Archived: Thursday, December 15, 2022 8:53:29 AM  
Sent: Wed, 14 Dec 2022 20:20:15  
Subject: FW: Boards and Committees: Attention: Departmental Specialist: Counseling Amendment Comments  
Importance: Normal  
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Thriveworks - MI Counseling rules Comments.pdf;  
From: Thriveworks Legal <>  
Sent: Wednesday, December 14, 2022 2:33 PM  
To: BPL-BoardSupport <>  
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  
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Thanks for your understanding!  
- Your friends at 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  
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  
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  
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.  
Lastly, we agree and appreciate the Board’s inclusion of the ability for supervision to occur via  
2-way real-time audiovisual technology that allows direct, contemporaneous interaction by sight  
and sound between the supervisor and supervisee.  
Thank you for your time and attention to this matter.  
Stefanie Frank, VP & Associate General Counsel  
Heidi Faust, Chief Clinical Compliance Officer