80 comments
As a GRADUATE OF OR STUDENT IN the University of Baltimore’s Applied Psychology Counseling Psychology MS training program, I oppose the Virginia Counseling Board’s stated (in meeting minutes and to prospective licensees) objective to restrict licensure to CACREP-program graduates. The University of Baltimore prepares counselors who have a strong counselor identity, as well as an appreciation for psychological science. I wish to retain my eligibility to practice in the state of Virginia as a well-qualified counselor. CACREP restrictions would eliminate my ability to ever move to, work in, and serve the residents of Virginia as a counselor, given that my graduate program is not CACREP accredited (nor is it eligible, based on the faculty’s degrees in clinical and counseling psychology).
In addition, I oppose the current regulation restricting supervision of counseling residents to LPCs and LMFTs. This regulation potentially endangers national licensure portability plans, further divides the sister professions of counseling and psychology, and limits options for clinical supervision during counselor residency at a time when consumers need more access to services, not less.
Maryland continues to include psychologists, social workers, and psychiatrists as supervisors for Licensed Graduate Professional Counselors (LGPCs; the analogous level of practice to Virginia’s “counseling resident”) and does not discriminate against licensure applicants from Virginia’s programs based on program accreditation, as there are no program accreditation requirements in Maryland for counselor licensure. As a neighboring state, I hope that Virginia will remain open to us as potential licensees, as Maryland remains open to Virginia graduates who meet educational requirements, regardless of program accreditation.
As a student in the University of Baltimore’s Applied Psychology Counseling Psychology MS training program, I oppose the Virginia Counseling Board’s stated (in meeting minutes and to prospective licensees) objective to restrict licensure to CACREP-program graduates. The University of Baltimore prepares qualified counselors who have a strong counselor identity, a good understanding of the ethics underlying the counseling profession, as well as a background in psychological science. Upon graduation, I wish to retain my eligibility to practice in the state of Virginia, and CACREP restrictions would eliminate my ability to ever move to, work in, and serve the residents of Virginia as a counselor, given that my graduate program is not CACREP accredited (nor is it eligible, based on the faculty’s degrees in clinical and counseling psychology). It can already be exceedingly difficult to find an appropriate therapist, and restricting licensure to graduates of CACREP-only programs will only make access to mental health and related counseling services more difficult for Virginia residents.
In addition, I oppose the current regulation restricting supervision of counseling residents to LPCs and LMFTs. This regulation potentially endangers national licensure portability plans, further divides the sister professions of counseling and psychology, and limits options for clinical supervision during counselor residency at a time when consumers need more access to services, not less.
Maryland continues to include psychologists, social workers, and psychiatrists as supervisors for Licensed Graduate Professional Counselors (LGPCs; the analogous level of practice to Virginia’s “counseling resident”) and does not discriminate against licensure applicants from Virginia’s programs based on program accreditation, as there are no program accreditation requirements in Maryland for counselor licensure. As a neighboring state, I hope that Virginia will remain open to us as potential licensees, as Maryland remains open to Virginia graduates who meet educational requirements, regardless of program accreditation.
As a student in the University of Baltimore’s Applied Psychology Counseling Psychology MS training program, I oppose the Virginia Counseling Board’s stated (in meeting minutes and to prospective licensees) objective to restrict licensure to CACREP-program graduates. The University of Baltimore prepares counselors who have a strong counselor identity, as well as an appreciation for psychological science. I wish to retain my eligibility to practice in the state of Virginia as a well-qualified counselor. CACREP restrictions would eliminate my ability to ever move to, work in, and serve the residents of Virginia as a counselor, given that my graduate program is not CACREP accredited (nor is it eligible, based on the faculty’s degrees in clinical and counseling psychology).
In addition, I oppose the current regulation restricting supervision of counseling residents to LPCs and LMFTs. This regulation potentially endangers national licensure portability plans, further divides the sister professions of counseling and psychology, and limits options for clinical supervision during counselor residency at a time when consumers need more access to services, not less.
Maryland continues to include psychologists, social workers, and psychiatrists as supervisors for Licensed Graduate Professional Counselors (LGPCs; the analogous level of practice to Virginia’s “counseling resident”) and does not discriminate against licensure applicants from Virginia’s programs based on program accreditation, as there are no program accreditation requirements in Maryland for counselor licensure. As a neighboring state, I hope that Virginia will remain open to us as potential licensees, as Maryland remains open to Virginia graduates who meet educational requirements, regardless of program accreditation.
Providing quality mental health treatment is vital for the well-being of the citizens of Virginia. Limiting access to those from CACREP-accredited programs only not only fails the hardworking students, alumni, and faculty of other qualified mental health programs, it fails the people of Virgina more broadly. The move to curtail licensure in Virginia is self-serving and short-sighted and most assuredly not in the best interest of the residents of Virginia.
Do not allow CACREP to restrict the practicing scope of licenced counselors.
Please oppose CACREP and ACA efforts to exclude other highly qualified licensed mental health professionals such as psychologists from providing supervision to students and licensure candidates. With the growth of holistic and multidisciplinary clinics, the proposed restriction unfairly penalizes students and prospective licensees working in these settings or who seek excellent training in these settings. Since these settings are predominantly responsible for mental health service provision in our state, this unfair exclusion will ultimately negatively impact the ability to meet the mental health needs of your constituents as well.
As a student the University of Baltimore’s Applied Psychology Counseling Psychology MS training program, I oppose the Virginia Counseling Board’s stated (in meeting minutes and to prospective licensees) objective to restrict licensure to CACREP-program graduates. The University of Baltimore prepares counselors who have a strong counselor identity, as well as an appreciation for psychological science. I wish to retain my eligibility to practice in the state of Virginia as a well-qualified counselor. CACREP restrictions would eliminate my ability to ever move to, work in, and serve the residents of Virginia as a counselor, given that my graduate program is not CACREP accredited (nor is it eligible, based on the faculty’s degrees in clinical and counseling psychology).
In addition, I oppose the current regulation restricting supervision of counseling residents to LPCs and LMFTs. This regulation potentially endangers national licensure portability plans, further divides the sister professions of counseling and psychology, and limits options for clinical supervision during counselor residency at a time when consumers need more access to services, not less.
Maryland continues to include psychologists, social workers, and psychiatrists as supervisors for Licensed Graduate Professional Counselors (LGPCs; the analogous level of practice to Virginia’s “counseling resident”) and does not discriminate against licensure applicants from Virginia’s programs based on program accreditation, as there are no program accreditation requirements in Maryland for counselor licensure. As a neighboring state, I hope that Virginia will remain open to us as potential licensees, as Maryland remains open to Virginia graduates who meet educational requirements, regardless of program accreditation.
Please upohld inclusive supervision requirements that includes licensed psychologists, psychiatrists, and social workers – CACREP cannot be the only licensing option.
Greetings. I am writing to oppose the Board of Counseling’s continued efforts to restrict Virginia counselor licensure to graduates of programs accredited by CACREP, despite official withdrawal of the proposal last Fall. So why is this important to me as a graduate college professor in New York? I am a professor for a mental health master's program at the University at Buffalo so it is on behalf of my students that I am writing to you today. There are plenty who will write to you opposing these efforts who will speak to the importance of inclusive licensure process where the emphasis is on accrediation (as it should be) rather than one accrediting body. I agree with those points wholeheartedly. It is essential to my students, who are not from a CACREP accredited program to have the ablity to apply for licensure in all 50 states. And that is the point that I want to emphasize.
There is much need in our various communities across this country, especially in states with large rural populations, to have enough licensed professionals to meet the needs. There are many mental health disparities that need to be addressed and many populations that are under-served. Between high rates of depression and suicidality and high levels of addiction with opioid and other drugs, there is so much work to do and we need all hands on deck. For that reason it is vital that we reduce the systems and structures that will slow down or limit the ability of individuals to get licensed.
I urge you to support the withdrawl of the proposal and support inclusive licensure for Virginia. I am happy to speak with you further about this if you so wish.
Amy L. Reynolds
August 30, 2018
To the Virginia Leadership:
In response to the current periodic review of the Regulations Governing the Practice of Professional Counseling (18 VAC 115 20), we are writing this letter to strongly encourage you to reject any attempt by the Virginia Board of Counseling to restrict counselor licensure to graduates of programs accredited by the Council for the Accreditation of Counseling and Related Educational Programs (CACREP). We further request that you consider reviewing and removing the recent 2016 revision of the regulations (18 VAC 115 20) that restricts counseling residents in Virginia to receiving supervision from only Licensed Professional Counselors (LPCs) or Licensed Marriage and Family Therapists (LMFTs). Prior to the revision, psychologists, social workers, and psychiatrists were able to provide supervision to counseling residents.
We are concerned, based on the Virginia Counseling Board’s meeting minutes and reports from prospective licensees, that proponents of CACREP accreditation are again poised to attempt to restrict the license-eligibility of graduates from psychology-based counselor master’s programs. (CACREP does not accredit psychology-based programs; only MPCAC accredits psychology-based counseling master’s programs.) If this movement continues unopposed and is successful, graduates of our Applied Psychology program and other non-CACREP accredited counseling master’s programs in Maryland (that is, the majority of Maryland programs) will not be license-eligible in Virginia, simulating a type of regulatory capture and limiting the availability of well-trained practitioners from serving Virginia residents. In fact, only about 30% of counseling programs nationally are CACREP-accredited, thus reducing the number of eligible practitioners able to enter and practice in the state of Virginia should such a regulation pass.
Over the past 30 years at the University of Baltimore, we have students who travel to our program from and intend to practice in Virginia; CACREP licensure restrictions are a threat not only to our students and their professional goals, but to most Maryland graduate counselor training programs in general. The counselor licensure requirements of Maryland do not name any specific program accreditation for gradutes seeking licensure and do not restrict graduates of Virginia counseling programs from seeking licensure in Maryland based on program accreditation. In addition, the profession of counseling is currently exploring ways to enhance portability of counselor licensure. Restrictions in one state that are not shared by other, and particularly neighboring, states are likely to complicate efforts toward portability. We encourage you to review the 2016 Economic Impact Report on the last proposed regulation changes that would restrict licensure in Virginia to CACREP graduates:
http://towhall.virginia.gov/l/GetFile.cfm?File=C:\TownHall\docroot\25\4259\7390\EIA_DHP_7390_vE.pdf
Rejecting a CACREP-only agenda does not threaten CACREP, the public, or the profession of counseling. Those schools that choose to seek CACREP accreditation remain free to do so. Those schools, such as George Mason University (GMU), that do not choose to seek CACREP accreditation may still train and graduate well-prepared counseling professionals to serve the residents of Virginia. GMU counseling program graduates are currently eligible for licensure in Virginia and have been serving the public for decades. Nothing will change regarding their training; only the restriction of a regulation change would render them ineligible for licensure, similar to the potential effects on many Maryland counselor training programs (and those across the country).
Finally, we urge you review and remove the regulation passed during Governor McDonnell’s Regulatory Reform Initiative (RRI) that removed psychologists, social workers, and psychiatrists as eligible supervisors of counseling residents. This regulation was changed during a broad RRI in 2012-2013, the motivation for which was to alleviate regulatory burdens and promote job creation for Virginia residents. It appears that this change did not get the same level of public scrutiny that it would have under the regular regulatory change, although 6 public comments in 2011 were all opposed to the action before its passage under the RRI. The change, though enacted under the RRI, was not specifically listed as such in the report to the governor in December 2013. Additionally, the change was antithetical to the purpose of the RRI (removing regulations to alleviate burdens), as it instead further restricted resident counselors’ ability to find qualified supervisors for their resident training period. The professions of psychiatry, social work, and most notably, psychology share theoretical, technical, and empirical bases for the work of mental health treatment with the profession of counseling. There is no evidence to suggest that these closely related professions and their licensed clinicians are unable to supply quality supervision to LPCs. Furthermore, these regulations are likely to interfere with portability of licensure between states, which is of great interest to Maryland training programs. Current Maryland state counseling regulations allow for psychologists, social workers, and psychiatrists (in addition to LPCs and LMFTs) to provide supervision to Licensed Graduate Professional Counselors (our version of counseling residents).
We appreciate your time and attention to our concerns regarding these important issues.
Sincerely,
Darlene Brannigan-Smith, Ph.D., Executive Vice President and Provost
Christine Spencer, Ph.D., Dean, Yale Gordon College of Arts and Sciences
Sharon Glazer, Ph.D., Chair, Division of Applied Behavioral Sciences
Courtney Gasser, Ph.D., L.P., N.C.C., Program Director, Master’s of Science in Applied Psychology-Counseling Psychology Concentration
I am writing to oppose 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. Such a restriction hurts the public and the large number of communities that remain underserved. Such a restriction will continue to marginalize many minority and diverse communities. I urge you to uphold inclusive supervision requirements that includes licensed psychologists, psychiatrists, and social workers to protect the public as well as the counselors from another CACREP only effort.
Arpana G. Inman, Ph.D. N.C.C.
Professor and Chair, Department of Education and Human Services
I am writing to express my opposition to 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. Such a restriction would result in a shortage of supervisors and thus represent a barrier to employment, which would in turn result in fewer service providers for clients in need.
I am also writing to express strong opposition to any regulations requiring graduation from a CACREP-accredited school in order to become licensed to practice. Such regulations are politically and financially motivated and have no supporting empirical data which show that providers from CACREP-accredited schools provide services which result in better client outcomes.
I am writing to voice my opposition to any changes to the law that would restrict professional counselors from receiving supervision from psychologists and other licensed behavioral health specialists. This change would place an undue hardship on counselors seeking supervision for licensure and would in turn restrict access to healthcare unnecessarily.
I’m writing to oppose 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. I’d like Virginia to return to more inclusive supervision requirements that includes licensed psychologists, psychiatrists, and social workers. All of these professions share a common education base that qualifies them to supervise counseling residents.
Also, I’m writing to oppose the Board of Counseling’s continued efforts to restrict Virginia counselor licensure to graduates of programs accredited by CACREP. Given the high level of mental health needs in Virginia, counseling professionals from non-CACREP programs who are equally or even better trained should be made available to serve the people of Virginia.
I urge you to oppose 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.
I also urge you to oppose the Board of Counseling’s continued efforts to restrict Virginia counselor licensure to graduates of programs accredited by CACREP, despite official withdrawal of the proposal last Fall. These continued efforts are documented in their minutes and are confirmed by reports from prospective licensees.
The proposed restriction that would limit licensure to graduates of programs accredited by CACREP and restrictions of graduates’ supervisors to LPCs and LMFTs are clearly NOT “necessary for the protection of public health, safety, and welfare or for the economical performance of important governmental functions,”
CACREP-only restrictions would create a government-imposed monopoly of a private organization that is not accountable to the citizens of Virginia. 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.
We also urge you 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.
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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I am writing to express opposition to any regulation in Virginia that restricts licensed psycholgosits from providing supervision to professional counselors. Counseling psychologists like myself have substatial training in providing supervision. During my professional training, I provided nearly 1000 hours of supervision to trainees, under the supervision of a licensed psychologist. Indeed, I believe that such training and oversight has prepared me and my colleagues in Virginia with the necessary experience and training to be effective supervisors. Excluding psycholgists from providing supervision to professional counselors seems more like a guild issue than an effort to protect Virginia residents.
Sincerely,
Daniel Walinsky, Ph.D.
To Whom It May Concern:
As the Director of Loyola University Maryland’s Clinical Professional Counseling Program, I am writing with the support of my colleagues (signed below) at Loyola, to oppose the Virginia Counseling Board’s stated (in meeting minutes and to prospective licensees) objective to restrict licensure to CACREP-program graduates. Loyola prepares counselors who have a strong counselor identity, as well as an appreciation for psychological science. I urge you to consider this decision carefully as many of our students decide to make their home in Virginia after graduating. CACREP restrictions would eliminate their ability to ever move to, work in, and serve the residents of Virginia as a counselor, given that Loyola’s graduate program is not CACREP accredited (nor is it eligible, based on the faculty’s degrees in clinical and counseling psychology).
Additionally, while Counseling and Psychology are in fact separate professions, psychotherapy is not profession-specific. There is far ranging research that demonstrates that no one profession produces more effective psychotherapists and no one profession is more effective in psychotherapy. Ensuring that well-trained and competent clinicians are available to meet the mental health needs of Virginia residents is essential. Making politically-motivated decisions to promote one profession over another (without evidence to support this) would not be in Virginia residents’ best interests.
Maryland continues to include psychologists, social workers, and psychiatrists as supervisors for Licensed Graduate Professional Counselors (LGPCs; the analogous level of practice to Virginia’s “counseling resident”) and does not discriminate against licensure applicants from Virginia’s programs based on program accreditation, as there are no program accreditation requirements in Maryland for counselor licensure. As a neighboring state, I hope that Virginia will remain open to our students as potential licensees, as Maryland remains open to Virginia graduates who meet educational requirements, regardless of program accreditation. Thank you for your consideration,
Katie J. Loomis, PsyD- Director of Clinical Professional Counselors Program Jeffrey Barnett, PsyD- Associate Dean- Loyola College of Arts and Sciences Carolyn Barry, PhD- Department Chair and Professor of Psychology Anthony Parente, MA, LCPC, Affiliate Faculty, Director of Masters Plus Program
I am writing as a counselor educator, whose students go on to practice in all states including Virginia, to ask that you reverse the recent regulation that restricts graduates’ choice of supervisors to people with LPC and LMFT licenses. That will provide unreasonable restrictions on the ability of new graduate counselors to obtain the supervised experience necessary to become licensed in a timely manner. The majority of available supervisors, and in fact mental health practitioners, are licensed psychologists, psychiatrists, and social workers, with whom counselors will work for the rest of their professional lives. It is also important to note that this regulation received substantial opposition during the public comment period, which was apparently disregarded in the process of adoption. Further, I continue to oppose any efforts to restrict counseling licensure to graduates of CACREP accredited programs. While accredition is important, there are other equally rigorous accrediting bodies, whose graduates will quite capably serve the residents of Virginia.
Pamela Foley, Ph.D.
I oppose 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! I also oppose the Board of Counseling’s continued efforts to restrict Virginia counselor licensure to graduates of programs accredited by CACREP.
The proposed restriction that would limit licensure to graduates of programs accredited by CACREP and restrictions of graduates’ supervisors to LPCs and LMFTs are clearly NOT “necessary for the protection of public health, safety, and welfare or for the economical performance of important governmental functions,” which are the goals of the periodic review.
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.
We also urge you to 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.
Thank you for your time and consideration,
Anthony Isacco
.
I’m writing to share that I oppose current regulations that restrict counseling residents’ supervisors to professionals with credentials as a Licensed Professional Counselor (LPC) or Licensed Marriage and Family Therapist (LMFT). I strongly encourage that Virginia return to supervision requirements that include licensed psychologists, psychiatrists, and social workers, all of whom are highly qualified to supervise counseling trainees.
Additionally, I’m writing to share my opposition to the Board of Counseling’s efforts to restrict Virginia counselor licensure to graduates of programs accredited by CACREP. Counseling professionals from non-CACREP programs are equally qualified, if not exceeding in their credentials. Virgina would be at a major disadvantage for serving its people if this was pursued.
To Whom It May Concern:
I am writing to oppose the current regulations that restrict counseling residents’ supervisors to people who hold Licensed Professional Counselor (LPC) or Marriage and Family Therapy (LMFT) licenses. Licensed social workers, licensed psychologists, and licensed psychiatrists are also qualified to provide excellent supervision to counseling trainees and bring a wealth of knowledge that will ultimately be beneficial to the clients and patients they serve. Supervision by other mental health professionals is also consistent with efforts to prepare health care professionals to work with members from other professions. This 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 would also like to oppose the Board of Counseling’s continued efforts to restrict Virginia counselor licensure to graduates of programs accredited by CACREP, despite official withdrawal of the proposal last Fall. These continued efforts are documented in their minutes and are confirmed by reports from prospective licensees. CACREP-only restrictions would create a government-imposed monopoly of a private organization that is not accountable to the citizens of Virginia.
The proposed restriction that would limit licensure to graduates of programs accredited by CACREP and restrictions of graduates’ supervisors to LPCs and LMFTs are clearly NOT “necessary for the protection of public health, safety, and welfare or for the economical performance of important governmental functions,” which are the goals of the periodic review.
Thank you for your consideration,
LaVerne A. Berkel, PhD
Licensed Psychologist
Greetings to the Viginia Board of Counseling,
The discipline of counseling is a technical offshoot of the discipline of psychology. Counselors and Counselor Educators, for most part rely on the scientific and practical work of psychologist as the base their expertise. The CACREP-Only movement is based on the desire to corner the market on mental health work. It has nothing to do with patient welfare or the the public good. In fact, it works against the public good by limiting the potential training opportunities for masters level counselors, both in terms of the provision of supervision and in terms of their exposure to a diverse faculty of mental health experts. I currently work as an Assistant Professor teaching in a Counseling Department. Based on regulations like "18 VAC 115 20 Regulations Governing the Practice of Professional Counseling” and "18 VAC 115 50 Regulations Governing the Practice of Marriage and Family Therapy,” I would not be able to share my particular expertise in counseling theory and practice.
As a Counseling Psychologist, I received over 5000 hours of supervised practical training in the provision of psychotherapy. I was required to take a course in clinical supervision as well as engage in supervised practice of clinical supervision. I was also required to build a deep understanding of psychological theory at both the undergraduate and graduate level, which is different from Counselor Education in that a psychology background is not always prerequisite for beginning counselor training. I share this with you not to claim any superiority, but to rebuff the idea that I should be restricted from assisting in the training of anyone who plans to provide psychotherapy.
I would ask that instead of placing CACREP-First, that you place the Public-First in your deliberations. I believe that Counseling is an important discipline, however I do not believe that it so unique that it must be taught by counselors exclusively. Nor should that desire for exclusive access to a market (i.e., a monopoly) be supported by the state.
Thank you for your time and consideration.
Dear Legislator,
I am a licensed psychologist, educator, and supervisor working in an institution of higher education and I have trained and supervised students at Master's and Doctoral levels in clinical, counseling psychology, and school psychology for over 25 years.
I urge you to oppose 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. Licensed psychologists, social workers, and psychiatrists all have sufficient preparation to provide such supervision. CACREP's restrictions on supervision limits mental health professionals' abilities to provide supervision to counseling trainees across a wide range of settings. These restrictions will diminish the availability of vital and valuable mental, emotional, and behavioral health services across multiple service settings and most particularly restrict and unnecessarily limit graduate training programs in their ability to train and supervise students in CACREP programs.
Please do not be fooled by CACREP's assertions that counseling licensure should to be restricted to CACREP programs. This is a market ploy to limit competition and force graduate training programs to hire CACREP graduates. Certainly, hiring decisions should be based on who is most qualified and not on who is in the club.
Please think about your constituents and their mental, emotional, and behavioral health needs and consider the impact of maintaining the CACREP restrictions or further narrowing the type of providers eligible for licensure along with those who are designated as "qualified" to supervise counseling residents and trainees.
Sincerely,
Heidi A. Zetzer, Ph.D.
To whom it may concern:
This letter represents the views of the Society of Counseling Psychology, Division 17 of the of the American Psychological Association, in response to recently learning that the Virginia Board of Counseling has forwarded a proposal to restrict supervision of counselors in Virginia to only professional counselors (LPCs) or marriage and family therapists (MFTs). If this proposal is approved it would limit mental health resources in a time when more resources are desperately needed rather than less to address the growing mental health services crisis in our nation. Presently, in the U.S. the demand for mental health services greatly exceeds the number of qualified mental health practitioners who can competently treat those experiencing psychological distress.
The Virginia proposal also fits with a political agenda designed to privilege CACREP accredited counseling programs over the many other qualified mental health care professional groups (psychologists, social workers, psychiatric nurses, non-CACREP trained counselors). While granting the wishes of CACREP would enhance the stature of this organization in Virginia, it would harm the public. As counseling psychologists we know that licensed psychologists are supremely qualified to provide expert supervision to individuals who serve the public through mental health interventions, psychological assessments, and psychotherapeutic practices. It makes no sense to disallow qualified people from supervising counselors in this time of great need. In this age of integrated practice and integrated professionalism across health fields, the Virginia proposal coming from the Board of Counseling flies in the face of the growing trend to find ways for health and mental health disciplines to work together in providing the best treatment possible to patients distressed with mental health and health problems.
Thus, we strongly urge you to NOT support this proposal which limits who can supervise mental health practitioners.
Sincerely,
Michael J. Scheel, Ph.D., ABPP
Vice President for Education and Training
The Society of Counseling Psychology
Division 17 of the American Psychological Association
I am a licensed professional counselor and a licensed psychologist, and I train both counselors and counseling psychologists. I would like to share why I oppose the regulations that would restrict counseling residents’ supervisors to professionals with credentials as a Licensed Professional Counselor (LPC) or Licensed Marriage and Family Therapist (LMFT). I would like to encourage that Virginia return to supervision requirements that include licensed psychologists, psychiatrists, and social workers. I believe that each of these disciplines are highly qualified to supervise counseling trainees. Additionally, I’m writing to express my opposition to the efforts by the Board of Counseling to restrict Virginia counselor licensure CACREP program graduates. Counseling professionals who come from non-CACREP programs are not only equally qualified, but also often exceed the clinical training requirements. Even more importantly, there is an immense need for supervision from multiple fields - from counseling to psychology, psychiatry, and social work to ensure there is a well-prepared group of helping professionals who are able to serve and meet the mental health needs of marginalized groups. Thank you for soliciting feedback on this issue.
As a graduate of a CACREP-accredited master's program, I strongly oppose legislation that would restrict the supervision of counseling trainees to LPCs and LMFTs. This would not only limit counseling students' access to clinical training opportunities and potentially delay their ability to graduate from their programs and achieve licensure, but also it would conflict with efforts to create an integrated health care system based on interprofessional collaboration. Integrated health care and interprofessional collaboration are now well-established principles of best practice in health-related settings. Legislation that limits supervision promotes professional silos and goes against efforts towards collaboration and integration to provide the best care possible to patients with mental health needs. In addition, legislation that restricts counseling licensure to graduates of CACREP-programs may have adverse consequences on consumers residing in areas where access to mental health services is limited; it has the potential to further reduce the number of LPCs in those areas and therefore further limit access to mental health care.
As a licensed clinical psychologist who has helped supervise and train master's level counselors for over 20 years, I believe the proposed restriction of those who can supervise counselors in Virginia to only those with a LPC or LMFT license is an inane and misguided regulation. It would unduly restrict experienced psychologists and social workers from providing supervision, and may harm those seeking/needing supervision by limiting their options of who can supervise them. In many settings, mental health and medical professionals from various disciplines work together on integrated teams, and it is often more convenient (and adds diversity in perspective) for counselors-in-training to find qualified supervisors from those in their workgroup, who may come from a related mental health professsion. In some rural areas, options for supervision may be quite limited, and this regulation could limit these choices even further.
A clear and decisive rationale does not exist for the restrictions that the Board has imposed...why curtail or restrict choice of (qualified and experienced) mental health supervisors? Why disregard typically well-trained licensed psychologists as providers of clinical supervision? Therefore, reverse the recent regulation that restricts graduates’ choice of supervisors to people with LPC and LMFT licenses. More broadly, the Board should take a stronger stance to respect graduates from programs that are not CACREP accredited (such as mine) that nonetheless provide rigorous academic and clinical training, and successfully prepare students to sit for licensure in any state.
Am strongly opposed to the restriction of licensure to CACREP-program graduates, and to the restriction of supervisor credentials. The protection of the public and superior training opportunities will be better served without these restrictions.
l oppose 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!
In addition, although not specifically part of this periodic review, I oppose the Board of Counseling’s continued efforts to restrict Virginia counselor licensure to graduates of programs accredited by CACREP.
I write in two capacities. One as an educator of counselors, many of whom, after graduation, live, work, and practice in Virginia. I also write as a consultant who does work in Arlington 3-4 times a year. Part of the ethics of the field of counseling, and mental health in general, is to broaden its reach to indivudals who, in other circumstannces, would not be able to access mental healthcare. Limiting access in the ways being proposed hurts the field, the providers, current and potential students, and related mental health professons that are essential to the function of a uniform social safety net. Regulation is essential, but the legislation being offered is restrictive and damaging.
I write in two capacities. One as an educator of counselors, many of whom, after graduation, live, work, and practice in Virginia. I also write as a consultant who does work in Arlington 3-4 times a year. Part of the ethics of the field of counseling, and mental health in general, is to broaden its reach to indivudals who, in other circumstannces, would not be able to access mental healthcare. Limiting access in the ways being proposed hurts the field, the providers, current and potential students, and related mental health professons that are essential to the function of a uniform social safety net. Regulation is essential, but the legislation being offered is restrictive and damaging.
It was with great regret that I reviewed the proposed regulation to limit counselor supervision to that provided by other counselors and family therapists. I was the longest serving president of the Maryland Chapter of AMHCA (LCPCM), and my heart is devoted to the development of our profession. But pragmatically when we create this limitation and exclude social workers, psychologists, psychiatric nurse practitioners, and psychiatrists as potential supervisors, we harm our new graduates in entering agencies, since these employers will only hire those who they can supervise. Many public agencies have a large concentration of social worker supervisors and many colleges are dominated by psychologists. We want our new graduates to be accepted into any employment setting. Our regulations must be realistic and flexible and not driven solely by professional identity concerns. In Maryland, we kept our regulations flexible, and new graduates have a wide choice of supervisors for half of their supervision, I would suggest Virginia follow our lead, as our example has worked and made counseling a major mental health profession in Maryland.
The proposed restriction that would limit licensure to graduates of programs accredited by CACREP and restrictions of graduates’ supervisors to LPCs and LMFTs are clearly NOT “necessary for the protection of public health, safety, and welfare or for the economical performance of important governmental functions,” which are the goals of the periodic review.
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.
We also urge you to 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 wm writing to indicate 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 rather than a more inclusive supervisory structure.
As the Academic Program Coordinator and Professor for the George Mason University Counseling and Development Program, I am strongly opposed to the proposed regulation to limit counselor supervision to people who hold an active Licensed Professional Counselor (LPC) or Licensed Marriage and Family Therapist (LMFT) license. Given the demand and need for mental health services both in Virginia and nationally and the corresponding lack of qualified mental health practitioners, this restriction, rather than helping to meet the mental health needs in the Commonwealth of Virginia, restricts supervisory training for counselors and may cause further human resource shortages in the provision of services. It is important to mention that there has been no research supporting this regulation that indicates a difference in quality or skill of trained counselors related to the profession of the supervisor. In fact, many of the textbooks and videos used in counselor graduate training are from psychologists, psychiatrists, and social workers. As the former head of the counseling departments at Ohio State University, Johns Hopkins University, and now George Mason University, I am proud to say that I have been involved with the training of 100s upon 100s of counselors who have received exceptional supervision from not only counselors, but also psychologists, social workers, and psychiatrists. I am strongly in favor of multiple professional disciplines providing supervision to counselors in training and strongly urge the Board to not support this very narrowly focused regulation that has no research basis.
I was the Academic Director of Seton Hall's Online Educational Specialist Program in Counseling until 2015. I continue to teach in the program. For many years our program has had a number of military personnel enrolled. I believe restricting the availbility of Internship supervisors could be especially problematic for active duty military students, who have little say as to where they may be stationed. Since Virginia is a state with a large military presence, I believe that this restriction would be very problematic for SHU students and likely others as well. This proposed restriction seems to serve programs, rather than students. John E. Smith, Ed.D.
I am the 2013 State Council of Higher Education for Virginia (SCHEV) Outstanding Faculty Award recipient and I strongly oppress the current proposed regulation of restricting supervision by only Licensed Professional Counselors (LPCs) or Licensed Marriage and Family Therapists (LMFTs). I believe this proposed regulation will do a great disservice to the Commonwealth of Virginia’s citizens/the public and the counseling profession. The reasons why I strongly oppose the proposed regulation are as follows:
VA has approximately 4,575 LPCs (VA LPC, 2016) and 850 employed LMFTs (U.S. Bureau of Labor Statistics, 2017), with approximately 40% of LPCs nationally 55 years and older who may be due for retirement in the near future. The study conducted by VA LPC (2016) reported that 7% of the LPCs will retire within the next 2 years and 24% are projected to retire in 10 years. With the growing society’s tension and pressures encountered by citizens that is frequently reported by mainstream news media and supported by empirical research, issues such as the opioid crises, race relations, xenophobia, interpersonal violence, gun violence, poverty, etc., there is and will be a growing demand for mental health counselors.With multiple factors such as 36% LPC who work in sole or group private practice (VA LPC, 2016) may allow this group limited opportunities to provide supervision; the projection of LPC retirements; and the proposed regulation to limit supervision to be done by only LPCs and LMFTs creates diminished supervisory opportunities for counselors working towards their license in Virginia and hence the reduction and delay of training the numbers of LPCs needed in the field to address these social issues.
This proposed restrictive regulation of only having those who are LPCs and LMFTs will further reduce VA public/citizens access to counseling by LPCs for those who come from diverse and/or underserved populations and communities.
The counseling profession, similar to other mental health professions, overlaps with various mental health professions and yet all these professions have acknowledged, understand and accepted their unique identities and those of other professions. The non-inclusive approach limiting supervisors for LPCs to only LPC and LMFT supervisors sets precedence for divisiveness within the mental health profession, by suggesting which mental health professionals are more qualified to provide clinical supervision for others.In a time where there are great mental health needs in Virginia and nationally with a high demand for mental health professions to assist with society’s social problems, I strongly believe that this regulation would foster divisiveness within the mental health professions and create harm to the population we serve.
Therefore, I strongly oppose to proposed regulation to restrict supervision of LPCs to only those who hold LPC or LMFT. I strongly urge an inclusive rather than restrictive supervision policy.
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I am writing to express opposition to the regulation restricting supervision of Virginia LPC candidates to Licensed Professional Counselors (LPCs) or Licensed Marriage and Family Therapists (LMFTs). Why impose further barriers to licensure in Virginia at a time when there is a critical need for mental health providers in all areas of the state? There is value in a diversity of clinical perspectives, opinions, and approaches. Restricting competent, experienced psychologists and social workers from providing supervision may hinder and potentially harm those seeking/needing supervision by limiting their options for supervision and employment (if there are no LPCs at an agency to supervise them, they will not be hired by that agency). The people of Virginia need access to qualified mental health professionals; this regulation may reduce access to counseling services at a time when those services are already difficult to obtain in many areas of the state.
I am a licensed counselor practicing in Lexington VA. My education and training was in Maryland - the course work was identical to that required by VA, in some subjects, it exceeded this states required curriculum. My professors included Licensed Counselors, Licensed Social Workers, and Psychologist - I believe this mix provided a thorough and rich foundation that prepared me well to serve the wide range of clients served in my community. The program, while provided through the Applied Psychology Division, was specifically designed for the Professional Counselor.
Moreover, as I have watched and read about Virginia's accredidation struggle, I have yet to see empiracle evidence to support this move other than a couple of percentage point difference on the national exam. Anyone in this field knows that it is not a 2 to 5 point difference on any exam that qualifies a person as a "good councelor". In my experience it is the richness of inclusiveness and diversity that enables young professionals to evolve into their avocation.
I applaud all the hard working, devoted professionals on the Board of Counseling - I do not envy the task you have in designing and enforcing policy and regualtions that serve the best interest of the Commonwealth. However, my community is under-served as it is - so many without health insurance and personal income to afford badly needed mental health support - please don't restrict that even further.
I believe those that support Restricted Supervision and CACREP accrediation come at this from their best intention; yet I urge you not to enact these proposal.
I am an educator who has actively trained masters and doctoral level counselors and psychologists for the past 27 years. I am writing to state my opposition to the current regulations that restrict counseling residents’ supervisors to individuals who hold an active Licensed Professional Counselor (LPC) or Licensed Marriage and Family Therapist (MFT) license rather than following more inclusive supervision requirements that allow supervision by licensed psychologists (who frequently have more education, training, and experience in clinical supervision), psychiatrists and social workers. The restriction is not based on any evidence about the relative quality of supervision by LPC or MFT individuals compared to other appropriately trained and licensed mental health providers. As a scientist, I am skeptical about regulations that have no empirical support and that bypass the standard levels of review for regulatory change. Rather than enhancing services to the citizens of Virginia, the current regulation is likely to restrict their access to services because new graduates from clinical mental health training programs will not be able to meet their supervision requirements, rendering them unable to be employed and offer services to the public. In other words, it creates a problem where none existed.
In a similar vein, there is no empirical support for the ongoing efforts by the Board of Counseling to restrict Virginia counselor license to graduates of programs accredited by CACREP. Again, rather than protecting the citizens of Virginia, restricting licensure only to graduates of CACREP accredited programs ignores the established quality of other programs and restricts the number of mental health workers available to serve the needs of the population. This is hardly in the best interest of the state. However, it does appear to be based in a guild mentality focused on establishing a state-sanctioned monopoly by a private accrediting body.
I am writing in opposition to the regulation, adopted under former Governor O’Donnel’s Regulatory Review in 2013, that eliminated psychologists and social workers as possible supervisors for counseling residents in Virginia. I am a psychologist and retired counseling educator. Across 4 decades I supervised students, taught in, and directed graduate counseling and psychology programs. My own training and that of the many hundreds of students I have known have been enriched by learning from psychiatrists, family therapists, social workers, addictions professionals, counselors, and psychologists. I can tell you, based on a lifetime of experience, that effective professionals from these various branches of the mental health field, when working with mental health clients, are all far more alike than different. Furthermore, the differences add rich perspective rather than detract from one’s educational experience. Excellent supervision, including nurturing trainees’ identity as professional counselors, is not the sole province those who hold the LPC or LMFT degree. Moreover, disallowing trainees to seek out supervision from the professional with expertise in a given specialty area they want to learn, does a disservice to both students and the public.
Counseling trainees who wish to develop expertise in evidence-based treatments for trauma or brain injury might be best served by psychologists who have trained and worked in the VA system. Those wanting to specialize in working with autistic children may find their best supervision from a behavior analyst, just as those with interest in couples or family therapy may be best mentored by an LMFT, competency in addictions by addictions professionals, and so on. In a given locale or setting, an LPC may be the best supervisor for each of these scenarios. But the opposite is also possible, and the choice should be available to the trainee.
Creating training silos that separate developing counselors from supervisors and mentors who may otherwise be best positioned to facilitate their professional development, is a mistake. This thinking guided my choice of faculty and clinical supervisors for multiple areas of training in the counselor training programs that I directed. I strongly believe that drawing from multiple disciplines is the best model for counseling training, and therefore I strongly suggest that the current restriction on the supervision be removed from the Virginia regulations.
For similar reasons, I oppose the Board of Counseling’s intention to require a degree from a CACREP-accredited counseling program for licensure as an LPC. Again, much is lost when the diversity of intellectual and professional traditions during training is limited, as is required under CACREP rules. Furthermore, there is no substantiated evidence that CACREP-accredited programs provide superior training. This is a national as well as a state concern, as all states grapple with how to best serve the public interest. Only three states require a CACREP degree for initial licensure, and in one state the restriction applies only to in-state applicants. Thus, overwhelmingly, states have not adopted CACREP as a licensure standard. The majority of counseling programs in the country are not CACREP-accredited, many (those based in psychology departments) cannot be, and many elect not to be, out of preference or due to the very high costs of obtaining and maintaining the accreditation. A CACREP-only policy in Virginia would put it out of synch with most states, limit training and employment opportunities across state lines, complicate attempts to establish portability of licenses among states, and, importantly, threaten the viability of one of Virginia’s premier counseling programs, at George Mason University, which has not chosen this accreditation.
For all of these reasons I strongly urge a return to inclusive policy in qualifications for supervisors of counseling residents, and rejection of any proposal to limit LPC licensure to graduates of CACREP programs.
I am in support of the regulations that support the need for CACREP accredited programs. However, I believe that Counselors should collaborate with psychlogists and psychiatrists to supervise all interns, especially, in agency settings. Counselors have to have exceptional training in ethcial guidlienes , and procedures, that pertain to client rights, and mandated Multi-cultural training, that is just very important, yet it is not a significant part of psychology, or psychiatry graduate programs. And we believe in the importance of the collaborative relationship that epitomizes the power of the client to advance past their challenges.
I have seen some of the worst ethcial breaches, that involve professionals who only have psychology and psychiatry courses, without CACREP acrediation. The agency settings are often like military Gestapo setting, and are not very suppoertive of individual rights and enhancing client growth, often because they have just eradicated their rights to individual liberties. This is where you see professionals treating many competent individual with very demeaning, condescending, and patroniing approaches that are just very insulting to the client.
And, historically, the race, gender, and social class, of the client have often affected these interactions. There is often that lack of respect, for individual perspectives, that is mandated in a CACREP accredited Counseling prograsm, that enforce a respect for diversity. This is why you see more psychologists and psychiatrists misdiagnosing African Americans and Latin Americans, for example, with improper diagnosis (Hood, 2002).
This is because while we counselors are required to acknowlwdgw the powerful influence, of external variables, such as, racism and sexism, our older Helping Professions have not added this requirement until recently. As such, an individdual, who has been a victim, of several hate crimes, for example, or encountered the "glass ceiling", previously, would probably have been misdiagnosed, by many of these professionals, as having an internal behavioral challenge, which is not accurate, or very helpful with helping clients to address their challenges, because every variable that affects these challenges is not adressed properly, or, even acknowlwdged in a competent manner, by that professional.
And, I have seen some surprising lack of proper assessment procedures with this population, until recently, with the new DSMV changes, that pertain to culture and social influences and assessment. This is a good step, and it epitomizes the need for respectful and open, collaboration among our professions. If you would like to get more information, pertaining to the ethical challenges, in agency settings, please check outt my comments , on "ACA Connect", on the American Counselors' Association's website.
Nicole Ellis
Licensure, School Counseling
I am writing in opposition to a change in the law that would restrict profesional counselors from receiving supervision from mental health professionals including psychologists or other licensed behavioral health specialists. Not only would this change negatively impact / restrict counselors seeking supervision and licensure, it also, ultimately, restricts access to healthcare for members of the public in need of mental health services.
This is bad for the profession in general. It imposes impediments to the rights of my colleagues to practice in Virginia.
I am a licensed psychologist in the state of Pennsylvania (PS017244) who has benefitted greatly from supervision from many professionals during my graduate and postdoctoral training. I collaborate with health care professional in many professions and continue to benefit from their multiple perspectives. I currently teach both Masters and Doctoral students and always encourage them to value the wealth of perspectives offered by supervisors who hold different credentials. I strongly believe that clients and students receive better care and education when supervision can be provided by multiple professionals. I strongly oppose 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.
In addition, I strongly encourage you to support analogous breath and diversity of professional perspectives by not restricting licensure to graduates of programs accredited by CACREP. CACREP-only restrictions would create a government-imposed monopoly of a private organization that is not accountable to the citizens of Virginia. Rejecting this proposal would not harm any program that chooses to pursue accreditation through CACREP and would instead 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 as well as those who are affiliated with CACREP. I strongly oppose the Board of Counseling’s continued efforts to restrict Virginia counselor licensure to graduates of programs accredited by CACREP.
Thank you.
Sincerely,
Jennifer Q. Morse, PhD
Associate Professor and licensed Psychologist
Chatham University
Graduate Psychology Programs
Woodland Road
Pittsburgh, PA 15232
While I am not a resident of Virginia, I think it's important to voice my opposition publicly as a licenced psychologist as this is a national, as well as state issue. I oppose 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. I also oppose the Board of Counseling’s efforts to restrict Virginia counselor licensure to graduates of programs accredited by CACREP. I believe acceditation is an important quality control mechanism, however CACREP is only ONE credentialed accrediting body -- programs accredited by MPCAC and the soon to be accreditation granted by the American Psychological Association would be needlessly excluded by such legislation. We need more, qualified mental health professionals in the field, NOT a monopoly owned by CACREP which is what this regulation would do.
As a counseling educator and CACREP program graduate, I strongly oppose the regulatory reform initiative restricting program graduate choice of supervisors to LPCs or LMFTs. In providing mental health services to a diverse community with a spectrum of presenting concerns in a variety of contexts, it is in the best interest of public health, safety and welfare for the state of Virginia to support training, supervision and mentorship opportunities for graduates that reflect a variety of specializations. Supporting a CACREP monopoly on path to licensure would have significant and negative financial impacts for educational program, agencies, and limit access to necessary services to the public.
I am writing to express my strong opposition to any regulation or law that would exclusively restrict counseling residents’ supervisors to only those with Licensed Professional Counselor or Licensed Marriage and Family Therapist licenses. I request a return to inclusive supervision requirements which allow for a range of qualified licensed mental health professionals to provide required clinical supervision of counselor trainees. Excluding psychologists, psychiatrists, and social workers from providing clinical supervision to counselor trainees unnecessarily limits the training experiences available to such students. Moreover, it essentially excludes them from integrated models of behavioral health care which are now the cutting edge of the mental health profession.
I also strongly oppose efforts to restrict counselor licensure in any state to graduates of CACREP accredited programs only. Such a proposal, in essence, creates a government-sanctioned monopoly of a private organization (CACREP) which is not accountable to the citizens of the state in which the restriction is granted. The licensure process for counselors and other mental health professionals is meant to protect the public welfare. What CACREP proposes far surpasses the mandate to protect the public welfare and moves toward excluding qualified candidates simply because they chose an educational institution whose professional principles diverge from those of CACREP. The state licensing board must not abdicate its responsibility to protect the welfare of its citizens to a private organization such as CACREP. Please keep eligibility to sit for licensure a fair process wherein those who are qualified are granted the ability to apply for licensure based on their knowledge and abilities and not solely on what any one accrediting body has to say about the matter.