@michigan.gov

Re: Administrative Rules for Counseling – General Rules

Dear Board,

Thriveworks appreciates the Board giving us an opportunity to comment on the proposed rules

regarding Counseling – General Rules.

Thriveworks is a leading mental health provider offering counseling and psychiatry services

online and in-person at 350+ locations nationwide. We work to make therapy and psychiatry

better for everyone: providing best-practice care and creating a supportive environment our

clinicians can thrive in. We employ over 2000 mental health clinicians nationwide, with over 80

practicing in Michigan, including supervisors and associates. Our goal is to continue to grow our

presence in the State.

The Thriveworks Resident Program is a nationwide initiative that provides pre-licensed

clinicians, which we call Residents, with the opportunity to provide clinical services under

supervision. This enables provisionally licensed clinicians to build professional experience and

develop clinical skills in the gap between the completion of their Masters and receiving

licensure.

In regard to the proposed rule, and in view of the Thriveworks Resident Program, we agree with

the new definition of “Supervisor”. We also thank the Board for including Telehealth within the

rules and agree with the description and requirements.

Under R. 338.1772, we request clarification on providing a professional disclosure statement

with the application for a limited license as it is ambiguous. Thriveworks recommends that

notices be sufficient if it is within the informed consent document, and no separate notice be

required.

Further, under the same section, we found the language on Supervisors providing information to

the Board to be ambiguous as well. Thriveworks asks that the Board create a form that includes

all the required information for a Supervisor to easily complete and submit, without the need of

Board approval. As Thriveworks employs thirteen Supervisors in the State of Michigan, we want

to show our quality, while not overburdening our supervisors.