To Whom It May Concern:

I am writing to oppose the current regulations that restrict counseling residents’ supervisors to people who hold Licensed Professional Counselor (LPC) or Marriage and Family Therapy (LMFT) licenses.  Licensed social workers, licensed psychologists, and licensed psychiatrists are also qualified to provide excellent supervision to counseling trainees and bring a wealth of knowledge that will ultimately be beneficial to the clients and patients they serve.  Supervision by other mental health professionals is also consistent with efforts to prepare health care professionals to work with members from other professions.  This current regulation specifically excludes the majority of qualified supervisors in hospitals and related clinical settings, most of whom are licensed as psychologists, psychiatrists, and social workers. If this regulation is not changed, the experience in other states has been that this will pose a significant employment barrier to new graduates seeking employment in agencies and regions of the state where these supervisors are not available (and who can only offer supervision through psychologists or social workers). This policy actually harms the employment prospects of new counselors and hampers the growth of the profession. In addition, it should be noted that this regulation, which has yet to go into effect, was adopted outside the normal processes after a public comment period in which all commenters opposed the then-proposed regulation.

I would also like to oppose the Board of Counseling’s continued efforts to restrict Virginia counselor licensure to graduates of programs accredited by CACREP, despite official withdrawal of the proposal last Fall. These continued efforts are documented in their minutes and are confirmed by reports from prospective licensees. CACREP-only restrictions would create a government-imposed monopoly of a private organization that is not accountable to the citizens of Virginia.

The proposed restriction that would limit licensure to graduates of programs accredited by CACREP and restrictions of graduates’ supervisors to LPCs and LMFTs are clearly NOT “necessary for the protection of public health, safety, and welfare or for the economical performance of important governmental functions,”  which are the goals of the periodic review.

Thank you for your consideration,

LaVerne A. Berkel, PhD

Licensed Psychologist