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]
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12/3/13  6:48 pm
Commenter: Katharine Loner Mailleue

I strongly support this petition!
 

Lots of the posts keep saying that the issue has nothing to do with being a CACREP versus non CACREP accredited program. I know that is probably somewhat true, but the actual regulations do specify that the academic course of study in CACREP accredited programs is automatically considered to satisfy the Degree Program Requirements whereas other programs that are not CACREP accredited have to prove they satisfy it. And if CACREP approval has nothing to do with it, then why is it that psychologists who teach in a counseling program in a psychology department such as JMU can be considered identifiable counselor training faculty but psychologists at other programs cannot not. Assuming that the board has criteria for determining identifiable counselor training faculty that they apply in an unbiased way across  all programs, they need to articulate them. Otherwise, it appears that the decisions the board is making are either random or based on some unspecified agenda designed to systematically exclude graduates from a couple of programs. 

The board needs to come up with really clear statements that protect both the board as well as the people who want to get licensed. It seems as if the rules are a bit of a moving target. If the board can’t replace the vague terms with clear definitions that are specific and apply to all programs equally, then I think the board really needs to ask itself if it is indeed making arbitrary and unfair decisions.

However, when they come up with the regulations, they will have to follow them. It’s not ok to intentionally keep the language so vague in order to allow them to make arbitrary decisions. For example, what does it really mean to reject someone because there is not an identifiable counselor training faculty? How do they define this term? Do the faculty have to have doctoral degrees? Do the faculty have to have graduated from a Counseling Program in a Department of Education? Can the faculty have graduated from a Counseling Program in a Department of Psychology? Do the faculty have to have their LPC? Do the faculty have to be a member of a certain professional organization? etc.  I can’t help but wonder if the board is fully aware that there may be inconsistencies in the criteria they use for different schools and that is why they have not articulated their criteria in an objective way. I would certainly hope not and assume that the board would want to do all they could to avoid giving that impression.

So let’s say that the board says “all full-time core faculty must hold a doctoral degree, have graduated from a counseling program in a department of education and have the LPC”. (Granted, some faculty may have been grandfathered in and thus not held to the same standard). Then, any student who graduates from a program that meets that criterion should not be denied on the basis of their program not having an “identifiable counselor training faculty”.   The board needs to be transparent and honest in how they make their decisions. It is then up to the program to start hiring faculty who meet those criteria, to modify their curriculum to meet the regulations, or to explicitly inform students that their program does not meet the Educational Requirements for the LPC in Virginia.

When I entered RU in 2008, I assumed I would be license eligible because students had never been turned down on the basis of anything related to the program in the past. However, when I was one year into my two year program, three students got turned down (in 2009). So suddenly everyone who came in my year had to try to figure out what we wanted to do if we would not be license-eligible in Virginia.

Like the graduates of my clinical psychology program, I have a servant's heart.  It has always been my goal to use my career to help others in need. It is shameful that so many talented, intelligent, willing individuals have been denied the LPC in Virginia. Not only does it prevent these individuals from obtaining a license, but it denies the mental health community the services of these highly competent individuals. Our only goal as graduates of clinical psychology is to improve the lives of those in our communites battling mental health disorders.

Finally, since we first learned that three people got turned down in 2009 because of their program, rather than anything about their personal credentials, it seems that no one has been willing to apply for licensure or try to challenge the board because they were just one person. Some moved out of state, some got different jobs, some (like myself) went on for further graduate degrees etc. But, now Dr. Chase’s official petition has made the problems a matter of public record that the board can no longer ignore. Currently, people are being denied the opportunity to apply for licensure based on criteria that the board will not articulate. However, it seems to me that much of the controversy is the board’s fault because, as Dr.  Chase said, they are using vague terminology. Why doesn’t the board just make a decision, clarify the terminology so that there is no confusion, and end the debate, and let people move on with their lives?

CommentID: 29458