Michigan LLPC Supervision Requirements

100 Hours Is a Total, Not a Rate

The counseling rule states the supervision requirement as a quantity, not a pace: "not less than 100 hours of regularly scheduled supervision" for the 3,000-hour master's path, and "not less than 50 hours" for the 1,500-hour doctoral path (R 338.1774(1)(c)(i), (ii)). Neither subsection sets a weekly or monthly rate. Neither one splits the hours into individual and group categories, and neither states a group-supervision rule at all. Where Michigan's social work rules spell out a monthly minimum with an individual-hour floor, the counseling rule is silent on all of it: it names a total and stops.

That silence is worth stating plainly rather than filling in. A common assumption is that 100 hours across the 2-year minimum behind the 3,000-hour requirement works out to about 4 hours a month, and that arithmetic checks out, but it is arithmetic, not a rule R 338.1774 states. Nothing requires an LLPC to hit that pace in any given month; the rule's only word on timing is "regularly scheduled."

In Person or Two-Way Real-Time Audiovisual

Supervision has to happen "in the immediate physical presence of the supervisor or via 2-way real-time audiovisual technology that allows direct, contemporaneous interaction by sight and sound between the supervisor and the supervisee" (R 338.1774(1)(c)). Those are the two qualifying modes; a phone call, a recorded session, or asynchronous messaging does not satisfy either one.

Supervision Starts With the Limited License

"The supervision begins on the issuance of the limited license and continues until the licensed professional counselor license is issued" (R 338.1774(1)(c)(i)). For experience gained in Michigan, the applicant "shall have held a limited license ... while accruing the experience", and the supervising licensed professional counselor has to be "in good standing throughout the period of supervision" (R 338.1774(2)). Hours worked before the limited license issues do not count, and the rule requires the supervisor's good standing throughout the period of supervision.

What "Supervisor" Means Under the Rule

R 338.1751(1)(f) defines a supervisor as "a licensed professional counselor that received training in the function of counseling supervision, as specified in R 338.1781". R 338.1751(1)(g) defines being "under the supervision of a licensed professional counselor" as supervision by a Michigan LPC who meets R 338.1781, with one narrow exception for experience gained outside Michigan: the out-of-state supervisor can instead be an individual who "substantially satisfies" Michigan's LPC and supervisor requirements (R 338.1751(1)(g)). Both definitions tie back to the same rule, R 338.1781, that sets who is eligible to supervise.

No Supervising Without Training

The statute puts the obligation directly on the licensed professional counselor: an LPC "shall not supervise a limited licensed counselor without completing training in supervision" (MCL 333.18106). That training is the same requirement described in R 338.1781(2) below, and it applies regardless of how long the LPC has held a full license.

The Four Ways an LPC Qualifies to Supervise

R 338.1781(1) sets four routes, and an LPC has to satisfy one of them before providing supervision: (a) first supervised on or before Jan. 1, 2013, with supervision training and 3 years of post-master's practice in counseling; (b) first supervised after Jan. 1, 2013 and before May 5, 2022, with training meeting subrule (2) and 3 years of post-master's practice; (c) first supervised on or after May 5, 2022, with training meeting subrule (2) and "not less than 5 years of post-master's practice in counseling"; or (d) currently holding the Approved Clinical Supervisor (ACS) credential issued by the Center for Credentialing and Education (CCE).

The training itself, under subrule (2), is 2 semester hours of graduate credit in counseling supervision, or 30 contact hours of workshop training, covering nine listed topics: the roles and functions of a supervisor, models of supervision, the supervisor's professional development, methods and techniques of supervision, the supervisory relationship, cultural issues in supervision, group supervision, legal and ethical issues in supervision, and evaluation of supervisees.

The Supervisor's Written Statement of Qualifications

Before supervision begins, the supervising LPC has to provide the supervisee "a written statement that addresses the licensee's supervising qualifications" (R 338.1781(3)). That statement does not stand alone. It rides along in the LLPC's own professional disclosure statement, which every licensee gives to prospective clients (MCL 333.18113(1)). The LLPC's version has to add the supervising LPC's name, business address and telephone number, plus "a signed statement from the supervising licensed professional counselor about the licensed professional counselor's supervising qualifications, including how the supervising licensed professional counselor in this state satisfies the requirements in R 338.1781(1) and (2)" (R 338.1772(c)(iii)).

A separate disclosure statement is required per practice location, and changes have to be filed within 30 days. The LLPC's license cannot be issued without a disclosure statement on file, which makes the supervisor's written statement of qualifications a piece of paperwork that has to exist before the license itself does.

The Supervisor's Documentation Duty

The written statement of qualifications is not the only paperwork a supervisor owes. "A licensee that provides counseling supervision shall keep ongoing documentation including, but not limited to, performance and clinical notes, for each supervisee" (R 338.1781(4)). That duty runs for as long as the supervision relationship does, not just at the start or the end of it.

What the Supervisor Certifies on the Counseling Work Experience Form

Once the hours are complete, each supervisor fills out a section of the Michigan Counseling Work Experience form (LARA/BPL-COUNSELEXP, 4/25), a one-page fillable form filed with the LPC application. The applicant completes their name, date of birth, phone number and LLPC license number. The supervisor completes the agency name and address, certifies that the applicant "practiced counseling under my supervision from ___ to ___ for a total of ___ hours including ___ hours in my immediate physical presence or via 2-way real-time audiovisual technology", and certifies their own training under R 338.1781. The form also carries an availability certification in its own words: the supervisor states they were "available on a regularly scheduled basis to review the practice of the applicant, to provide consultation, to review records, to further educate the applicant and there was continuous availability of direct communication in person or by radio, telephone or telecommunication". The supervisor signs and gives their license number; an out-of-state supervisor gives their state and license type instead. A separate form is required from each supervisor.

No Prohibited-Relationship Rule, No Supervisor Registry

The counseling rules set no prohibited-relationship rule for this track, and none should be assumed from another state's rules. LARA publishes no registry of counseling supervisors, and the rules set no pre-approval step before supervision begins. Eligibility rests entirely on the supervisor meeting R 338.1781, confirmed through the written statement of qualifications and, ultimately, the Counseling Work Experience form.

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