If you're a registered mental health counselor intern in Florida, you've probably been told two numbers: 1,500 hours and two years. Both are roughly right and neither is the whole picture. The requirements live in three separate places — the statute, the Board's rules, and the form your supervisor eventually signs — and they don't all say the same thing at the same level of detail.
This guide puts all of it in one place, in the order it actually matters.
Your intern registration expires five years after it is issued, and it cannot be renewed or reissued. Not "you should finish in five years." It expires. Section 491.0045(6), Florida Statutes, is explicit: any registration issued after March 31, 2017 expires 60 months after the date it is issued.
Most guides lead with 1,500 hours. The hours are the work; this is the deadline. Everything below should be planned against it.
The requirements, at a glance
Here's an important distinction that trips up even well-written guides. The statute (s. 491.005(4)(c), F.S.) says only that you need "at least 2 years of clinical experience in mental health counseling" at the post-master's level. It never mentions 1,500 hours.
The specific numbers come from Board rule and appear on form DH-MQA 1181, the Verification of Clinical Experience your supervisor signs. That's the document that actually decides whether you're done.
| Requirement | Amount | Where it comes from |
|---|---|---|
| Face-to-face psychotherapy with clients | 1,500 hours | Board rule / DH-MQA 1181 |
| Supervision | 100 hours | Board rule / DH-MQA 1181 |
| Minimum duration | 100 weeks | Board rule / DH-MQA 1181 |
| Supervision frequency | 1 hr / 2 weeks | Board rule |
| Interactions that must be in person | 50% | Board rule |
| Individual supervision group size | ≤ 2 interns | Board rule |
| Group supervision size | 3–6 interns | Board rule |
| Interns per qualified supervisor | ≤ 25 | Board rule |
| Registration validity | 5 years | s. 491.0045(5)–(6), F.S. |
The 100-week clock and the 5-year cliff
Two time limits run at once, in opposite directions, and you have to satisfy both.
The floor is 100 weeks. You cannot finish faster, no matter how many hours you bank. An intern seeing 30 clients a week could hit 1,500 hours in roughly a year — and still be nowhere near eligible. If your plan involves working intensely to finish early, the clock doesn't care.
The ceiling is five years, and it's absolute. If your registration lapses before you've completed the experience and submitted your licensure application, you don't get an extension by default. Section 491.0045(6) allows the Board a one-time exception in emergency or hardship cases, and only if you've already passed the theory and practice examination. That is a lifeline, not a plan.
There is a fuller treatment of this in the guide to the five-year expiry — the arithmetic, the milestones, and what to do if you are already behind.
The practical failure mode looks like this: an intern works part-time for the first two years, has a life event, slows down, and arrives at year four with 900 hours logged and no idea that finishing is now arithmetically impossible. Nobody sends a warning letter.
Run your own numbers
The free supervision hours tracker projects your completion date from your actual pace and tells you plainly whether you'll finish before your registration expires. It also flags supervision gaps, the in-person ratio, and the group/individual balance. Nothing is uploaded — it runs entirely in your browser.
Open the tracker →Nothing before registration counts
Section 491.0045(4) is blunt: time spent completing the experience requirement before registering as an intern does not count toward it. There is no backdating and no credit for good intentions.
This catches people who graduate, start working at an agency, and get around to filing the registration application a few months later. Those months are gone. If you have graduated and intend to accrue hours, file the application before you see your first client.
Processing takes time. Your registration date is the date the Board issues it, not the date you applied. Build that lag into your planning, and use the issue date — not your start date at the job — everywhere it matters.
Individual, group, and the alternation rule
Florida distinguishes the two formats by headcount:
- Individual supervision — one qualified supervisor with no more than two interns.
- Group supervision — more than two interns, capped at six.
That second number surprises people: a session with two supervisees still counts as individual supervision. It's the size of the room that decides, not whether it feels like a group.
The rule people actually get wrong is what happens when you mix them. Each hour of group supervision must alternate with an hour of individual supervision. In practice this means your group hours should never run ahead of your individual hours. An intern who attends a weekly group and meets individually once a month will accumulate a group surplus that doesn't count the way they assume it does.
Group sessions must also occur in person with all participants present.
The 50% in-person rule and telehealth
At least half of all interactions between you and your supervisor must be in person. Before using any online method, you and your supervisor must have met in person at least once.
This one drifted badly after 2020 and a lot of supervision arrangements never drifted back. The rule counts interactions, which means a convenient run of video check-ins can quietly push you under 50% even when your total hours look healthy. If you're below the line, the only fix is more in-person sessions — you can't retroactively reclassify what already happened.
The two-week rule
You need at least one hour of supervision every two weeks. Not an average of one hour per two weeks across the internship — a session at least that often.
Gaps happen for ordinary reasons: your supervisor takes vacation, you're sick, the holidays land badly. Two things help. First, document the reason at the time rather than reconstructing it later. Second, know where your gaps are before the Board does — a supervisor signing DH-MQA 1181 is attesting to a pattern of supervision, and a log full of five-week gaps is a hard thing to sign.
Private practice: the premises rule
Buried at the end of s. 491.005(4)(c) is a sentence with real teeth:
"A licensed mental health professional must be on the premises when clinical services are provided by a registered intern in a private practice setting."
On the premises. Not reachable by phone, not available for consultation, not supervising you weekly. Physically there while you are seeing clients in a private practice setting.
This is the single most commonly violated rule I see, and almost always unknowingly. The classic version: an intern joins a small group practice, is given a caseload and a telehealth setup, and works from home three days a week. Everyone involved believes they're compliant because supervision is happening on schedule. The premises requirement is a separate obligation from the supervision requirement, and it isn't satisfied by good supervision.
If that describes your arrangement, raise it with your supervisor now rather than at licensure.
What counts as a face-to-face psychotherapy hour
The 1,500 hours are specifically face-to-face psychotherapy with clients. The things that surprise interns are usually what doesn't count: case notes, treatment planning, staff meetings, chart review, no-shows, training, and driving between sites. All necessary work. None of it accrues toward the number.
This is why 1,500 hours takes most people the full two years even in a busy setting. A full-time clinical job rarely produces 40 billable face-to-face hours a week; 20 to 25 is a realistic sustained pace, and that math lands you at roughly 60 to 75 weeks of direct service — before vacation, illness, or a caseload gap.
The forms, in the order you'll need them
Get these from the Board directly rather than from a copy someone emailed you — several were revised in 2025, and an outdated form gets returned.
Before you start
- Intern Registration Application (DH-MQA 1175) — the one that starts your clock, in both directions
- Qualified Supervisor Affirmation Statement (DH-MQA 5049)
- Mental Health Counseling Education Worksheet
While you're accruing
- Official Supervision Log (DH-MQA 5078) — required, and both you and your supervisor must keep current copies
- Qualified Supervisor Information Sheet
When you apply
- Application for Licensure by Examination
- Verification of Clinical Experience (DH-MQA 1181) — the form your supervisor signs, and the one that defines "done"
- HIV/AIDS Affidavit — required for initial licensure under s. 491.0065
If time is running out
- Intern Hardship Form — the one-time exception, available only if you've passed the exam
Common questions
Can I finish in less than two years if I work extra hours?
No. The 100-week minimum is a floor independent of your hours. You can finish the 1,500 hours early, but you cannot be licensed before 100 weeks have passed since your registration was issued.
What happens if my intern registration expires before I finish?
Under s. 491.0045(6), F.S., a registration expires 60 months after issue and may not be renewed or reissued. The Board may grant a one-time exception in emergency or hardship cases if you have passed the theory and practice examination. Do not plan around that exception — plan around the deadline.
Does supervision with two interns count as individual or group?
Individual. Florida defines individual supervision as one qualified supervisor with no more than two interns. Group supervision means more than two, up to a maximum of six.
Can all of my supervision be done over telehealth?
No. At least 50% of all interactions with your supervisor must be in person, and you must meet in person at least once before using online methods. Group supervision must be conducted in person with all participants present.
Do case notes and treatment planning count toward the 1,500 hours?
No. The requirement is 1,500 hours of face-to-face psychotherapy with clients. Documentation, staffing, chart review, training, and no-show appointments do not count.
Do hours I worked before registering count?
No. Section 491.0045(4), F.S., states that time spent completing the experience requirement before registering as an intern does not count toward it. There is no backdating.
Can I work in private practice as a registered intern in Florida?
Yes, but a licensed mental health professional must be on the premises whenever you provide clinical services in a private practice setting (s. 491.005(4)(c), F.S.). This is a separate requirement from supervision and is not satisfied by meeting your supervision hours.
This guide is information, not legal or Board advice. It reflects Chapter 491, Florida Statutes, and the Board's published guidance as of August 2026. Rules change, and individual circumstances vary. The Board and your qualified supervisor are the authority on your licensure — verify anything here against them before you act on it. Current requirements: floridasmentalhealthprofessions.gov.
Sources: Chapter 491, Florida Statutes (2025) · Board: Registered Mental Health Counselor Intern · Board: Qualified Supervisor Information (PDF) · Form DH-MQA 1181, Verification of Clinical Experience