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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9/18/19  1:26 pm
Commenter: Augusto C. Garcia Vizcarrondo, University of Baltimore

I Strongly Oppose
 

Although licensure portability laws are a step in the right direction in improving the behavioral health care of our clients, I strongly oppose the stipulations outlined in this particular proposal. It is evident that this proposal seeks to limit the ability of behavioral health care professionals graduating from non-CACREP programs to provide counseling to clients across state lines and favors CACREP endorsed programs. There is no evidence to indicate that graduates from CACREP accredited programs provide better care that those who are not, and the fact that most programs in the US are not CACREP accredited, severely limits our client’s options for care. Even more concerning is the fact that we are also limiting the care provided to our service members returning from overseas. Virginia is one of the top five states with the highest concentration of veterans as well as Active Duty service members, being home to several military installations such as FT Eustis and FT Lee. When considering future proposals for licensure portability, we must ensure that we are always placing the needs of our clients first.

CommentID: 76255