The current proposal offers a pathway to licensure that recognizes the value of professional experience in the development of skill and expertise among mental health professionals.  This is a laudable effort, however the huge discrepancy in years of experience required, depending  on the accreditation of one's graduate program, is highly problematic.  For this reason, the proposal should not advance.

License portability is a concern of every practicing professional in our highly mobile society.  Barriers for those attached to the military deserve particular attention.  Most professional mental health counselors in the U.S. were not trained in CACREP-accredited programs.  Thus, most professionals in the country would face a huge roadblock in obtaining a license to practice in Virginia under this proposal.  If a candidates is short on any of the state's requirements (such as fewer than 600 hours in supervised internship, a relatively recent development in the field), and the master's program was not CACREP-accredited, the candidate would have to show 10 years of post-license experience, as opposed to 3 years for an otherwise identically-prepared graduate of a CACREP-accredited degree program.

Given that there is no credible evidence that CACREP training leads to greater competence or faster accumulation of skills in post-license years, the requirement s contained in this proposal are  not justifiable.

Other program accreditation exists (see mpcacaccreditation.org) to support excellence in training for master's-level mental health professionals.  Marginalizing graduates of programs with this accreditation, or the vast majority of licensed professionals trained before program accreditation became common, lacks empirical justification, undercuts the mobility of duly licensed professionals and does not serve a public with huge and diverse mental health needs.  I urge the rejection of this proposal in its current form.