I am in firm opposition to the petition to replace the existing degree program requirements for LPC's, LMFT's and other covered professions. 

The proposed language eliminates the standards of 18VAC115-20-49, which have served the state well over decades.

The Virginia licensure program for LPCs was one of the first in the nation.  It was and remains one of the highest standards for licensure and serves as a model for other states.   The fact that it was created in the Virginia is a key element in the decades of successful graduate training and committed counselors.  This occurred under existing and prior legislative language.  There is no compelling need to change the language in a way that turns over Virginia regulation to a specifically named out of state organization. 

In essence, the language cedes the authority of the state to the standards of an out of state, for profit organization that is not chartered to be responsive to the specific needs of Virginia.  For example, CACREP could change its requirements without soliciting any input from the Virginia Board of Counseling.  Citizens and those licensed by the board would have no guaranteed forum to express their views on changes and interpretations   With all due respect, by adopting the CACREP standard in name; this language needlessly surrenders state responsibilities and citizen participation.

The goals of conforming to CACREP standards can be achieved without binding those goals to the specific acts of the organization creating the standards.  Virginia colleges and universities can work directly with the organization to achieve approval or form a consortium in behalf of all Virginia graduate counseling programs.

Current and past Virginia law and regulation has served the state well. 

Retaining state autonomy and control serves the state well.

Guaranteeing citizen and professional participation in any future changes in the cited laws and regulations serves the state well.

The proposed change is unnecessary and may turn out to be unadvisable.

Respectfully submitted,

Michael T. Greelis PhD,LPC, LMFT
Private Practice, Herndon, VA