Having adequate licensed staff is critically important to competent service delivery in the behavioral health arena.  We are fortunate to have an  excellent graduate program in Clinical and Counseling Psychology at Radford University. This program produces highly qualified professionals, who are often interested in remaining in the area. Southwest Virginia is in need of qualified professionals. We have several graduates of this program on staff, licensed previously, who provide quality services. However given the recent interpretations of the licensing Board, many new graduates are no longer staying in Virginia, but taking their training and expertise and moving out of state, where they are able to be licensed.  This is a genuine loss to the citizens of the Commonwealth. Please consider amending the regulations to more broadly allow licensing for non-CACREP graduate programs.

The Virginia Association of Community Services Boards (VACSB) strongly supports the Chase petition to require that the Board of Counseling amends its definitions and requirements to accept Master's Degree graduates of non-CACREP couseling-psychology programs.  There exists a severe need for licensed behavioral health professionals in Virginia and the need is exacerbated when the Board of Counseling limits qualified candidates who have completed legitimate programs of Virginia's colleges and universities.

I support the Chase petition to require that the Board of Counseling amends its definitions and requirements to accept Master's Degree graduates of non-CACREP couseling-psychology programs.  I am the Director of a mental health agency and we have experienced a severe shortage of licensed behavioral health professionals to fill vacancies.  The Board of Counseling should allow qualified candidates who have completed legitimate programs of Virginia's colleges and universities to become licensed.

over this text and enter your comments here. You are limited to approximately 3000 words.

One of the most valuable human resources in our field is licensed professional counselors. They are in high demand, and the availability of them is extremely  limited.  I support this petition as the Senior Director of Adult and Family services at Horizon Behavioral Health and as a  licensed professional counselor in three states, including Virginia.  The licensing process requires intensive hours of  clinical supervision, hands on experience, as well as testing, all of which compliment the Masters level formal education whether CACREP or not. 

In the Human resources field the most valuable resources our field has is a Licensed Professional Counselor.  Given they are in high demand and very hard to hire I support this petition as the Program Director of Outpatient Services at Horizon Behavioral Health and as a Licensed Processional Counselor in the state of Virginia.  The process of getting licensed is intensive and requires extensive clinical supervision hours, experiences in the field, sitting for the licensure exam, and this all compliments the Masters program of some ones choose regardless of the programs CACREP status. 

To Whom IT May Concern:

   I request respectfully that you ammend the definitions and requirements to accept Master's Degree graduates of non-CACREP counseling programs.

I have worked in the human services field for 24 years and during that time I have met a lot of therapist - some who are worth there salt and some who are not. I did not stop to ask them what school they went to or what degree they had or whether the program they graduated from was accredited or not. 

Why? Because I based their competency on them as an indivdual. I knew that they had spent many years studying for their degree, had tons of clinical supervision and lots of on the job experience and passed their licensure exams; but I also knew by their dedication and their connection with those whom they counseled whether they were good counselors or not. Some of those counselors were not from CACREP programs and others were.  

It is obvious to me that the programs who are non-CACREP accredited still have and maintain high standards and they are producing qualified counselors; therefore those who pass their exams and all other requirements should be allowed to the same rights and privileges being granted to counselors from CACREP accredited programs.

Submitted respectfully,

Edward Hix 

To Whom It May Concern,

I am asking that the Board of Counseling change the definitions in Section 10 and requirements in Section 49 of the regulations governing the practice of Professional Counseling to accept Master's Degree graduates of a non-CACREP clinical-counseling psychology program.

I have had the privilege of working with individuals seeking their licensure but have been stalled due to "wording" in Sections 10 and 49.  It is a shame that "wording" can risk competent individual in obtaining licensure.  These individuals are dedicated future licensed therapists.  I have seen them in action and you could not ask for more compassion and dedication. I have seen these individual continue training and education to ensure they are knowledgeable of new/developing therapeutic practices.  I have witnessed this dedication change the lives of youth experiencing trouble times and allowing them the opportunity to experience positive life direction. 

I am asking that the Board of Counseling look at the "program" of educational institutions rather than "words".  Please don't let non-CACREP programs that are producing exceptional individuals who are seeking their counseling licensure fail in reaching their goal because of "wording".  I've always felt that actions speak louder than words.  Please look at educational institutions and individual's accomplishments over "words".   

Thank you for your time in reading my concerns.

Cordially,

Joan Hammond

With recent developments in our nation showing the need for mental health counseling, I support the Chase petiition to require the Board of Counseling amend it requirements to accept Master's Degree graduates of non CACREP counseling psychology programs. I do hope The Board of Counseling will allow qualified candidates who have completed legitimate programs of Virginia colleges and unversitites to become licensed.

An private citizen as well as an employee in the Behavioral Healthcare field, I wholeheartedly support amending the Board of Counseling definitions and requirements to allow Master's Degree graduates of non-CACREP counseling-psychology programs.   There is a severe shortage and an incredible need for licensed behavioral health staff throughout Virginia.  Consideration of this amendment is very timely and would effectively address this shortage by allowing more qualified staff to become licensed. 

Fairfax Falls Church CSB Administration and Service System supports the petition because the current regulations impede capacity expansion of LMHP's in the state.  Our professional staff have noted no demonstratable benefit with the current regulation requiring CACREP schools and the NBCC does not require CACREP schools either, but waives some of the the post-master's experience and supervision if a CACREP school is used.

George Braunstein

I am in support of the Chase petition that is asking for definitions in Section 10 and requirements in Section 49 of the Regulations governing the practice of Professional Counseling be changed to accept Master’s Degree graduates of a non-CACREP clinical-counseling psychology program.

I am in support of the Chase petition that is asking for definitions in Section 10 and requirements in Section 49 of the Regulations governing the practice of Professional Counseling be changed to accept Master’s Degree graduates of a non-CACREP clinical-counseling psychology program

As someone who has been in the field for over 20 years and having earned a Master's Degree pre-CACREP -- I am very much in support of the Chase petition  asking for definitions in Section 10 and requirements in Section 49 of the Regulations governing the practice of Professional Counseling be changed to accept Master’s Degree graduates of a non-CACREP clinical-counseling psychology program

I am in support of the Chase petition that is asking for definitions in Section 10 and requirements in Section 49 of the Regulations governing the practice of Professional Counseling be changed to accept Master’s Degree graduates of a non-CACREP clinical-counseling psychology program

I am in support of the Chase petition that is asking for definitions in Section 10 and requirements in Section 49 of the Regulations governing the practice of Professional Counseling be changed to accept Master’s Degree graduates of a non-CACREP clinical-counseling psychology program

I am in huge favor of supporting the change. I believe that those who participate in a program that is not Acrep certified but follows the guidelines that they have for the progam be granted the same license.

I support the Chase petition which asks that the Board of Counseling amend its definitions and requirements so that   Master's Degree graduates of non-CACREP couseling-psychology programs have the potential to become licensed .  I am a retired psychology professor from Radford University, and have seen a consistent and chronic shortage of  qualified counselors and other behavioral health practitioners in the state, particularly in the more rural regions of Virginia.  I believe that the Board of Counseling needs to accept qualified candidates who have completed legitimate or accredited graduate programs in counseling,  counseling psychology or other program where the main focus is on counseling practice to improve psychological and behavioral health of the individual and his or her family, whether or not the program is CACREP accredited. I can specifically attest to the high quality of the training that graduate students receive at Radford University, and hope that these potential counselors can become licensed so that they can provide much needed services to the people of Virginia.

In support of the petition

I support this change being proposed as it would allow rural CSBs to have more options to retain well qualified licensed staff in our areas.

I am an LPC in the state of Virginia and am a supervisor for Mt. Roger's Community Services Board. I graduated in 2007 with my Master's of Science from the Counseling Psychology program at Radford University. I have heard from former classmates about their difficulty with licensing due to the title of their program. I found this odd as I was licensed and we shared most of the same classes, same professors, and had the same syllabi. The licensure application outlines specifically the classes that are expected to be completed. I believe that if the coursework meets these requirements then it should be accepted, whether it is from Clinical Psychology, Counseling Psychology, Counseling Education, etc. In Southwest Virginia we have a shortage of Licensed Counselors. Medicaid and licensure requirements are placing more licensed staff in supervisor roles and has limited the number of direct care licensed clincians in our area. Any legislation that could limit competent, qualified counselors from practicing in our state is a detriment to the individuals we serve. I also believe this legislation limiting clinical programs from being accepted into licensure was made after many applicants had finished their degrees. There was no variance offered for persons who had already completed their degrees with the expectations of being licensed in Virginia. I cannot imagine how frustrating it would be to graduate with your Master's degree only to find out a year later that a policy had been put in place to limit your application to practice as an LPC. I believe that any time a new policy is put in place in this regard that it should not take effect until that date to allow people who were already in a college program or had already graduated to become licensed. In conclusion, I am in support of including any program whose coursework meets the guidelines set forth in the application. 

I support this petition. As long as a person meets the course requirements for the LPC, it shouldn't matter what program they are in. It's just a name. What should count is the substance of the program. 

I support the Chase Petition

I strongly support Dr. Chase’s petition to revise the Degree Program Requirements listed in section 18VAC115-20-49 of the Virginia Regulations Governing the Practice of Professional Counseling. For over 30 years, the Virginia licensing board evaluated candidates on the basis of their coursework, training, and ability to demonstrate their knowledge and competence on the objective licensing exam, rather than on a subjective philosophical distinction between “counselors” and “psychologists”. At the completion of all required coursework and other requirements, every individual was required to take the licensing exam. An individual who passed became licensed as an LPC. Those who did not pass, did not. Thus, evaluation of who would be licensed as an LPC in Virginia and who would not was made based on an individual’s competence, as evidenced by the objective licensing exam.

I am not sure of the exact timeline, but somewhere around 2009, that standard for evaluation changed. The licensing board made a dramatic shift in the interpretation of the regulations such that individuals who had been trained in a non-CACREP accredited program in clinical psychology were now turned down when they applied for approval for registration of supervision. Because these individuals were not allowed to complete this step, they subsequently were prohibited from the opportunity to take the licensing exam. In other words, the licensing board put up a barrier for these individuals which prohibited them from the opportunity to demonstrate their competence through passing the licensing exam. It is a travesty that some of these qualified individuals who were trained in Virginia ultimately had to move to another state in order to become licensed professional counselors.

As best I understand it, this appears to be an issue of guild-protection, rather than competence-protection, or protection of the public. I firmly believe that the citizens of Virginia deserve the best mental health services that the Commonwealth has to offer and thus I am fully supportive of a licensing board that regulates mental health services. However, I am greatly concerned that the licensing board is now blocking highly trained and competent mental health professionals from obtaining that license due to a subjectively determined philosophical distinction between “counselors” and “clinical psychologists”, rather than on relevant coursework, completion of all other requirements, and performance on the objective licensing exam.

For the purpose of clarity, at the bottom of my comments I have included the exact wording pasted from the Regulations Governing the Practice of Professional Counseling (18VAC115-20-49) and also from section § 54.1-3500 from the Code of Virginia. Letter A of the regulations does not state that an applicant  must have graduated from a CACREP accredited program. Rather, it states that, by definition, such a program is automatically recognized “as meeting the definition of graduate degree programs that prepare individuals to practice counseling and counseling treatment intervention as defined in §54.1-3500 of the Code of Virginia”. However, letter B states “The applicant shall have completed a graduate degree from a program that prepares individuals to practice counseling and counseling treatment intervention, as defined in §54.1-3500 of the Code of Virginia, which is offered by a college or university accredited by a regional accrediting agency and which meets the following criteria: 1)  There must be a sequence of academic study with the expressed intent to prepare counselors as documented by the institution; 2) There must be an identifiable counselor training faculty and an identifiable body of students who complete that sequence of academic study; and 3) The academic unit must have clear authority and primary responsibility for the core and specialty areas”.

Definitions provided for “counseling”, “practice of counseling,” and “professional counselor” in §54.1-3500 of the Code of Virginia are provided below. Specifically, "professional counselor" is defined as “a person trained in the application of principles, standards, and methods of the counseling profession, including counseling interventions designed to facilitate an individual's achievement of human development goals and remediating mental, emotional, or behavioral disorders and associated distresses that interfere with mental health and development”. One would be hard-pressed to argue that psychologists do not meet this definition, or that psychology program cannot a) adequately provide a sequence of academic study with the expressed intent to prepare counselors, b) be considered an identifiable counselor training faculty, and c) have clear authority and primary responsibility for the core and specialty areas. Thus, graduates from

Master’s level Clinical or Clinical-Counseling Psychology programs that are not CACREP accredited should not be denied the opportunity to apply for licensure and take the licensure exam on any of these grounds.

However, I am aware of highly trained and competent individuals who graduated from a master’s degree program in Clinical Psychology from an accredited university in Virginia, whose applications to proceed with licensure as a Licensed Professional Counselor were denied because the Credentials Committee determined that their course of study did not meet the requirements set forth in regulation 18VAC115-20-49. Three specific reasons have been cited: “there was insufficient emphasis on counselor preparation in the academic curriculum and program description, there was a clear intent to prepare students to become clinical psychologists rather than counselors, or the faculty roster does not have an identifiable counselor training faculty”. While I understand that the licensing board evaluates the credentials of individual applicants rather than university programs per se, the stated reasons that these individuals were denied suggest that the board takes issue with the discipline of clinical psychology itself, rather than with the actual training or coursework provided by the program or the competence of the individual applicants. The stated reasons for denial seem to imply that the training provided by doctoral level psychologists in a master’s level clinical psychology program is so different than that provided by doctoral level “counselors” that, by definition, such graduates are not even eligible to apply for licensure as an LPC in Virginia. Clearly, psychologists have a long history in training competent mental health professionals at both the masters and doctoral level in the Commonwealth. It would be ludicrous to argue that clinical psychologists are not trained in “counseling” as defined in § 54.1-3500 and listed below. It would also be ludicrous to argue that clinical psychologists have no role in training master’s level mental health professionals, or that the students they train are not competent to become master’s-level licensed mental health professionals and earn the LPC in Virginia.

Therefore, I urge the board to return to the position it held for over 30 years, whereby individuals applying for licensure would be judged on the basis of their coursework and competence, not on the philosophical orientation of the program from which they graduated. I believe the current distinction between master’s level “counselors” and “clinical psychologists” would be analogous to the Board of Medicine deciding that it would no longer license individuals from a Virginia medical school who graduated with a D.O. rather than an M.D., which is something that the medical board does not do.

However, if the licensing board is going to deny the applications of all students who graduate from non-CACREP accredited Clinical Psychology or Clinical-Counseling Psychology programs, regardless of the coursework or competence of the graduates, then the licensing board should change the wording of the regulations and make that explicit. If a non-CACREP accredited program in Clinical-Counseling Psychology that has a sequence of academic study with the expressed intent to prepare counselors as documented by the institution does not meet the standards intended by the regulations, then the regulations should explicitly state that. Likewise, if clinical psychologists do not meet the qualifications to be considered “identifiable counselor training faculty”, then the regulations should explicitly state that. The lack of clarity as to whether graduates from a non-CACREP accredited program in Clinical-Counseling Psychology will be license eligible upon completion of their degree has been a problem for over 5 years. It is only fair to the Psychology Programs that provide such training and to the students who enroll, or choose not to enroll, in those programs, based on a clear understanding of whether they will be license-eligible or not.

In summary, the Commonwealth of Virginia does not have room for guild issues regarding who can become an LPC and who cannot. This is evident by the numerous comments already posted in support of Dr. Chase’s petition. Such restrictions are unneeded and do not enhance the protection of the public, which is ultimately what the Board of Counseling is designed to do. The comments clearly suggest that many mental health professionals and agencies support this petition and that the interpretation of the current regulations hinder their ability to hire qualified mental health professionals and to fill vacancies in their region. Given that there is a serious shortage of mental health professionals in the Commonwealth and many regions are severely underserved, I strongly advocate that competent graduates from non-CACREP  accredited programs in Clinical or Clinical-Counseling Psychology who have met all other requirements be deemed eligible to sit for the licensing exam in Virginia.

Let the coursework and licensing exam be the determinant of who is a competent mental health professional and who is not.

Respectfully,

Ann Elliott

Regulations Governing the Practice of Professional Counseling (18VAC115-20-49)  

http://www.dhp.virginia.gov/counseling/counseling_laws_regs.htm

18VAC115-20-49. Degree program requirements.

A. Programs that are approved by CACREP or CORE are recognized as meeting the definition of graduate degree programs that prepare individuals to practice counseling and counseling treatment intervention as defined in §54.1-3500 of the Code of Virginia.

B. The applicant shall have completed a graduate degree from a program that prepares individuals to practice counseling and counseling treatment intervention, as defined in §54.1-3500 of the Code of Virginia, which is offered by a college or university accredited by a regional accrediting agency and which meets the following criteria:

1. There must be a sequence of academic study with the expressed intent to prepare counselors as documented by the institution;

2. There must be an identifiable counselor training faculty and an identifiable body of students who complete that sequence of academic study; and

3. The academic unit must have clear authority and primary responsibility for the core and specialty areas.

According to Section 18VAC115-20-10, the terms “Counseling” Counseling treatment intervention” and “Professional Counselor” shall have the meaning ascribed to them in 54.1-3500 of the Code of Virginia.

§ 54.1-3500. Definitions in the Code of Virginia

http://lis.virginia.gov/cgi-bin/legp604.exe?000+cod+54.1-3500

"Counseling" means the application of principles, standards, and methods of the counseling profession in (i) conducting assessments and diagnoses for the purpose of establishing treatment goals and objectives and (ii) planning, implementing, and evaluating treatment plans using treatment interventions to facilitate human development and to identify and remediate mental, emotional, or behavioral disorders and associated distresses that interfere with mental health.

"Practice of counseling" means rendering or offering to render to individuals, groups, organizations, or the general public any service involving the application of principles, standards, and methods of the counseling profession, which shall include appraisal, counseling, and referral activities.

"Professional counselor" means a person trained in the application of principles, standards, and methods of the counseling profession, including counseling interventions designed to facilitate an individual's achievement of human development goals and remediating mental, emotional, or behavioral disorders and associated distresses that interfere with mental health and development.

18VAC115-20-49. Degree program requirements.

A. Programs that are approved by CACREP or CORE are recognized as meeting the definition of graduate degree programs that prepare individuals to practice counseling and counseling treatment intervention as defined in §54.1-3500 of the Code of Virginia.

B. The applicant shall have completed a graduate degree from a program that prepares individuals to practice counseling and counseling treatment intervention, as defined in §54.1-3500 of the Code of Virginia, which is offered by a college or university accredited by a regional accrediting agency and which meets the following criteria:

1. There must be a sequence of academic study with the expressed intent to prepare counselors as documented by the institution;

2. There must be an identifiable counselor training faculty and an identifiable body of students who complete that sequence of academic study; and

3. The academic unit must have clear authority and primary responsibility for the core and specialty areas.

I support this petition 100%.  I am not currently in the mental health field however I graduated from the master's of psychology program at Radford University with a concentration in clinical psychology.  It consisted of many hours of counselor training and culminated in an internship which placed me in the field as a mental health counselor.  From my experience I was as prepared as other mental health counselors who had a different degree.  Please consider this program and others like it for licensure.  The program at RU has produced many fine graduates who are well trained to be counselors and clinicians.

I support this petition 100%. I chose to complete the Radford University Clinical Psychology Masters Program (alum 2013) because it looked to be a comprehensive well-rounded program. I can honestly say that I learned an incredible amount during my time in the program and I was shocked to discover that I was unable to sit for the licensure exam due to the fact that it was a "Clinical" program. I desperately wanted to work in the field of Psychology and was unsure of what to do as I knew getting a job with a masters and no licensure was not the best option. I ended up pursuing the PsyD in Counseling Psychology at Radford and getting in was in part due to the quality education I received in the Masters and my ability to demonstrate a wide range of knowlege in the counseling field.  Had I been unable to get into this program I fear that I would have been unable to obtain a job, in the field, that allowed me to achieve my highest potential and do the work that I have always wanted to do (be a counselor or therapist). If my education prepared me to be a PsyD student (and have a praciticum in my first semester doing traditional therapy with actual clients) I do not see how it would not prepare someone for licensure. I remember the worries about where I would go next, how I would obtain a job, and what choices I had in pursuing my dream career, and any step we can take to eliminate those feelings for the next student I support fully. 

It is a shame the board has gotten to the point it leaves no option for those that have worked hard to accomplish there degree and then be told that it is no longer accepted when it has produced other's in prevoius years that were recognized and they were able to obtain there LPC.  And they are excellent clinicians today.  I ask that the board work with those applicants to resolve this issue.

I graduated from Radford University Clinical Psychology program with an MS in 2008. I immediately went to work at the local Community Services Board (NRVCS) where I excelled. I became invested in the community and planned to stay in Virginia working in community mental health, specifically in doing crisis counseling. To do this I knew I needed to get licensed. Unfortunately, as I watched my peers get rejected by the board, it became clear to me that this would not be an option in Virginia without getting a second graduate degree in counseling. This seems ridiculous ot me and a waste of time and resources. I am already trained as a counselor and I have great professional experience. I don't want to repeat the points that have already been made about the qualities of my graduate program. I thought it would be more helpful to give a picture of the consequences of not allowing me to pursue an LPC with my graduate degree. Instead of staying in Virginia and working in the community, I left the state and I am now doing research in psychology, preparing to start a doctorate degree. Had my degree been license eligible in Virginia I likely would have stayed and continued to work in emergency services which is a field that is sorely needed but people often don't stay very long. I wasn't able to move up in my agency so to advance my career I had to leave the field.

The current interpretation of the LPC licensure regulations result in a lot of false negatives; in other words, they screen out many individuals with excellent training and skills who would otherwise be great additions to Virginia's LPC community. For example, many of the graduates from Radford University have masters in Clinical Psychology, but they took many of the same courses as those in the Counseling Psychology program, sharing many of the same classrooms, instructors, assignments, and syllabi. Requiring some additional coursework and/or supervision may allay any professional identity or training consistency concerns. However, simply refusing to include these individuals in the LPC community is overly strict, results in fewer licensed individuals in the field and able to provide services (many agencies and insurances require the provider to be licensed), and has very negative impacts on the individual lives of these clinicians.

I am in support of this petition. I believe an individuals competence in the field should be the determining factor of whether they are able to become licensed. I have personally been affect by this. My options as a young professional are to move out of state to become licensed, or take a job in a field outside of my degree if I desire a livable salary. I know numerous others who have had to face this same situation. In the end it is the citizens of Virginia who are losing out. By restricting who is able to become licensed the board is actively passing up many young mental health professionals due to a matter of syntax, not because they are unfit to become licensed.

I fully support the idea of students who have graduated from clinical psychology programs being eligible to receive their LPC in Virginia. As a graduate from Radford University's Counseling Psychology program, I shared many classes with the Clinical Psychology students who were held to the same standard as we were and had a nearly identical courseload. Since graduating in 2007 I have encountered many very qualified clinicians who are not license eliglble due to the name of their program and have seen them become frustrated and discouraged by not being recognized as the excellent providers that they are. I believe that the Board should take this into consideration and open up the LPC credential for all who are qualified.

I graduated with my M.S. in Clinical Psychology from Radford University in 2009. I took all of the courses that the board required for LPC licensure and almost half of them were in the Counselor Education department as well. After having classmates be told that they were trained as "psychologists and not counselors" I began to explore other options. Not being license eligible is detrimental to a career in the mental health field. I worked at New River Valley Community Services for three years before determining that I needed to make a change in order to advance in the field. I even considered getting my MSW and leaving the field of counseling altogether. I was very well trained in the Clinical Psychology program at Radford University and excelled during my time at NRVCS as a clinician.

I moved out of the state in 1012 to explore other options and am ultimately being licensed as a Nationally Certified Counselor and Licensed Professional Counselor- Counselor Intern during the next month in Louisiana. I passed the licensing exam with scores well above the mean. It is a shame that Virginia's policies are forcing competent and capable counselors to leave the state to work in other fields or in counseling in another state. 

It is incredibly frustrating to be told that despite your training and competency that a matter of semantics is the reason you are not license eligible. Many states are now reaping the benefits of this policy that ultimately makes little sense. If one is well-trained, competent, and passes the licensing exam, there is no reason to deny licensure due to program title especially when the courses are the same.

I would like to formally announce my strongest support for the Chase Petition.  I graduated from Radford University in 2009 and went on to attend a Combined and Integrated doctoral program in Clinical and School Psychology.  My program had a strong counseling emphasis and we took many classes with the masters of counseling students.  When I went into these classes, I realized I had already covered this material extensively in Radford's M.S. program.  I was able to opt out of some counseling classes that my peers were required to take based on my performance with actual clients which were videotaped as rated by my professors.  Furthermore, I would like to add that my program required a master's degree for acceptance and ALMOST ALL of my peers had degrees in Counseling.  I was able to not only keep up with these peers, but I was also able to excel beyond them in many domains based upon the excellence in training that I was provided at Radford.  Looking back now as a psychologist, I have no doubts about the excellence of my program in training first class practioners and I am steadfast in my belief that my peers are capable and effective clinicans who have the skills, aptitude, and ability to work in many areas of the counseling field.  Please consider the request to allow my fellow graduates to be recognized formally through the process of licensure in being the true enactors of therapeutic change which I know them to be.  Their dignity as clinicans should be recognized through the granting of their ability to obtain licensure.  

My name is Rebecca Bivens and I am an alumnus of Radford University's Clincial Psychology master's degree program.  After graduating from the program, I attempted to become a licensed professional couselor (LPC) so that I could continue in my chosen career.  However, when I submitted my application, I was rejected.  In the rejection letter I received, the exact wording was as follows: "1. Specifically, the graduate level program you enrolled in does not have an expressed intent to prepare counselors; 2. There is not an identifiable counselor training faculty; and 3. The coursework on your transcript does not meet the core content criteria of the educational requirements set forth by Regulations as there is not a sequence of academic study with the expressed intent to prepare counselors."  Due to this rejection, I was forced to rethink my career path and so decided to return to school.  I was accepted into Virginia Tech's Human Development department and am now a Ph.D. candidate and the executive director of a new adult day service center in Princeton, West Virginia.  Although this career change was positive for me, it was a hardship for myself and many others who anticipated launching careers as counselors.  Drs. Chase and Elliott, faculty in Radford University's Clincial Psychology department, have worked continuously to overturn the ruling of the board some four years prior, and I commend them for their tenacity and caring of their students.  It is for that and all other reasons outlined above that I lend my full support to the petition forumlated by Dr. Chase.

I fully support the petition for Clinical Psychology majors to be eliglible to be licensed in the state of Virginia.  It makes no sense to offer a program in psychology and then deny the graduates the opportunity to sit for licensure.  It becomes a waste of time and money neither of which people can afford.

Let's Go Highlanders! I am a graduate of the counseling psychology program at Radford University. We took classes with students in the clinical program. I now work with a graduate from Radford University's clinical psychology program. We share many laughs and memories from RU, but more importantly I am confident in his clinical skills. I know what was expected from the professors at RU, and what their students must accomplish to get their degrees. We work side by side in the field, but due to the name of his program he is ineligible to be licensed. I feel he should be allowed to complete hours toward becoming a LPC. All students who have completed the needed courses should be eligible.

I clearly support any changes to the regulations for the Laws Governing Licensed Professional Counselors that will support individuals who are competent to provide counseling and have faced such debilitating complications from an organization that should be there to promote support and encouragement to thrive in their profession as therapists. I earned my LPC for Texas and due to the regulations, the Virginia Board of Counseling has declined to endorse my license and will not allow me to register under a Board Approved Supervisor. I completed my Masters Degree in 12/2001 in Counseling Psychology. I was told that though my degree was in “Counseling Psychology” I still did not have enough “counseling” courses. I graduated from a 48 credit hour approved masters program with thesis in 2001. I have over 12 years of experience that has taught me valuable skills, techniques, and knowledge that I could have never gained in a classroom. I cannot register under a board approved supervisor due to the lack of course work and lacking 150 internship hours to match the 600 required by Virginia. Did I mention I have over 12 years of experience? Taking course work, though time consuming and costly, is easy to accomplish through online courses but it is impossible to enroll in just a course to complete 150 internship hours. All programs require that you are a full-time graduate student to enroll in an academic advised internship. So now that I cannot register under a board approved supervisor, after 12 years of experience and direct client contact, I am no longer able to have direct contact within my current employment or any employment that I should qualify for. What a punch in the gut this has been. I am expected to complete the 4 required courses in 3/2014 but this still leaves the 150 internship hours needed to register under a board approved supervisor which is needed to complete 500 more hours of residency requirements, as I only completed approximately 3500 hours in Texas (only needed 3000) and in Virginia 4000 is needed. So over 12 years of experience appears to lack any substance, weekly meetings with a supervisor during these 12 years is considered non-existent, and my future to become a licensed professional counselor in Virginia currently looks impossible due to the current academic standards. Instead of moving forward within my career I have been placed on hold and over looked for numerous career opportunities.

Please consider changes in the regulations of the laws governing counselors as there are so many competent and much needed individuals that are in the same position.

Christin Guretsky, MS

As a 2007 graduate of the Counseling Psychology program at Radford University, I am aware that individuals in the Clinical program completed coursework with professors and syllabi identical to mine. It is unfortunate that  these individuals are not able to proceed with the LPC application process. Furthermore, it seems inappropriate to change requirements during the process. I support the entirety of the Chase petition. 

I support Dr. Chase's petition to revise the Degree Program Requirements of the Virginia Regulations Governing the Practice of Professional Counseling. When I was attending Radford University, I chose the Clinical Psychology program with emphasis on assessment because I believed it would better prepare me for a well rounded career in counseling. I worked for a local Court Service Unit for approximately 13 years. When I left that job to pursue other opportunities, I found I was unable to pursue my L.P.C. as the board had changed it's regulations to exclude anyone with a degree in Clinical Psychology. My options at this point are to either go back to school to obtain another degree or go to another state and get liscened. At this time, I cannot afford to pursue either option.

I support this amendment. I think it is unfair to exclude people with Clinical Psychology backgrounds when they generally have the same type of course work as those of us with Counseling Psychology backgrounds.

In my previous posting, there was a typo. I left Virginia to move to Louisiana in 2012 not 1012.

I understand the frustration of those who have a pschology background seeking counseling vocations and credentials; however, my frustration would reflect yours if I wanted to pursue a licensure in a vocation such as school psychology. The courses under each discipline are not the same, which is why there are often two separate programs within a higher education . If I wanted to get any type of licensure in psychology, I would need to begin taking courses for it. I would expect the same for anyone in the psychology field pursuing to be a LPC.

Counseling and psychology are two totally separate disciplines and fields of study.  If a student wishes to become a counselor, a counseling program is appropriate.  A student wishing to become a psychologist would study psychology.  At some point, I would like to become a psychologist, but I am aware that I will need to obtain a degree in addition to a master's in counseling to do so.  I would never expect that degree and an LPC to qualify me as a psychologist.  The education is different for each occupation and I feel that each would be ill-equipped to do the work of the other.

Mr. Chase's petition to be licensed as a professional counselor in Virginia is an attempt to undermine the profession of counseling.  Simply put, he entered and completed a training program in psychology.  Psychology is a distinct profession separate and apart from counseling.  The psychology profession recognizes this, as they do not allow people with doctoral degrees in counseling or social work to receive licenses as psychologists.  Similarly, the social work profession does not allow those with degree in counseling or psychology to receive licensure as social workers.  I see no reason why the counseling profession should allow those with a degree in psychology or social work to receive a license as a counselor.

This is not an issue of CACREP vs. non-CACREP programs. It is an issue of Counseling as a distinct profession, and Psychology as a distinct profession.  Psychology and Counseling have distinct philosophical and practical differences, which are reflected in the curricular experiences each requires.

As for the argument that there are not enough training programs in Virginia preparing counselors, there are 12 CACREP accredited Counseling master’s programs in Virginia, and another six Counseling Masters programs that are not CACREP accredited across the Commonwealth, so there is no lack of opportunity to address the needs of students or of the public.  If Mr. Chase wanted to be licensed as a professional counselor, he should have enrolled in a program with a clear commitment to training counselors, not psychologists. 

It is unfortunate that psychologists do not license their graduates at the master's level.  I have empathy for the situation Mr. Chase finds himself in, but to rule in his favor would be to undermine all of the work the counseling field has been doing to unify the profession and establish a clear professional identity separate and apart from psychology.
 

Counseling and psychology are distinct disciplines which produce graduates with professional identities particular to each discipline. Counselors are not psychologists, nor are psychologists counselors. Yes, there can be overlap regarding professional duties and interdisciplinary coursework, and we share the common desire to ameliorate clients' mental health issues, yet our disciplines are not the same and thus, we are not licensed the same.

An LPC is a Licensed Professional Counselor, and those who hold the LPC are held to the standards of the counseling profession through their counseling master's degrees, their professional identities, their professional affiliations, and their professional focus. There are three licenses that people who align with and hold degrees in psychology can obain in the Commonwealth: Applied Psychologist, Clinical Psychologist, and School Psychologist. As a person who holds a counseling master's degree, I would not expect the Commonwealth of VA to license me with any of the three aforementioned licenses because the LPC is the appropriate designation for the education credentials I hold. At the core, public welfare is at stake if people with psychology degrees are granted an LPC just as much as it would be if those of us who hold counseling master's degrees were granted a psychologist license. Ethically, it would be erroneous and dangerous to public welfare to issue LPC credentials to people who do not hold counseling master's degrees.

I feel for the folks who have earned degrees that do not lead to the license they thought they would be able to obtain. Faculty in both counseling and psychology master's programs are responsible for educating their students about their profession's identity, licenses, and responsibilities. So too, students are responsible for researching master's programs, professional identities, and what license(s) each degree will prepare them to obtain. From my perspective, this is petition is a "knee-jerk reaction," and it endangers counseling consumers in the Commonwealth of Virginia. Virginia was first in the US to recognize and credential counselors as a distinct profession. A high standard was set, and that standard needs to be maintained. I do not support this petition.

As a licensed professional counselor, I strongly oppose this idea.  Having a BS in psychology and a M.Ed. and PhD in Counselor Education, I am well aware the differences posed in these two very different disciplines.  I had the option of choosing Counseling or Psychology for my graduate studies and made my choices based on the distinct philosophical differences. I appreciate what the two fields offer and would like to make the distinction clear by not sharing a licensure from two different Master’s Program. Please keep my licensure clear and void of confusion. 

I strongly oppose this petition.  The Board of Counseling in Virginia has determined that it cannot ethically sanction those trained in the discipline of professional psychology to practice as Professional Counselors, just as the Board of Psychology cannot ethically sanction those trained in the discipline of Professional Counseling to practice as professional psychologists.

It stands to reason that if one is trained for one distinct profession, one will not be able to adequately represent another.  Counselors and Psychologists have different philosophies and training.  In order to best serve clients we must be adequately trained.  This petition would not help the people who need it most.  

Protect clients. Assure them that counselors will have the proper background and training in a Counselor Education master's program. As a counselor who has both a major in Psychology and a Counselor Education graduate degree, I am convinced that these disciplines are distinctly different. I respectfully, yet adamantly, oppose this proposition. 

I strongly oppose this petition. Professional counseling is a distinct profession with its own set of educational requirements and ethical standards. Those who have studied and been trained in Professional Counseling can not then be licensed as a professional psychologist, it would be unethical. So, it stands to reason, that someone trained in professional psychology could not then be licensed as a Professional Counselor.

Counseling and Psychology are two different disciplines, with different philosophies, practices, codes of ethics, and training requirements.  Psychology graduate programs prepare students for psychology licensure not counseling licensure.  The content of the psychology graduate courses differ significantly from counseling graduate courses, even if the titles of the courses are similar.  Please do not compromise the meaning of the LPC by reverting back to a flawed policy of recognizing psychology master's degrees as comporable to counseling master's degrees.

Thank you,

Laura Welfare

While I feel for those individuals who graduated with a master’s in Psychology and then recognized that they were ineligible for the LPC, I also believe that it is the job of the Board of Counseling to ensure the welfare of clients, and to evaluate the preparedness of professional counselors.

I am well aware as a counseling student that I will not ever be a psychologist. I chose my degree based on the skill set I wanted to learn, and the licensure options eligible to me upon graduation. I also feel defensive of the LPC title, because I believe that Psychology and Counseling are distinct professions with differing philosophies. The Board of Counseling in Virginia ruled that it cannot ethically sanction those trained in the discipline of Professional Psychology to practice as Professional Counselors. Similarly, the Board of Psychology cannot ethically sanction those trained in the discipline of Professional Counseling to practice as Professional Psychologists.

There is no lack of opportunity in Virginia for those who wish to obtain their LPC to receive the adequate education to do so. Virginia has 12 CACREP accredited Counseling master’s programs, and an additional 6 programs that are not CACREP accredited.

I hope to eventually achieve my LPC, and I want the integrity of that license to remain in tact. It would be a disservice to clients seeking the services of an LPC if those without the appropriate training were eligible for this license.  It would also be a disservice to current counseling students who are working so hard for their degrees in a unique and distinct discipline to have that license compromised.