Dear Reader,

I’m writing to express my opposition to the current regulations that restrict counseling residents’ supervisors to people who hold an active Licensed Professional Counselor (LPC) or Licensed Marriage and Family Therapist (LMFT) license and urge a return to more inclusive supervision requirements that includes licensed psychologists, psychiatrists, and social workers. After unanimous opposition to this then-proposed regulation in a 2012 public comment period, it appears this new restriction was added as part of a part of a Regulatory Reform Initiative, bypassing the normal usual levels of review for regulatory changes.

CACREP-only restrictions would create a government-imposed monopoly of a private organization that is not accountable to the citizens of Virginia. It would also force George Mason University, an internationally respected counselor training program and the only counseling program in Virginia that is not, by choice, accredited by CACREP, to pursue that accreditation or close. Rejecting this proposal would not harm any program that chooses to pursue accreditation through CACREP; they can still do that. Rejecting this proposal would, however, maintain a path for licensure and service in Virginia for the national (and international) majority of students, alumni, and faculty in counseling programs that are not affiliated with CACREP.

I urge decision-makers to strike the regulation that restricts graduates’ choice of supervisors to people with LPC and LMFT licenses. That current regulation specifically excludes the majority of qualified supervisors in hospitals and related clinical settings, most of whom are licensed as psychologists, psychiatrists, and social workers. If this regulation is not changed, the experience in other states has been that this will pose a significant employment barrier to new graduates seeking employment in agencies and regions of the state where these supervisors are not available (and who can only offer supervision through psychologists or social workers). This policy actually harms the employment prospects of new counselors and hampers the growth of the profession. In addition, it should be noted that this regulation, which has yet to go into effect, was adopted outside the normal processes after a public comment period in which all commenters opposed the then-proposed regulation.

I am a psychologist with a PhD and have been training and supervising students who go on to be counselors for several years now.  I’m a licensed psychologist with the health service provider designation and have formal training in supervision of mental health clinicians (a requirement of ALL graduates from a counseling/clinical psychology doctoral programs).  It’s tough to argue that I’m less qualified than someone with a master’s degree (and no formal training in providing supervision) to supervise masters-level counseling residents.  The people of Virginia, like the people of Kentucky that I serve, need more mental health professionals available to them… not fewer.  Let’s not artificially restrict the pool of qualified supervisors, nor exclude high quality counselor training programs because they are uncomfortable pledging loyalty to the guild-first and Virginians-second policies of CACREP.

Thank you for your consideration,

Joseph Hammer, PhD

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Joseph H. Hammer, PhD, LP
Assistant Professor and Director of Training

Counseling Psychology PhD Program
Department  of Educational, School, and Counseling Psychology

243 Dickey Hall, University of Kentucky

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