Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Counseling
 
chapter
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]
Action Changes resulting from periodic review
Stage NOIRA
Comment Period Ended on 9/18/2019
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9/17/19  5:38 pm
Commenter: Suzanne Lease, University of Memphis

Strongly oppose proposal unsupported by data
 

I teach classes in a CACREP-accredited program, but I know that there are no data supporting that students graduating from the program have better clinical skills than students graduating from other rigorous counselor training programs (either those that are MPCAC accredited or are otherwise designed to follow accepted training standards). Therefore, there is no support for a proposal that requires different amounts of post-licensure experiences for counselors graduating from CAREP programs versus counselors from other programs. To require seven additional years of post-licensure experience for some individuals with no rationale for doing so is ludicrous and likely invites legal challenge.

CommentID: 76237