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The Legal Department articles are not intended to serve as legal advice and are offered for educational purposes only. The information provided should not be used as a substitute for independent legal advice and it is not intended to address every situation that could potentially arise. Please be aware that laws, regulations and technical standards change over time. As a result, it is important to verify and update any reference or information that is provided in the article.
This article focuses on a few basic supervision requirements for Trainees and Interns, as well as, basic qualifications for LMFT supervisors.
Alain Montgomery, JD, Staff Attorney The Therapist May/June 2014 Updated December, 2022 by Ann Tran-Lien, JD (CAMFT Managing Director, Legal Affairs)
Supervision is an investment of time, money, and energy for both the licensed supervisor and the pre- licensed Trainee or Associate MFTs. To ensure the most beneficial and effective outcome of a supervision relationship, it is important for supervisors and Associate MFTs/Trainees to understand the fundamentals of supervision requirements. This article focuses on a few basic supervision requirements for Trainees and Associate MFTs, as well as, basic qualifications for LMFT supervisors. The Board of Behavioral Sciences (“BBS”) also provides information regarding supervision on its website at www.bbs.ca.gov.
To qualify for licensure, the Board of Behavioral Sciences (“BBS”) requires licensed marriage and family therapist applicants to obtain a total of 3,000 hours of supervised professional experience and 104 weeks of supervision. Fifty-two (52) weeks of the 104 supervised weeks must be weeks in which the applicant receives at least one hour of one-on-one, individual, or triadic face-to-face supervision.
DEFINITION OF TERMS
VIDEOCONFERENCING SUPERVISION In 2022, the law was changed to allow for videoconferencing supervision for all pre-licensees, regardless of work setting (see AB1758).
SUPERVISION RATIOS FOR TRAINEES AND ASSOCIATES A Trainee must receive at least one (1) unit of supervision for every five (5) hours of psychotherapy or counseling performed, per week, in each setting. vi A Trainee can average the number of supervision units obtained over time in order to claim the hours of psychotherapy performed during a particular week. For example, in one week, a Trainee can perform ten (10) hours of counseling and obtain one (1) unit of supervision. The Trainee will still be able to count all 10 hours of psychotherapy performed in that particular week, as long as, the Trainee obtains an extra unit of supervision during one of the remaining weeks the Trainee works at that site.
Associate MFTs must receive one (1) unit of supervision for the first ten (10) hours of counseling performed, per week, in each setting. In a week during which more than ten (10) hours of psychotherapy is performed, the Associate MFTs must receive an additional unit of supervision. This does not mean that an Associate MFT needs one (1) unit of supervision for every ten (10) hours of counseling performed. Rather, for any hour over the tenth hour of psychotherapy performed – whether it is one hour, five hours, ten hours, twenty hours, or thirty hours – the Associate MFTs only needs to obtain an additional unit of supervision. For example, if an Associate MFT works at one setting, and performs 17 hours of psychotherapy in a week, the Associate MFT needs one (1) unit of supervision, and also needs just one (1) additional unit of supervision for that week. Thus, the maximum number of supervision units the Associate MFTs would need to acquire that week, at that setting, would be two (2) units of supervision. Associates could obtain more supervision hours, if required.
Two important pieces of information to remember are that: 1) ratios for trainees and Associate MFTs must be maintained in each setting at which the Trainee or Associate MFT works, and 2) the maximum number of supervision units the BBS will count towards licensure is six (6) hours of supervision, whether individual, triadic, or group a week.
GENERAL QUALIFICATIONS FOR SUPERVISORS OF TRAINEES AND ASSOCIATE MFTS A licensed mental health care professional must satisfy certain requirements in order to be a qualified clinical supervisor to an MFT Trainee or Associate MFT. The qualification standards are different depending on the type of license held by the mental health care professional. This following segment will focus on the general qualifications required for LMFT supervisors.
General Qualifications Licensed mental health professionals interested in providing supervision to MFT Trainees and Associate MFTs must meet certain qualifications in order to qualify as a supervisor. A few notable qualifications include:
Have and maintain a current and active California license that is in good standing and not under suspension or probation.
Have held an active license for at least two (2) of the past five (5) years immediately prior to commencing supervision.
Have either practiced psychotherapy (or psychological counseling if an LEP) or provided direct clinical supervision of qualifying supervisees who perform psychotherapy for at least two (2) years within the five (5) year period immediately prior to commencing supervision.
Have completed the initial supervisor training/coursework that was required at the time the supervisor began began supervising (or will complete it within 60 days of commencing supervision).
Have completed (or if not yet required, will complete) six (6) hours of continuing professional development (CPD) in supervision during each subsequent license renewal period. S
Has sufficient experience, training, and education in the area of clinical supervision to competently supervise individuals gaining experience toward licensure.
All qualifications and requirements can be found here: https://www.bbs.ca.gov/pdf/forms/supervision_agreement.pdf
A licensee’s failure to maintain a current and valid license will prevent a supervisee from being able to count the hours gained during the period under which the supervisor’s license was either, delinquent, suspended, or on probation. Thus, it is important for supervisors to submit their renewal applications to the BBS in a timely manner. Also, it is recommended that Trainees and Associate MFTs keep themselves informed as to when their supervisor’s license expires and whether or not the supervisor renewed his/her license.
BBS Forms The following forms are required to document a Trainee or Associate MFT hours of experience:
Experience Verification Form
In-State Experience Verification
Out-of-State Experience Verification
The Experience Verification form is used to document the supervised clinical experience of a Trainee or Associate MFT. The Trainee’s or Associate MFT’s supervisor transfers the total hours in each category from the weekly log to the “Experience Verification” form, completes the appropriate sections, and signs the form. When an applicant submits an application for licensure and examination to the BBS, the “Experience Verification” forms should collectively document a total of 3,000+ hours of supervised clinical experience. Applicants should pay special attention to what documentation the BBS requires to accompany the application, including copies of the W-2 form or Volunteer Verification forms. The BBS advises separating pre-degree and post-degree experience on separate weekly logs and experience verification forms.
“Weekly Summary of Experience Hours” Prelicensees are required to maintain weekly logs of all experience gained toward licensure. The “Weekly Summary of Hours” tracks the experience and supervision hours of a Trainee or Associate MFT. While some supervisors sign the weekly logs several weeks at a time, the regulations specify that the weekly summary of hours “shall be signed by the supervisor on a weekly basis.” x
The “Weekly Summary of Hours” is NOT submitted to the BBS. However, the BBS may require the Trainee or Associate MFT to submit the forms to verify hours of experience. Thus, it is recommended that the Trainee or Associate MFT retain all of their weekly logs until licensed.
Supervision Agreement (for supervisory relationships that began ON OR AFTER January 1, 2022)
Supervisory Plan for LMFT Supervisees (for supervisory relationships that began PRIOR to January 1, 2022 AND continued PAST January 1, 2022)
Supervisors and supervisees must sign a Supervision Agreement within 60 days of the commencement of supervision. This form also includes a supervisory plan to be developed collaboratively by the supervisor and supervisee. The Supervision Agreement must be retained by the supervisee and submitted to the BBS with the Application for Licensure. This Agreement is to help ensure that supervisors and supervisees understand their requirements and responsibilities, and to help supervisees understand what is required for supervised experience to be accepted by the BBS. The Supervision Agreement replaces the Supervisor Responsibility Statement.
Supervisor Responsibility Statement (for supervisory relationships that began PRIOR to January 1, 2022)
The Supervisor Responsibility Statement is submitted to the BBS with the licensing exam application. The law requires any person who supervises a Trainee or Associate MFT to sign the “Responsibility Statement” under the penalty of perjury prior to the commencement of supervision
If you have more than one supervisor, each supervisor must sign a separate “Responsibility Statement.” Also, if a Trainee remains at the same site after their traineeship, and their status changes from Trainee to Associate MFT, the supervisor should complete a new form.
Sample Written Oversight Agreement
When a supervisor is not contracted with or employed by the work setting, a Written Oversight Agreement must be signed. The new content requires the employer to acknowledge their awareness that the supervisor will be providing clinical guidance and direction to the supervisee in order to ensure compliance with the standards of practice of the profession. This agreement must be provided to supervisees and submitted to the board upon application for licensure.
Substitute Supervisors When a supervisee obtains supervision temporarily from a substitute supervisor, the following are now required:
The substitute supervisor must meet all supervisor qualifications required by law; and
Sign the supervisee’s weekly log.
The substitute supervisor and the supervisee must also sign the Supervision Agreement
The substitute supervisor and supervisee’s employer must also sign a Written Oversight Agreement if required.
If the substitute will be supervising for MORE than 30 consecutive calendar days:
A new supervisory plan is also required, and
The substitute supervisor must also verify the supervisee’s experience gained during that time (the substitute supervisor must sign the Experience Verification form for hours earned under the substitute).
If the substitute will be supervising for 30 consecutive calendar days or LESS:
A new supervisory plan is not required. The substitute supervisor must follow the supervisee’s pre-existing supervisory plan.
The experience gained during this period may be verified by the regular supervisor (the regular supervisor may sign the Experience Verification form for hours earned under the substitute).
Supervisor Pass Away or Incapacitated Should a supervisor pass away or become incapacitated prior to signing off on their supervisee’s experience, the employer will need to provide the supervisee with documentation verifying the employment of the supervisor and supervisee (or, if the supervisor was not employed by the supervisee’s employer, you will need to provide a copy of the Written Oversight Agreement).
Conclusion It is important for supervisors and supervisees to have a thorough understanding of the requirements and qualifications each must satisfy. CAMFT encourages licensees, Trainees, and Associate MFTs to utilize the self-help resources provided by the BBS in addition to the resources available on CAMFT's website for information regarding supervision.