Oregon · Supervisors

What Oregon Requires a Clinical Supervisor to Document, Keep, and File

Last updated August 7, 2026

There is no shortage of writing about what your supervisee has to do. What you have to do — the file you are required to keep, how long you have to keep it, and how fast the board can make you produce it — is in the rules and almost nowhere else. This is that half, in plain language, with the rule numbers so you can check every line.

Oregon splits it across two boards. If you supervise a Registered Associate on the LPC or LMFT track, your duties are in OAR 833-050-0091, written by the Board of Licensed Professional Counselors and Therapists. If you supervise a CSWA, they are in OAR 877-020-0012, written by the Board of Licensed Social Workers. The two rules are not variations on each other. They ask for different things, on different clocks, and if you carry a mixed caseload you are subject to both.

If you supervise an LPC or LMFT Registered Associate

One sentence in OAR 833-050-0091(1)(f) carries almost the whole record-keeping obligation. The supervisor must:

"Create and maintain for at least three years a record of hours of supervision and notes for each supervision session contemporaneously as supervision occurs, and provide it to the Board within fourteen days of request."

That is four separate requirements in thirty-five words:

• Two things, not one. A record of the hours of supervision, and notes for each session. An hour tally with no notes does not satisfy it; session notes with no hour count do not either.
• Contemporaneously as supervision occurs. Written while you are supervising, not assembled afterwards. This is the phrase that decides most of what follows.
• At least three years. The rule sets no start point, so the safe reading is three years from the end of the supervisory relationship rather than from each record's own date — the file for a supervisee who finished eighteen months ago is still live either way, and the difference only matters for the early records of a long relationship. We flag this as a reading rather than a rule because the text does not settle it; if you need certainty, ask the Board.
• Fourteen days from a Board request. Not fourteen days from when you get around to it, and not negotiable against your caseload that fortnight.

Read the last two together and the reason for the first becomes obvious. Two weeks is nowhere near enough time to rebuild a year of supervision from memory and a calendar, and a record rebuilt after the request is not contemporaneous by definition — the deficiency is visible in the document itself. The rule is not really asking you to be able to produce a file. It is asking you to have been keeping one all along.

The annual written evaluation

Separately, OAR 833-050-0091(1)(i) requires you to "provide a written evaluation of the registered associate's skills and progress annually and at the conclusion of the plan in a form and manner prescribed by the Board," and it "must include progress toward completion of the registered associate's plan." The same subsection adds that supervisors "may report to the Board at any time deemed necessary" — the annual cadence is a floor on your reporting, not a ceiling.

This is the OBLPCT annual Supervision Report, which since January 1, 2024 replaced the old six-month cycle. It is anchored on the date your associate's initial Registration Plan was approved rather than on a calendar year or anyone's birthday — the registration itself becomes effective at plan approval, per OAR 833-050-0061(1) — and it reports hours month by month: OAR 833-050-0111(1)(e) requires the associate's reports to include "the hours of direct client contact accrued by month," which is exactly why a running record beats a shoebox.

The other fourteen-day clock

OAR 833-050-0091(1)(e) requires you to "notify the Board within 14 days and explain any significant interruption to supervision or expected termination of the supervisory relationship." Note this is a different fourteen days from the records clock in (1)(f), triggered by a different event, and it runs on things that are easy not to treat as events at all: a supervisee's medical leave, your own sabbatical, a job change that everybody assumes will be sorted out next month. The rule says "expected termination," so the clock can start before anything has formally ended.

When you have concerns

OAR 833-050-0091(2) turns a professional or ethical concern about a supervisee into a reporting duty: you "must promptly notify the Board" and provide four specific things.

1. The specific concerns regarding conduct or performance.
2. The steps you have taken to address them.
3. A remedial action plan with measurable outcomes.
4. The associate's progress in addressing the concerns you raised.

The third item is the one supervisors are least prepared for. The rule does not envisage you handing the board a problem; it envisages you handing them a problem, a plan, and evidence of what has happened so far. Subsection (3) then lists what the Board can do with it — assign a new supervisor, require a health assessment or personal therapy, require additional training, extend the registration, place it on hold, or deny the license. Which is another argument for the contemporaneous record: items 2 and 4 are things you can only describe accurately if you wrote them down at the time.

The small one everybody misses

OAR 833-050-0091(1)(c) makes you responsible for your supervisee's public-facing materials — letterhead, business cards, advertisements, directory listings, brochures, "and any other representation" must carry the associate's correct title and your name, designated as "supervisor." If your supervisee has a Psychology Today profile or is listed on a group practice website, that is squarely in scope, and it is your obligation rather than theirs.

If you supervise a CSWA

The Board of Licensed Social Workers writes its supervision rule around what you submit rather than what you retain. OAR 877-020-0012(8) says a supervisor who agrees to supervise an associate must:

• (8)(a) — submit to the board, at intervals not to exceed six months, an evaluation of the associate's progress toward completion of the plan, on a form provided by the board;
• (8)(b) — report to the board in writing immediately if the associate is not complying with the plan of practice and supervision;
• (8)(c) — report to the board in writing immediately if the relationship ends earlier than the date provided for in the plan;
• (8)(d) — make other reports as required by the board.

Two of those are "immediately," which is a stricter standard than the counseling board's fourteen days, and both are triggered by things that feel provisional while they are happening — a supervisee who quietly stops scheduling, or a relationship everyone assumes will resume.

Before you report a missed cadence, though, check which cadence actually applies. The baseline is twice a month for at least an hour (OAR 877-020-0010(3)(b)(A)), but the same rule carries two legitimate departures from it, and neither is non-compliance:

• An approved reduction. Under 877-020-0010(4) an associate may request in writing that the board reduce the requirement to one meeting per month; the board weighs reasons such as reduced work hours, illness, or family responsibilities.
• The later phase of the plan. Under 877-020-0010(3)(b)(B), once the supervision and practice-hour requirements are met, the requirement itself drops to at least once each month.

So the reportable thing is an associate falling short of the cadence that applies to them, not of the twice-monthly default.

What the board expects supervision to actually cover

OAR 877-020-0012(7) is unusually specific about content. You and the associate are "expected to discuss cases with each other based on case notes, charts, records, and audio or visual tapes of clients, if available"; the associate must present assessments, diagnoses, and treatment plans; the treatment plans presented "must be appropriate"; and you must have authority to determine whether the associate's client population fits their level of expertise. Subsection (6)(c) backs that up by requiring the plan itself to give you authority to review and consult on caseload and treatment plans.

Remote supervision has its own conditions

This one catches people who moved supervision to video in 2020 and never revisited it. OAR 877-020-0012(9) binds clinical social workers who participate in supervision conducted by electronic video-conferencing media or telephone — so it lands on both of you, not on the supervisor alone. Whoever is on the call must ensure that clients whose records may be discussed give written consent to having confidential records and information transmitted electronically; must conduct the call in a setting and manner that protects both parties' privacy; and must use secure transmittal methods, with encryption named as the rule's own example. The consent requirement runs to the client, not the supervisee — which means it has to be built into intake paperwork, because it cannot be obtained retroactively for a conversation that already happened.

Before you take an associate at all

Worth stating precisely, because it is widely misquoted, including once in our own notes. OAR 877-020-0012(2) requires a plan supervisor to have completed two years of licensed practice, to have "completed and reported to the board at least fifteen (15) hours of initial continuing education … in techniques of supervision prior to commencing the supervision of an associate," to "complete at least six (6) hours of continuing education on supervision every five years," and to have passed the BLSW Oregon rules and statutes examination within the five years before commencing supervision. Fifteen up front and six every five years — not six instead of fifteen. The recurring six-hour obligation is the half that quietly lapses, because nothing prompts you.

A careful note about retention

We read chapter 877 division by division and did not find a rule attaching a retention period to the supervisor's own supervision records the way OAR 833-050-0091(1)(f) does on the counseling side. Do not read that as permission to keep nothing, and do not substitute the number that looks like it fits: OAR 877-030-0100 requires client records to be kept seven years from the last session, and that is a different duty about different documents. If you supervise on both tracks, the honest answer is that you are already subject to a three-year contemporaneous-record rule for part of your caseload, and keeping one standard is easier than keeping two.

The whole thing on one page

What this means for how you keep records

Nothing in either rule prescribes a format. There is no board-issued supervision log, no template, no software anyone requires you to use. What the rules do is set a shape: dated, per-session, written at the time, showing hours, retrievable years later, and convertible into a periodic evaluation on the board's own form without you having to reconstruct anything.

Which is a description of a habit more than a description of a tool. Supervisors who get caught out are almost never the ones who chose the wrong system; they are the ones who kept the record in the calendar, the supervisee kept it in a spreadsheet, and neither was written the week it happened. If you take one thing from the rules, take the word contemporaneously, and treat the ten minutes after a supervision session as part of the session.

The second thing worth building in is the deadline arithmetic, because it is not the same for two supervisees on your caseload. Worth being precise about what the rules do and do not fix here: 877-020-0012(8)(a) sets your evaluation duty as "intervals not to exceed six months" and names no anchor date, so the six-month clock is a maximum you can start anywhere. What is anchored is the CSWA's own BLSW reporting window, which runs off their birth month — so in practice supervisors line the evaluation up with that window rather than running a separate clock. An LPC or LMFT associate's annual cycle runs off the date their Registration Plan was approved instead. Four supervisees on mixed tracks means four independent clocks, and nobody is going to remind you.

This guide is informational, not legal advice. Licensure rules change — always verify current requirements with your board before making decisions about your supervision plan, and flag any discrepancies to support@almostlicensed.com so we can fix them.