High ComplexityComing SoonAssociate Clinical Mental Health Counselor (ACMHC)Clinical Mental Health Counselor (CMHC)

Utah ACMHC → CMHC Supervision Requirements

Everything you need to know about completing your 3,000 supervised hours in Utah — including the new SB26 changes.

Total Hours

3,000

Calendar Minimum

18 months

Supervision

100

Direct Hours Floor

1,200

Why This State Is Complex

Utah's CMHC track is rated High complexity due to the SB26 reform creating two distinct requirement sets depending on when your ACMHC was issued (before or after May 1, 2024), mandatory direct observation hours, strict W-2 employment requirements, supervisor certification mandates, and an upcoming alternate exam pathway effective January 2027. Grandfathering timelines add additional tracking complexity.

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Key Requirements at a Glance

3,000 total hours of post-degree clinical mental health experience while licensed as an ACMHC
At least 1,200 hours of direct client care (post-May 2024 licenses; 1,000 for pre-May 2024)
100 hours of direct clinical supervision, including 25 hours of direct observation (post-May 2024)
Must be a W-2 employee at an approved facility (agency, hospital, school, non-profit, or government)
Supervisor must have 4,000+ hours of practice in 2 consecutive years and max 6 supervisees
Written supervision contract and Supervisor Verification Form must be filed with DOPL before hours accrue
Pass the NCMHCE examination (or qualify via alternate pathway after Jan 2027)
Complete 2-hour suicide prevention training and criminal background check

Common Pitfalls to Avoid

Working as a 1099 independent contractor — only W-2 employee hours qualify in Utah
Not filing the Supervisor Verification Form with DOPL before starting — hours logged before DOPL acknowledgment may not count
Confusing old vs. new requirements — licenses issued before May 1, 2024 follow different (grandfathered) rules through January 1, 2027
Assuming practicum or internship hours from graduate school count — they do not; all 3,000 hours must be post-degree
Submitting backdated supervisor verification forms — DOPL stopped accepting these as of January 1, 2023
Not tracking direct observation hours separately from regular supervision hours — the 25 direct observation hours are a distinct requirement

Frequently Asked Questions

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