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.