To ensure safe and competent patient care as outlined in the mission statement of the Department of Health Professions the Board should return to previous interpretations of regulations which emphasized academic training based on course content and demonstrated competence on internship and supervised practice rather than professional identification. Like many CACREP approved programs housed in Psychology Departments, the Board has historically considered graduates from accredited Clinical and/or Counseling Psychology Master's programs as meeting the academic requirements to initiate LPC credentialing. A distinction between counseling and psychology and clinical seems arbitrary given many CACREP approved programs, including some in this state, are in Clinical Mental Health Counseling. Virginia and Virginians are ill served when the Board limits those with demonstated competence to practice and serve individuals with mental, emotional, or behavioral disorders because of a putative distiction between the practice of counseling as defined in the code by those trained in counseling versus those trained in counseling or clinical psychology. An individual suffing from mental illness wants a skilled clinician irrespective of a degree in counseling or in psychology.   

   By not allowing competent clinicians who meet the course and practice requirements to become licensed professional counselors fewer clinicians are available to serve those in need, and equally important state agencies lose a revenue steam from their employees becasuse they can not bill for their services. This has resulted in long-term employees with demonstrated competence to lose their position within public mental health facilities and places an additional  financial burden on the agency. 

   It is unclear that the Board's recent rejection of applicants historically approved for the LPC from accredited Master's psychology programs from Virginia state schools was the result of a disproportionate rate of professional violations by such individuals, a result of increased public harm, or that the policy change increased the public welfare. If the Board can not provide the public, the Department of Health Professions, and the state legislature documentation as to unique and disproportionate harm by those who with Master's in psychology who meet the coursework and experience requirements then they should revert back to their past interpretation of code and allow such graduates to obtain the LPC.

   The Board should first and foremost ensure the competent practice of those counseling individuals suffering from mental illness through documenting coursework and clinical training. Emphasizing professional identity over documented training limits the public, and state agencies mandated to provide services to those suffing from mental illness. Counseling by a competent counselor from a counseling program or clinical/counseling psychology program is a distinction without a difference and does not best serve Virginia. Please reinstitute the prior regulatory interpretation of the regulations and allow graduates from accredited Master's programs in clinical/counseling Psychology in Virginia to become credentialed as an LPC.

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As an individual who has been seriously impacted in my career decisions due to the Board's recent policy changes, I agree with Dr. Chase's statements.  It appears to me that my application for supervision was declined due to the fact that my program name did not include counseling in the title.  It does not seem to matter that I took most of my classes with students who were in the counseling program.  It seems to me that unless I retake what is fundamentally THE SAME degree under a different name I will always be marginalized by an inability to receive licensure in my choosen career path.  Language is a very poor tool to communicate how this has affected me on different levels in my life.  Needless to say, strongly enough to impell me to break  traditional professional mores regarding expression of feelings.  I think I speak for many others who are remaining silent due to that reserve, fear for their license eligible positions, or to the lack of information about this comment box on the web.  Please reconsider the recent changes that have been made.

Thank you,

Alyson Woleslagle

I am a graduate of Radford University's Clinical Psychology M.S. Program.  I have never applied for supervision for LPC in Virginia, but know many people who have.  Currently, I work for a public mental health agency, and have been employed full-time by this agency for approaching five years.  However, perhaps due to my inability to become licensed, I often feel as if my presence and abilities are constantly in question.  Also, I have been clearly reminded that I am expendable.  There is an enormous lack of available resources, including counselors, for the population that I serve and burnout is rampant.  These problems won't be fixed just by allowing clinical students to become license- eligible, but if they are competent, they can help.  If someone has already experienced immense personal hardship while attempting to acquire a LPC (such as the expense of a second master's program, having to relocate to another state to become licensed, repeated rejections from the board for what feel like arbitrary reasons) will they even want to continue in this field? Or even worse, will they stay in the field with a jaded perspective on human nature, causing potential harm to their clients and even harder work for those that follow in their path?  

As others have said, there are many others who would speak here, but I suspect they are not, out of fear of the consequences, exhaustion, or not knowing this forum exists.   I've tried to incorporate the thoughts of those I have spoken to who are experiencing hardship because of these decisions.  Thank you for reading and considering my viewpoint.