1000 Jefferson Street
Lynchburg, VA 24504
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
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.