MMHCA SUGGESTIONS TO LPC SUPERVISORS OF LLPCs

LPC supervisors who supervise LLPCs for licensure purposes, like all healthcare professionals, are struggling to determine how best to meet their professional responsibilities and the needs of those they serve in the face of the COVID 19 pandemic. In determining how to proceed with clinical supervision for LLPCs at this time, the Michigan Public Health Code requirements for this supervision need to be consulted.  The first directives are found in Section 333.16109:

          (2) “Supervision”, except as otherwise provided in this article, means the overseeing of or participation in the work of another individual by a health professional licensed under this article in circumstances where at least all of the following conditions exist:

          (a) The continuous availability of direct communication in person or by radio, telephone, or telecommunication between the supervised individual and a licensed health professional.

           (b) The availability of a licensed health professional on a regularly scheduled basis to review the practice of the supervised individual, to provide consultation to the supervised individual, to review records, and to further educate the supervised individual in the performance of the individual’s functions.

The current Administrative Rules of the Michigan Board of Counseling, R. 333.1752, Rule 2 (3) (a) (i) and (ii) require the regularly scheduled supervision be “in the immediate physical presence of the supervisor.”

In view of the guidance provided by the Michigan Public Health Code, MMHCA recommends the following guidelines for LPC supervisors of LLPCs:

  1. Make certain that there is continuous availability to communicate with supervisors as you always do. This requirement may be “by radio, telephone, or telecommunication“ if necessary.
  2. Make certain that you are available to your supervisees on a regularly scheduled basis.
  3. Assess the risks of in person contact for supervision in a professional and clinically appropriate manner, just as you would do with your clients.
  4. Be aware that only supervision done “in the immediate physical presence of the supervisor” may count toward the required 100 hours for licensure.

In summary:

-Remain in regular contact with your supervisors and be available for any emergency consults as you

always do.

-Assess the risks and benefits of continuing in person contact at this time and make a professional

and clinically sound decision as to how you will handle this.

-Only count those hours that are in person towards licensure requirements.

-Consider ways your supervisees can make up in-person hours, if necessary, when the crisis passes.