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.