Jaime Hoyle, Executive Director

Virginia Board of Counseling, Psychology, and Social Work

9360 Maryland Drive

Suite 300

Richmond, VA 23233

Subject:  Opposition of the Association for Multicultural Counseling and Development to the petition for endorsement of the National Counselor Licensure Endorsement Process.

The Association for Multicultural Counseling and Development (AMCD) stands with the American Counseling Association (ACA), the Virginia Counseling Association a state branch of ACA and the Virginia Association for Multicultural Counseling and Development at state division of AMCD in opposition of the National Counselor Licensure Endorsement Process.

AMCD supports professional counselor licensure portability and professional counseling standards however, we do not support restrictions or policies that would intentionally lockout, delay or limit the licensure of qualified professional counselors in the to the Commonwealth of Virginia without merit or research.

AMCD does not support the current NCLEP Model for the following reasons:

• 3 year waiting period for professional counselors that are currently license is too restrictive.
• Model significantly limits minority serving institutions (Historically Black Colleges, Hispanic Serving Institutes, Tribal Colleges, financially marginalized institutions) in developing qualified, ethical professional counselors to provide services to a growing diverse population(s) in the Commonwealth of Virginia.
• No evidence of regulations would provide protection to public.

AMCD does support the ACA Model for the following reasons:

• Model addresses the increasing standardization of training and postgraduation supervision requirements.
• Includes all independently licensed professional counselor and is respectful of the training that counselors undergo.
• Model designed with the intention of protecting the public.
• Model stipulates that portability is contingent upon a violation-free practice.

It is for these reasons that we stand with ACA, VCA and VAMCD is opposition of the NCLEP model and request the board vote no.  We further request and advocate that the ACA model be adapted as the licensure portability model for the Commonwealth of Virginia.

Sincerely,

Shon D. Smith, Ed.D., LMHC,

Clinical Assistant Professor

Association for Multicultural Counseling and Development – President 2018-2019