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BHEC staff: school-based LPC associates’ clinical hours may count but supervision, records and access pose practical limits
Summary
Agency staff and meeting attendees discussed whether LPC associates working as school counselors can count school time as supervised direct counseling hours. Staff said hours may count if the work is professional counseling, properly supervised and the district provides access for supervision; school records belong to the district.
Joni Adams asked whether LPC associates who are employed as school counselors may count their school‑based hours as direct counseling hours toward LPC licensure.
Christina DeLuna, board administrator for the LPC board, and Daryl Spinks, executive director, said school hours can count when the associate is performing professional counseling services that meet the board’s definition and is under required supervision. DeLuna pointed attendees to rule 681.31 as a place to compare the types of practice that qualify for professional counseling experience.
Spinks and DeLuna explained practical limitations: educational records in public schools belong to the school district rather than the individual licensee, so the district typically controls access to those records and would need to provide releases or supervisory access to permit an outside supervisor to review notes. Both staff members said that in many cases it is simpler and less risky when supervision is provided by someone inside the school system who already has access to educational records.
Spinks said informed-consent arrangements in school settings usually differ from private practice. Consent for school counseling often is a district-level consent signed by parents during enrollment or as part of school policy, rather than consent between the licensee and the family as in private practice. He said licensees should not expect to be required to maintain school records in the same way they maintain private‑practice progress notes.
Several experienced school‑based supervisors in the meeting said school districts sometimes contract or pay outside supervisors and can provide access when district policies allow. Agency staff recommended documenting supervised-experience hours on the supervisory-experience form so the agency can record hours already completed in case an associate later pauses practice or changes supervisors.
Staff and participants urged licensees and supervisors to consider: whether the associate’s duties are explicitly counseling (rather than school-only guidance), whether the supervisor has access to necessary records and whether informed-consent forms for district services include language allowing supervised practice and record sharing where needed.
The agency did not issue a new rule in the session; staff offered guidance and recommended supervisors and employing districts coordinate to ensure supervision, access, and documentation requirements are met.
