I am writing my strong support of this petition to revise the Degree Program Requirements listed in section 18VAC115-20-49 of the Virginia Regulations Governing the Practice of Professional Counseling. As many others have noted in their comments, the shift in preventing those with a strong educational background, training, and experience from being approved for supervision or allowing them to take the licensing exam, I believe has harmed and will continue to harm the profession of the LPC. This relatively recent change in interpretation of these requirements prevents many people, including myself, from seeking out and being granted not only licensure, but the career and service opportunities that enrich the profession. I have gone so far as to seek out career opportunities out-of-state due to these unnecessary barriers. While I have been approved for supervision in this state, I remain apprehensive about how my status will progress as I hear more and more stories of those who have progressed sometimes very far into the licensing process only to be denied taking the exam simply over what my colleagues in this forum have accurately described as "guild-protection". Seeking out licensure is not a decision one takes lightly, especially once one has reviewed the application and other requirements set forth prior to taking the exam. Therefore it would only seem logical to think that once an individual has examined the many steps they must take, they commit their time and talents fully aware of the demands it requires both professionally and personally. Simply put, it is not a decision taken lightly. So one would logically conclude that those willing to invest in the process are seeking the LPC with honesty, integrity, and hoping to build and then demonstrate their competency. It adds insult to injury to think that after such an expensive process, both in time and money, one would be denied the opportunity to demonstrate their competency via the exam.

As the statute is presently written, it seems to allow for those from non-CACREP programs to be evaluated on their own educational and training merits and be allowed to take the licensing exam which exists as the final and objective measure of competency to practice as an LPC. As mental health care is increasingly prevalent on the forefront of what now constitutes modern-day comprehensive medical care, I would think it would be in Virginia's best interest to investigate how they can best expand their base of skilled, competent, and ethical counselors, rather than reduce it. As someone who presently works in the mental health profession with daily contact with consumers of mental health services, I see first-hand the impact that the lack of skilled professionals is having on those in dire need of support and assistance. One only needs to read the news on any given day to see how mental health care is lacking. Agencies state-wide are having such a difficult time filling positions and keeping competent people once hired as soon as new hires become aware of a) how career advancement requires an LPC and b) the current restrictive interpretation of the above statute which ultimately prevents LPC and subsequent career advancement. The most concerning factor to me and to my peers, however, is the negative impact on those who need us the most- our fellow Virginia citizens and consumers of services. 

Thank you for your consideration.

C. Stafford