September 22, 2020  
Attention: Policy Analyst  
Department of Licensing and Regulatory Affairs  
Bureau of Professional Licensing - Boards and Committees Section  
P.O. Box 30670, Lansing, MI 48909-8170  
Dear Bureau of Professional Licensing,  
On behalf of the Michigan Mental Health Counselors Association (MMHCA), I would like to thank you for  
the opportunity to provide comment on the proposed counseling rules set (2020-33 LR).  
MMHCA believes the rules as presented appropriately implement the legislative intent of the current  
licensed professional counseling statute and that, if promulgated, will ensure licensed professional  
counselors the opportunity to practice to their full scope, education and training as provided for under  
Public Act 96 of 2019.  
In light of actions taken by Governor Whitmer under the COVID-19 State of Emergency Declaration that  
suspended mandatory in-person supervision during the pandemic, we strongly recommend that this rules  
opportunity also be utilized to allow for similar accommodations in a future state of emergency. To that  
end, MMHCA recommends the following provision be added to this proposed rule set:  
“Under a Governor declared state of disaster or emergency, the Board may allow for an alternative  
supervision arrangement to the immediate physical presence requirement between a supervisor and  
the supervisee such as, but not limited to, use of two way real time audiovisual technology that allows  
for direct remote interaction by sight, sound, and observation between the supervisor and the  
supervisee to obtain the required supervision hours.”  
Thank you again for this opportunity to provide comment and for all the department’s efforts throughout  
this inclusive and collaborative rules process. Please allow this letter to serve as MMHCA’s formal  
communication of our full support for the proposed general counseling rules with the addition of the  
proposed rule allowing for an alternative supervision arrangement under a future state of emergency.  
Sincerely,  
JAMES BLUNDO, MA, LPC  
Executive Director  
Michigan Mental Health Counselors Association  
248-930-0644  
Department Of licensing and Regulatory Affairs  
Bureau of Professional Licensing- Boards and Committees Section  
P.O. Box 30670  
Lansing, Michigan 48909-8170  
Attention: Policy Analyst Email: BPL-BoardSupport@michigan.gov  
RE: Purposed rule: 2020-33LR  
Rule set title: Counseling General Rules (R338.1751- R 338.1781)  
Draft Language update on: 8/17/20  
Greetings,  
As part of my professional career as Licensed Professional Counselor in the State of Michigan, I’ve worked for the last  
four-plus years by providing supervision using the CCE approved credential for supervisors of “ACS” to therapists during  
their Limited License in Counseling and/or Internship as they work towards their full Professional Counseling License. I  
also provide supervision to other therapists in the agency I work for.  
In behalf of providing supervision in modalities that will be equitable in learning, time, and financial management I am  
requesting that the language in the Counseling General Rule to be updated to the current and future scope of providing  
supervision from “in immediate physical presence” to language that encompasses our current and future modalities of  
supervision administration and oversight of development and monitoring of current and future Professional Counselors.  
In the purposed rule 2020-33LR under Part 3. Licensure  
Rule: R 338.1774 Application requirements; licensure by examination. It states the following in subsection:  
(i)  
….. regularly scheduled supervision accrued in the immediate physical presence of the supervisor. Of the  
100 hours, no more than 25 hours may be accrued via 2-way real-time audiovisual technology that allows  
direct, contemporaneous interaction by sight and sound between the supervisor and the supervisee.  
And in subsection:  
(ii) …… regularly scheduled supervision accrued in the immediate physical presence of the supervisor. Of the 50  
hours, no more than 15 hours may be accrued via 2-way real-time audiovisual technology that allows direct,  
contemporaneous interaction by sight and sound between the supervisor and the supervisee.  
Suggested change in Subsection (i) and Subsection (ii) (as stated above) to…  
Regularly scheduled supervision to be accrued between the applicant and the supervisor on an individual or  
group basis either in person or using a telecommunication method that provides for live and simultaneous  
contact.  
Respectfully submitted,  
Christine Gjestland LBSW, LPC, NCC, ACS  
Community Services Coordinator & Mental Health Therapist  
From:  
To:  
Subject:  
Date:  
Purposed rule: 2020-33LR  
Monday, September 21, 2020 2:51:01 PM  
Attachments:  
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Greetings,  
I am a Limited Licensed Professional Counselor in the state of Michigan, and I am writing concerning  
purposed rule 2020-33LR in regards to the guidelines for licensure supervision. The current  
language limits the ability for professional counselors to receive supervision via virtual options. Due  
to the COVID-19 pandemic, this rule potentially places both supervisor and supervisee at additional  
risk of exposure, which consequently increases the exposure risk of our clients. Furthermore, I  
believe that the need to meet supervisors in person, while definitely preferable, is not strictly  
necessary. Research suggests that the benefits of teletherapy are comparable to those of in-person  
therapy; though there is not a significant body of research indicating that tele-supervision is as  
effective as in-person supervision, it stands to reason that the results are likely similar.  
I am requesting that the language in the Counseling General Rule to be updated to the current and  
future scope of providing supervision from “in immediate physical presence” to language that  
encompasses our current and future modalities of supervision administration and oversight of  
development and monitoring of current and future Professional Counselors.  
In the purposed rule 2020-33LR under Part 3. Licensure  
Rule: R 338.1774 Application requirements; licensure by examination. It states the following in  
subsection:  
(i)  
….. regularly scheduled supervision accrued in the immediate physical presence of the  
supervisor. Of the 100 hours, no more than 25 hours may be accrued via 2-way real-  
time audiovisual technology that allows direct, contemporaneous interaction by sight  
and sound between the supervisor and the supervisee.  
And in subsection:  
(ii) …… regularly scheduled supervision accrued in the immediate physical presence of the  
supervisor. Of the 50 hours, no more than 15 hours may be accrued via 2-way real-time  
audiovisual technology that allows direct, contemporaneous interaction by sight and  
sound between the supervisor and the supervisee.  
Suggested change in Subsection (i) and Subsection (ii) (as stated above) to…  
Regularly scheduled supervision to be accrued between the applicant and the supervisor  
on an individual or group basis either in person or using a telecommunication method that  
provides for live and simultaneous contact.  
Respectfully submitted,  
Connor Jewell, MA, LLPC  
Home-Based Clinician  
Cell: (517) 388-2731  
Office: (517) 783-4250  
Fax: (517) 783-4164  
1206 Clinton Rd  
Jackson, MI 49202  
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From:  
To:  
Subject:  
Date:  
Purposed rule: 2020-33LR Rule set title: Counseling General Rules (R338.1751- R 338.1781)  
Monday, September 21, 2020 9:14:24 PM  
CAUTION: This is an External email. Please send suspicious emails to  
Department Of licensing and Regulatory Affairs  
Bureau of Professional Licensing- Boards and Committees Section  
P.O. Box 30670 Lansing, Michigan 48909-8170  
Attention: Policy Analyst Email: BPL-  
RE: Purposed rule: 2020-33LR  
Rule set title: Counseling General Rules (R338.1751- R  
338.1781)  
Draft Language update on: 8/17/20  
Greetings,  
I am a Limited Licensed Professional Counselor in the state of  
Michigan. I am requesting that the language in the Counseling  
General Rule to be updated to the current and future scope of  
providing supervision from “in immediate physical presence”  
to language that encompasses our current and future  
modalities of supervision administration and oversight of  
development and monitoring of current and future  
Professional Counselors.  
In the purposed rule 2020-33LR under Part 3. Licensure  
Rule: R 338.1774 Application requirements; licensure by  
examination. It states the following in subsection:  
(i)  
….. regularly scheduled supervision  
accrued in the immediate physical presence of the  
supervisor. Of the 100 hours, no more than 25  
hours may be accrued via 2-way real-time  
audiovisual technology that allows direct,  
contemporaneous interaction by sight and sound  
between the supervisor and the supervisee.  
And in subsection:  
(ii)  
…… regularly scheduled supervision  
accrued in the immediate physical presence of the  
supervisor. Of the 50 hours, no more than 15  
hours may be accrued via 2-way real-time  
audiovisual technology that allows direct,  
contemporaneous interaction by sight and sound  
between the supervisor and the supervisee.  
Suggested change in Subsection (i) and Subsection (ii) (as  
stated above) to…  
Regularly scheduled supervision to be accrued  
between the applicant and the supervisor on an  
individual or group basis either in person or using a  
telecommunication method that provides for live and  
simultaneous contact.  
Respectfully submitted,  
Michelle Lake MA, LLPC  
(517)612-3037  
From:  
To:  
Subject:  
Date:  
Support for MMHCA  
Tuesday, September 22, 2020 2:22:21 PM  
Hello,  
This is Roberto Overton. I had technical difficulties with my audio during the meeting. I want  
to support MMHCA on the proposed counseling rules set ( 2020-33 LR).  
Sincerely,  
Roberto Overton  
From:  
To:  
Subject:  
Date:  
Policy Analyst - Public Hearing 9/22  
Thursday, September 3, 2020 6:07:40 PM  
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Hello,  
I have received the notice of the upcoming Michigan Department of Licensing and  
Regulatory Affairs virtual public hearing on September 22nd. I would like to show my  
support and agreement with the discussion of "adding the National Clinical Mental  
Health Counseling Examination (NCMHCE) as an approved examination for  
licensure".  
Last year I moved to Michigan from New York where I was pursuing New York State  
Mental Health Counseling Licensure. New York requires its aspiring counselors to  
take the NBCC's National Clinical Mental Health Counselors Examination (NCMHCE). I  
successfully passed the NCMHCE before moving to Michigan.  
The National Board of Certified Counselors (NBCC) creates and administers the two  
state-recognized counselor examinations, the NCMHCE and the NCE. The content  
outline for the two exams are published on the NBCC's website and clearly  
demonstrate that both exams test counselors in the same 6 Domains. As stated in its  
content outline, this NCMHCE is a newer exam that was designed to frame the exam  
to reflect "the central clinical requirements of counselors through real world simulated  
cases." This is an advantage that the NCMHCE has beyond the multiple choice  
NBCC exam.  
I have been in the process of trying to see if my NCMHCE examination can qualify as  
an equivalent test to the NCE. This addition of the NCMHCE would be incredibly  
helpful as both examinations are extremely similar.  
I look forward to attending the hearing,  
Best,  
Rachel Toiv  
303-550-4882  
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