Greetings to the Viginia Board of Counseling,

The discipline of counseling is a technical offshoot of the discipline of psychology. Counselors and Counselor Educators, for most part rely on the scientific and practical work of psychologist as the base their expertise. The CACREP-Only movement is based on the desire to corner the market on mental health work. It has nothing to do with patient welfare or the the public good. In fact, it works against the public good by limiting the potential training opportunities for masters level counselors, both in terms of the provision of supervision and in terms of their exposure to a diverse faculty of mental health experts. I currently work as an Assistant Professor teaching in a Counseling Department. Based on regulations like "18 VAC 115 20 Regulations Governing the Practice of Professional Counseling”  and "18 VAC 115 50 Regulations Governing the Practice of Marriage and Family Therapy,” I would not be able to share my particular expertise in counseling theory and practice. 

As a Counseling Psychologist, I received over 5000 hours of supervised practical training in the provision of psychotherapy. I was required to take a course in clinical supervision as well as engage in supervised practice of clinical supervision. I was also required to build a deep understanding of psychological theory at both the undergraduate and graduate level, which is different from Counselor Education in that a psychology background is not always prerequisite for beginning counselor training. I share this with you not to claim any superiority, but to rebuff the idea that I should  be restricted from assisting in the training of anyone who plans to provide psychotherapy. 

I would ask that instead of placing CACREP-First, that you place the Public-First in your deliberations. I believe that Counseling is an important discipline, however I do not believe that it so unique that it must be taught by counselors exclusively. Nor should that desire for exclusive access to a market (i.e., a monopoly) be supported by the state. 

Thank you for your time and consideration.