As a counselor in Virginia with a strong interest in promoting the profession, I strongly urge the Board of Counseling to adopt the petition to require that all individuals applying for an initial license to practice counseling in Virginia graduate from a CACREP-accredited program.  The adoption of this rule serves the profession and the citizens of the commonwealth in several ways.  First, it will enhance the employment prospects of graduates of counseling programs in Virginia by ensuring that they meet training requirements recently adopted by the federal government for counselors who wish to work with military veterans.  Failure to require graduation from a CACREP-accredited program does a disservice to students who enter a counseling program without being fully informed of the need for accreditation in order to work with military populations.  Second, it will increase the availability of mental health professionals to serve active-duty and veteran members of the military living in the commonwealth by bringing the training standards in line with federal standards, making graduates of counseling programs in Virginia automatically eligible to work with veterans by virtue of the training they receive in institutions within the commonwealth.  Third, adopting the CACREP rule allows the Board to follow recommendations for training established by the Association of Counselor Educators and Supervisors, a division of the American Counseling Association.  Fourth, as the counseling profession moves towards enhanced licensure portability and uniform training standards, adopting the CACREP rule will position Virginia well to meet the emerging standards that are under development for portability.

I would not support this petition if it did not also contain a solid grandfathering clause that will allow students and programs ample time to prepare for the transition.  It does.  It also ensures that counselors who are currently licensed or in residency who have not graduated from a CACREP-accredited program will NOT be disenfranchised by the adoption of this rule.  They will continue to be recognized as licensed professional counselors and their practice will not be affected by this rule.  These are important considerations which the petitioner appears to have considered and addressed.

In short, I fully support the adoption of this rule and I encourage the Board of Counseling to approve it.

I am writing to support the proposal to the Board to allow, with grandfathering, CACREP accreditation as a prerequisite for working with Tricare, VA, and other defense contractors. Licensing agencies have already indicated that they value CACREP education by allowing the internship hours to count toward licensure, this is the next step toward recognizing the value that the preparation requirements and experiences provide solid training for the LPC.

The changes described in this petition will increase quality and consistency in Counselor Education Programs.  The generous grandfathering timeline will allow students, recent graduates, and programs ample time to make informed decisions about how to proceed.  Thank you all for your work on this important matter.

I fully support this petition as a significant and appropriate means of solidifying the training standards and professional identity of LPC's in the Commonwealth of Virginia.  

The CACREP accredidation programs certainly seems like a good program currently, but the proposal here isn't to require Virginia Schools to be accredited, it is to require new people seeking licensure to have graduated from an accredited program. 

I am always wary, as the State should also be, of offloading the State's responsibilities to others, and of creating monopolies.  This proposal effectively does both, and should only be adopted if the quality of newly licensed individuals is lacking and there is no other reasonable way to improve it.

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

Greetings,

I wish to add my voice of support for legislation requiring require graduation from a clinically-focused counselor preparation program.However, I am concerned that including into the law an implicit endorsement of a private, professional organizatio or accrediting body may cause issues needing to be dealt with in the future. witht he possibility of another accrediting body emerging or the dissolution of CACREP being a distant but real possibility or moreover, the possibility of the standards of CACREP departing from professional best paractices or the values of the commonwealth of Virginia, using such language may cause the need for future legislation inorder to address such issues.

Although, I support the standard of CACREP and feel that they create an appropriate framework whereon to build a Counseling program, I would like to see legislation which is sustainable and reflects the goals and future of the profession. Further more, I would endorse legislation which requires a minimum of 60 semester credits (90 quarter hour credits) of curricular experiences and a practicum of at least 100 hours and an intership of at least 600 hours.  Allow a grandfathering of programs that meet current requirements for seven years from the effective date of the regulations.

Michael A. Williams, Sr, PhD

I opppose the proposed CACREP only standard as it penalizes future applicants who do not go to a CACREP school.  The Commonwealth is inadequately funding the Board and the result is a lack of staff able to review the current applicants.  Allowing an outside, private credentialing organization to do the work of the Commonwealth is a slippery slope which will allow all curriculum to be written and administered to a different standard than what is appropriate for the citizens of Virginia.

It will also hinder students of programs who do not wish to pay CACREP for their credentialing.  Having attended a non-CACREP school, my courses matched up directly with the CACREP standards but if this change goes forward, I would not have had the ability to be licensed and practice in Virignia.

In summary, I am against an outside organization imposing their rules upon the Commonwealth's duty to license and credential their mental health practioners.

I am writing to voice my support of this proposal since it will ensure the consistent quality of our counseling training programs.  Furthermore, I believe this proposal ultimately speaks to our issues with professional identity. We, as counselors, need to have a more consistent presentation to our mental health consumers as well as third-party payees and legislators.  If we, as counselors, are better able to make a consistent statement about who we are, how we are trained, and how we practice, then we will be better able to ask for the professional recognition and compensation that we need and deserve.

I agree with the need for our profession to come together more clearly and consistently around a professional identity - anchored in accreditation and portability of licensure. I've worked in two other states with an LPC and have experienced the disparity in the way counselors are viewed in comparison to other mental health helping professionals. Clarity, consistency, and anchoring standards are central to our profession growing and employment opportunities expanding. And the grandfathering clause is critical for justice and fairness.

I strongly support this petition for the following reasons:

1. Inclusion of CACREP accreditation as a requirement for the licensure education standards will promote professional identity for counselors.  The counseling profession has evolved to the point where further advancement of the profession requires that we be able to differentiate ourselves from other mental health professions.  The only way to effectively achieve this differentiation is to limit licensure to graduates of programs who have met rigorous standards for not only quality, but for promoting a strong professional identity.  Only CACREP accreditation can guarantee that programs have met such standards.
2. Protection of the public.  In order to make informed choices, citizens of the Commonwealth need to be able to clearly identify which mental health professionals are truly counselors.  The previous licensure of graduates from psychology programs only served to confuse the public and blur the differences between mental health professionals.  Again, the only way to completely ensure that only trained counselors are licensed as professional counselors is to require that they come from accredited programs.
3. Portability.  The counseling profession has for decades attempted to improve licensure portability for counselors.  Unfortunately, fifty-one different standards and fifty-one separate legislative bodies have made this effort almost impossible.  As with other mental health professions, it appears that the only realistic path to licensure portability is to support training standards established by a national accrediting body.  CACREP now accredits 52.4% of the institutions offering counselor education programs and 63.4% of the specific counselor education programs and the number of institutions applying for CACREP accreditation is increasing rapidly.  With almost two-thirds of counseling programs being CACREP accredited, CACREP has clearly become the recognized accrediting body for counselor education and should be recognized by the licensure boards as such.
4. CACREP’s history promoting the counseling profession.  CACREP was established in 1981 and was supported by the same pioneering counselor educators who were responsible for creating Virginia’s counselor licensure in 1976.  CACREP is a non-profit organization whose Board of Directors is composed of practicing counselors and counselor educators with limited terms.  Current and former board members are recognized leaders in our profession.   CACREP, along with NBCC and ACA has consistently and effectively advocated for our profession and have helped provide opportunities for counselors that would have been difficult to imagine twenty years ago.
5. Advancement of the profession.  The recognition of licensed counselors by Tricare has created a controversy in the profession over Tricare’s requirement for graduation from a CACREP program.  It is important to note that if CACREP did not have the credibility to be endorsed by the Institute of Medicine, there would be no counselors eligible endorsement by Tricare.  Despite the controversy, the Tricare endorsement is an example how CACREP’s credibility has benefitted our profession.  If CACREP standards are accepted for licensure education standards, the benefits of being a licensed counselor will continue to increase.

6.       Sufficient grandfathering period.  The proposed seven-year grandfathering period is sufficient for all              currently unlicensed counselors from non-CACREP programs to obtain licensure and for unaccredited programs to easily attain accredited status before the requirement for graduation from a CACREP accredited program takes effect.