Assuring "minimal competency in clinical counseling" and clairfying "unprofessional conduct" are indeed core aspects of the Board. My concern is that recent changes in the interpretation of current regulations, along with the proposed changes, have and will have the consequence of limiting clinical counseling services through the denial of applicants who are competent to practice, and has the additional cost of restricting public agencies from accessing all possible funding sources, thus increasing cost to the state.

It seems unlikely that under the "Alternatives" section that there "are no viable alternatives" to how the Board now wishes to interpret and amend licensure regulations. To restrict competent professionals from being licensed as an LPC and limit agency funding sources there should be a compelling need. Under "legal basis" the Board is charged with "conducting inspections to ensure licensees conduct their practices in a competent manner." The Board should use this emperical data to drive any proposed changes in practice. Specifically which degrees and training have had the most complaints and/or diciplinary actions against them. Such data should be available to the public and State in helping them determine the appropriateness of any proposed changes. For example, recent changes in the interpretation of regulations has resulted in harming graduates from Virginia Universities who have obtained Master's in Clinical Psychology. The Board has denied these competently trained, at the State of Virginia's expense, from fully practicing harming those in need of services and the agencies these clinicians work for. Is there data indicating that these applicants have a disproportinate rate of disciplinary actions against them? If not,why deny them, harm those in need of clinical counseling mental health services, and the State of Virginia. The Board's change in interpretation of who is eligible for the LPC appears to be driven by philosopy and not coursework, training, or demonstable competence. This would be like the Board of Medicine not licensing graduates from Virginia medical schools who graduate with a D.O. rather than an M.D., something that Board does not do. Or the Board of Counseling limiting licenses to those who only are Freudian or behaviorial in orientation. Such restrictions are unneeded, costly to the state, state agencies and clients in need of services and do not enhance protection of the public.

Without documented and demonstrable harm the Board should revert back to previous interpretations of the regulations focusing on coursework and training experiences and not philosophy so as to "first do no harm". Restricting competent professions whether from counselor education programs or clinical or counseling psychology programs does do harm to such graduates from Virginia universities, the State of Virginia, clients in need of services and their families. There is a documented shortage of mental health providers in Virginia. The Board should help all who are qualified to become licensed to better serve this state. It is disheartening when graduates whom the state has subsidized are restricted from fully practicing and serving the needs of those in this state. Often Virginia has lost these graduates to neighboring states who benefit from the training these students received in Virginia. Currently the Board's change in philosophy has had a real cost without any documented benefit. The Board should return to documenting required coursework, training, and clinical experience in determining who is eligible for the LPC and not philosophy or orientation.

I received my M.S. in Clinical Psychology from Radford University and was immediately hired in the emergency services unit for the New River Valley Community Services as an emergency services clinician. My job includes completing crisis interventions in the community, short-term crisis counseling, assisting in the psychiatric commitment hearings at St. Albans, and completing psychological testing and parental evaluations for social services. I have excelled at this position and had planned to get licensed so that I could stay with my agency and continue this type of work. After finding out that my degree is no longer considered license eligible I had to re-plan my career. I am now planning to return to school to get a doctorate in clinical psychology to pursue research instead of practicing in the community. If I had been able to get licensed with my initial degree I would probably have stayed in community mental health.

I earned a Master of Science degree in Clinical Psychology from Radford University.  At the time of my admission into the program, no graduate of the Clinical Pyschology program had difficulty obtaining Licensure in Virginia.  Despite taking an additional 21 hours in the Counselor Education department at Radford University, our program was deemed "not license eligible" after my graduation in 2009.

Upon my graduation from Radford University, I was hired as an emergency and assessment crisis clinician which required short-term crisis counseling, risk assessment, and crisis intervention.  After doing crisis work for a year, I moved to the Bridge Program also at New River Valley Community Services.  In my current position, I provide individual and group counseling to individuals involved in the criminal justice system who have mental health and substance abuse diagnoses.

As much as I enjoy my current position, not being license eligible in the state of Virginia has caused me to re-plan my career.  I now have to return to school and pursue a second Master's degree that will make me license eligible.  I even considered leaving the field of counseling to pursue social work.  Due to returning to school, I will be moving out of Virginia.

Two of my supervisors at New River Valley Community Services graduated from psychology programs at Radford University and were able to obtain licensure.  The Board does the Commonwealth and it's citizens a disservice by not allowing competent and well trained clinicians to obtain licensure.  The current interpretation of LPC regulations is causing the Commonwealth to lose clinicians, especially in community mental health, where we are most needed.

I graduated from Radford University in 2009 with a Master of Science degree in Clincial Psychology.  After graduation, I was immediately hired by the New River Valley Community Service Board as a crisis stabilization clinician, counseling high-risk clients on a short-term basis.  Shortly after getting hired, I received a letter indicating that the program I graduated from was not eligible for licensure.  After speaking with my previous professors and collegues, I found out that even though a M.S. in Clinical Psychology had been an acceptable degree for prior graduates seeking LPC licensure, it no longer appeared to be sufficient for the board.

This rejection of my LPC licensure application caused me to re-plan my career, and I applied to Virginia Tech's Human Development Ph.D. program and was accepted.  I am now attending school full-time and plan to graduate in 2013 with my degree.  My career plans now inlcude teaching at a higher education institution, rather than couseling.  Had my originial graduate program been acceptable to the LPC board, my career may have continued in the counseling field.

I highly recommend the board once again recognize the Radford University M.S. Clinical Psychology program as a suitable degree in LPC licensing requirements, otherwise more quality clinicians may be lost as they move or change career paths to accomodate the rejection of their LPC license application.

I am the supervisor of a treatment program through a CSB.  I have worked with several graduates from RU's clinical psychology program, their counselor education program, and their social work program.  I have found that the interns from the clinical program are no less capable of performing work in real clinical situations than interns from the other programs.  In many cases, the clinical program produces interns and residents who have superior skills and require less supervision than their cohorts from other programs; however, students from the other programs mentioned are deemed license-eligible because of the particular curricula are pre-approved.  At this point in time, the CSB is limited on who we can take as interns/residents for various positions because the students need to be license eligible.

As an employer, I respectfully request that the Board reconsider license eligibility for residents educated through clinical psychology programs.  They make excellent candidates to become strong counselors, not just clinical psychologists.

Thank you for your attention.

Heather Custer, LPC

After finding out that a number of our graduates had been denied for LPC eligibility in the state of Virginia, due to several reasons that we as students were unaware of in the Clinical Psychology program at Radford University, I was forced to transfer. I spent 2 years in the Clinical Psychology program, year-round, obtaining the core education requirements for the LPC. I was forced to change my direction and not graduate from the Clinical Psychology program at Radford University. I transferred to the Counselor Education program 1 month before graduating in order to save my career and salvage a chance to become an LPC. This was a costly decision that led to an extra full year in school and an additional $11,000 - $13,000 in tuition and living costs to add to my debt from graduate school. I worked full-time as a Community Support Professional and then a Short Term Crisis Clinician at New River Valley Community Services during this extra year of schooling that was necessary for me to possibly become license eligible. I recently graduated from Radford University with and M.S. in Counseling and Human Development. This also required me to restart and redo my supervision courses of practicum and internship after I already completed 700 hours of internship in the Clinicial Psychology program.

This has been a severe detriment to many lives in terms of finances, job satisfaction, career opportunities, and unneccessary extra education for fully trained and competent individuals. There are numerous professionals at my workplace that have sought extra education, completed extra education, or have settled for a career that does not require an LPC due to these new regulations. Many of my graduating class, alumni, and recent graduates have looked elsewhere for their residency and moved to different parts of the country where there education and experience would be accepted by licensing boards. Others have changed career paths all together due to the expense of graduate school and not wanting to obtain another degree that would better suit the requirements. The decisions by the board to no longer approve individuals who have completed the requirements necessary for an LPC has significantly impacted my life, my co-workers lives, and the people we serve.

I am writing as a supervisor and manager with New River Valley Community Services. I oversee 10-12 Master's-level clinicians in providing services for clients in crisis. In the past we have hired many very solid, very qualified clinicians coming out of Psychologoy Masters programs that have gone on to obtain their LPC without problem. We continued to hire quality candidates from both Psychology and Counseling programs under the presumption that, as has always been the case, they would be equally eligible for LPC, only to discover after hire that these fine clinicians were not eligible for LPC. This has caused us quite a crisis in 2 major ways. First, it has made these employees ineligible for key positions that they are abundantly qualified for (and that we truly needed and expected them to be able to fill). Second, it has compelled them to seek admission to other LPC-eligible graduate programs, meaning they will not be able to obtain licensure for several years, at a time when the positions they want and are uniquely qualified for have no other qualified candidates, positions that we need and planned to be filled in a matter of months.  

I understand that there are legitimate reasons to try to separate the fields of Counseling and Psychology. However, these candidates have literally completed the same coursework and are truly qualified by education to perform the duties of a Counselor--they vary from those graduating from CACREP programs in name only; it appears, to me, to be simply a matter of semantics and not substance. Further, even if the decision remains in years to come to exclude those coming from Psychology programs, it seems a terrible waste and a significant loss to the field to come to that decision so suddenly as to preclude an entire generation of solid clinicians from obtaining licensure. Rather, it seems much more reasonable to open a window of time for transition, as has been done with other changes in licensure requirements. This would allow those who obtained their degree and employment in good faith that they could obtain the LPC credential (based on longstanding history with the board) to obtain licensure, while also alerting all potential graduate students that after a certain year the LPC board will exclude Psychology-accredited programs.

Respectfully,

Reece Nielson, Ph.D., LPC, LMFT

I am outraged by the proposed regulatory changes to obtain a LPC. Making broad, sweeping changes without adequate warning to applicants who have previously completed coursework is haste, unfair, punitive and unethical. It is important to remember the process of becoming an LPC does not begin when one applies for supervision. Rather, it begins when students are choosing which graduate education program to attend. I feel that this reality has been forgotten by Board members and decision-makers. The consequences of this decision will dictate the life of my prospective and current career. Below is a first hand account of how the proposed changes to the licensure requirements will change the life of the recent graduate.

 Two and a half years ago I sat down and looked at the requiremets to get an LPC. Due to my passion for counseling and my interest in working with individuals with severe and persistent mental illness (SPMI), I decided to invest in my education and attend a Rehabilitation Counseling and Psychology Masters Degree program. I was informed by program staff that by completing their Rehabilitation Counseling program, upon graduating I would meet educational requirements for 1) National Certification as a Rehabilitation Counselor; 2) LPC licensure and 3) LSATP licensure. I invested two years and $80,000 in receiving my degree with hopes of applying for LPC and LSATP licensures so I could help individuals with co-occurring substance use and SPMI. During internship, I worked alongside students in Clinical Counseling programs, receiving identical treatment and engaging in the same activities. I provided individual counseling services for individuals with a variety of medical, psychological and interpersonal difficulties. Without pay, I completed 50-60 hrs/week so I could obtain the maximum amount of hours that could be counted towards my prospective LPC license. Upon graduating, I chose my employment based on the ability for the agency to provide me with clinical supervision and the opportunities needed to become a licensed professional counselor. Despite low salary, I chose to provide counseling services at Northwestern Community Service Board due to the agency’s willingness to help me on my journey to become a LPC. Northwestern CSB provides services to counties which make up Northwest Mental Health Catchment Area #27; a federally-designated Health Provider Shortage Area (HPSA) for mental health services. Last week I began the LPC application procedure where I learned about the proposed changes. If I was informed about these changes before I applied for master’s programs, I would have chosen a Clinical Counseling program. However, this is not the case. Without licensure, I will be unable to receive the level of gainful employment needed to replay my student loans. This will leave me two choices: 1) quit my job at Northwestern CSB and leave the state of Virginia; or 2) Get a second degree in Clinical Counseling. If my colleagues and I leave Northwestern CSB and Virginia, the shortage of mental health services in this area will be exacerbated and fewer individuals will be able to receive mental health services. If I invest 2 more years in getting a second master’s degree I will be paying thousands of dollars to repeat similar and identical courses while praying that that regulations will not change once again.

 With the exception of additional and specialized courses in severe and persistent mental illness and intellectual and developmental disability, Rehabilitation Counseling programs are identical to Counseling programs. As a prospective LPC, I would be able to provide specialized training in SPMI and have the ability to adequately address clients with intellectual and developmental disability. I feel that my educational background allows me to better counsel a diverse population. Counseling incorporates many populations, therefore increasing the utility of diverse counseling specializations. For example, all M.D.’s do not work in primary care or specialize in back pain.

So, if these changes take place, what are the hundreds of individuals who are passionate about counseling and in the same position as I supposed to do? The purpose of these regulatory amendments seems like a desperate attempt to tighten the reins on individuals who are becoming counselors due to liability and malpractice. However, I feel the licensing board can meet its needs and protect the LPC name by doing other activities, such as requiring higher examination scores, enact stringent GPA cut-off scores and so on. Changing the regulations after one has obtained the educational credentials is unfair, irrational and punitive.  I strongly encourage LPC board members to reconsider regulatory propositions and amend them in such a way that does not punish those who have completed the seemingly “invisible” portion of the LPC procedure.

I graduated from Radford University with a Master of Science degree in Clinical Psychology in May of 2009.  During my internship at Lewis-Gale Behavioral Health, my supervisor was a Licensed Professional Counselor who had graduated from the same program I was attending.  In addition to my supervisor, I personally knew several previous graduates from the program who had gone on to receive professional counselor licensure in the state of Virginia.  Therefore, I was surprised to receive a letter from the Board of Counseling's Executive director indicating that my application for professional counselor licensure did not meet the requirements as outlined in Virginia regulation 18VAC115-20-49.  The letter explained that the Clinical Psychology program I graduated from did not have appropriate emphasis on counselor preparation and that the intent of the program was to train students to be clinical psychologists rather than counselors.  To my knowledge, the program has not changed.  It is still confusing to me how the same program produced many other acceptable licensees in recent years, yet others were somehow deemed unacceptable. 

If the Board were judging applicants on some objective criteria, such as program emphasis on counselor preparation and program intent to train clinical psychologists rather than counselors as their letter indicated, why were some graduates from the same program acceptable and others unacceptable?  And if the concerns of the Board of Counseling were about me as an individual applicant, rather than the program from which I graduated, why weren’t those concerns outlined in the letter I received?

As a result of the Board's decision to not approve my LPC application, I was unable to obtain licensure in the state of Virginia with my current level of education.  I was forced to move to another state to pursue licensure, in order to put my training and education to use assisting community members with mental health concerns at a licensed level.  Had I been able to receive licensure in Virginia, community members there would be able to benefit from my graduate training.  It’s unfortunate that despite my training, experience, and completion of coursework that is very similar to that of students graduating from counseling programs, I will never be able to practice at the Master’s level in Virginia, the state where I was trained.

As an individual who has been "declined" to register for supervision due to these changes in criteria, I agree with the statements of Dr. Chase. 

I think these changes may prove ultimately detrimental to the entire field. In my case, I am having to reconsider my career path due to what amounts to a technicality to me.  I have held the same positions as LPCs and have had the exact same clinical work load as LPC colleges.  Strangely, no has said I couldn't do that because I have a clinical psychology as opposed to a counseling degree.  I'm sure others who are affected by these changes are having the same reactions.

Please reconsider these changes in light of the valuable members of this field that you may be losing to other professions.

I would ask that you revisit aspects of the revised regulations that are making it difficult for valuable and highly qualified mental health clinicians to pursue licensure as professional counselors.  I know of several individuals who have been impacted by these changes, and it would be unfortunate if they chose to pursue another profession/line-of-work because of the difficulties they have encountered.  Thank you for your consideration.