Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Counseling
 
chapter
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]
Action Requirement for CACREP accreditation for educational programs
Stage Proposed
Comment Period Ended on 7/14/2017
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458 comments

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5/16/17  8:52 am
Commenter: Larry Epp, Ed.D., LCPC, Past President, Maryland Chapter, LCPCM/AMHCA

Opposed: Regulation will Diminish Access to Mental Health Professionals in Virginia
 

This initiative is an implicit attempt by CACREP accredited universities to achieve market exclusivity in licensure. It will gradually eliminate or harm graduate programs that offer Masters degrees in Counseling Psychology, Creative Arts Therapy, Clinical Psychology, Sports Psychology, Forensic Psychology, among others, that qualify for licensure as a mental health counselor. In a CACREP-only state, these degree programs would not be recognized or approved by the state professional board; and the degree holder would be unable to practice as a mental health counselor.

I support an inclusive vision of mental health counseling, based on meeting course and clinical experience requirements, not degree title or accreditation. I am very concerned when an accreditation body attempts to create an educational monopoly, based on unproven claims of superiority, and does not allow alternative accreditation bodies to approve equivalent routes to mental health counselor licensure.

The Commonwealth of Virginia should be working toward parity of licensure between Maryland and Virginia to insure an ample supply of mental health professionals who can practice in Virginia; since such a policy would allow all Virginia residents access to highly qualified mental health professionals who could relocate from Maryland, if needed. Unfortunately, that is not the stance the Commonwealth is taking. They wish to make licensure more restrictive based on graduate program accreditation, an arbitrary standard, rather than the competency or experience of the practitioner. The narrowness of this approach is curious at a time when Virginia is in need of highly qualified mental health professionals to treat their residents.

CommentID: 59121
 

5/17/17  3:16 pm
Commenter: Joshua Murray, Cedar Ridge Children's Home and School

Opposed: Do Not Make Virginia CACREP-only State.
 

There is no good outcome for making Virginia a CACREP-only state. Any invidivual who meets current licensure requirements in Virginia would be one of the most qualified license applicants in any state as Virigina already has high standards for education and professional practice. As a Maryland-licensed professional counselor who completed my Master's degree in Virginia, including practicum and internship, and as someone who has a goal to return to Virginia and be licensed there, I must say that this proposal would only serve to prevent people from finding qualified counselors. Do not give in to pressure from CACREP accredited schools seeking their own financial gain at the cost of the people who actually need help. 

 

Sincerely yours,

Joshua S. Murray, MA, LCPC

CommentID: 59246
 

5/17/17  3:22 pm
Commenter: Cristina Machin LCPCM

Opposition to making Virginia a CACREP only state
 

There are many qualified counselors that have worked hard to get their license and accreditation even when CACREP was not available.  To limit counselors to only CACREP certified programs would severely limit the accessibility to mental health care.  As a bilingual professional, there are not enough qualified bilingual counselors and this new law would only limit the numbers more.  I am certified in Maryland and Delaware - I would not get certification in Virginia.

thank you for providing this forum.

CommentID: 59248
 

5/17/17  3:25 pm
Commenter: Liz Park

Opposition to make Virginia a CACREP-only state
 

I am opposed to making Virginia a CACREP-only state.  I beleive it will gradually eliminate or harm graduate programs that offer Masters degrees in Counseling Psychology, Marriage and Family Therapy, Creative Arts Therapy, Clinical Psychology, Sports Psychology, Forensic Psychology, among others, that qualify for licensure as a mental health counselor and have prorams approved by othr accredidating boards. I do not beleive that one accrediation baord should have a monopoly on the profession of mentla health counseling. .

CommentID: 59250
 

5/17/17  3:26 pm
Commenter: E. jonathan Klopp LCPC

Opposed: CACREP only damages the mental health system and patent access to high quality care
 

A CACREP only policy will dramatically limit access to mental health care by decreasing access to highly qualified counselors at a time when the need for quality mental health care is rapidly rising.  Virginia and Maryland shoud be working together to standardize the board requirements related to practice (note that the Maryland standard spells out coursework and curriculum but does not insist on only one organization being in charge of certifying them, resulting in high quality care throughout the state and improved access for patients to care) to increase portability and patient access to quality care.  Licensed counselors in both states have a proven track record of delivering good care, and using CACREP is likely to decrease this drastically.

CommentID: 59251
 

5/17/17  3:30 pm
Commenter: Chris Hall, LCPCM

Opposition to making Virginia a CACREP-only state
 

Doing so would result in diminished access to mental health services.

CommentID: 59252
 

5/17/17  3:35 pm
Commenter: Shannon

Opposed to cacrep only
 

Strongly opposed to making VA a CACREP only state. No valid rationale.

CommentID: 59253
 

5/17/17  3:38 pm
Commenter: perry nerantzis

egulations Governing the Practice of Professional Counseling [18 VAC 115 ? 20] Action: Requirement f
 

in principle i agree with the commonwealth position to add a requirement for all counseling programs leading to a license as a professional counselor to be clinically-focused and accredited by the Council for Accreditation of Counseling and Related Educational Programs (CACREP) or an approved affiliate, such as the Council on Rehabilitation Education (CORE).

i would just want to make sure that recipocity between states and the ablity to practice in said states is NOT limited to whether a particular school was CACREP accredited.

CommentID: 59254
 

5/17/17  3:41 pm
Commenter: Aldin Gordon, DITTO

Stupidity of a ten year old system.
 

This is the most uneducated idea from the system of education. Lets do some math. CACREP is literally in existance for, lets be generous, twelve years. Which means that 90% of the professionals in the field are  over the age of 35 and will lose their licensure. LCPCM and other organization should start coupleing their resources to file a discrimination class action law suite. This is discrimination by age. 

CommentID: 59255
 

5/17/17  3:41 pm
Commenter: Barbara Fairfield, LCMFT

Objection to restricting Virginia licensure for licensed counselors
 

As a long-term marriage and family therapist in the state of Maryland I strongly object to the proposed legislation that would restrict licensure for professional counselors in Virginia to only persons who had graduated from Virginia programs. This would severely limit the availability of experienced and qualified professionals to Virginia citizens. Furthermore, there are parts of Virginia that are geographically close to Maryland or D.C. and not allowing professionals from those areas to proactice by being licensed in Virginia would mean that individuals and families in the DC area would be unable to choose among various skilled and trained professionals. There are many specialties within our profession and people need to be able to obtain services tailored to their particular needs. The more in depth the pool of providers are, the more choice and appropriate services can be obtained by the consumer. This legislation does not serve the community; it only serves the university or training programs in Virginia. This is an economic, self-serving piece of legislation, not an effort to serve the citizens of Virginia!

CommentID: 59256
 

5/17/17  3:44 pm
Commenter: Ben Toma, LCPC, Alexandria CSB

I graduated from CACREP accredited schools. We are not superior.
 

I graduated from a CACREP accredited college (Lynchburg College) in Va in 1998, I am licensed in both Maryland and Virginia. Needless to say, I have found the post-masters certificate at Johns Hopkins (CACREP accredited).  Both have conributed to my development as a professional, yet I am certain that CACREP does not necessarily ensure higher competence. I have colleagues who did not graduate from CACREP insitutions and they display a high level of skill and competency; and, numerous clients finf them helpful.  I do not believe that the CACREP monopoly will be helpful to anyone.

CommentID: 59257
 

5/17/17  3:45 pm
Commenter: Rebecca Schaffner

AGAINST CACREP ONLY
 
There are less CACREP accredited programs in this nation and having CACREP only states would not only decrease services for people in MH crisis, emotional turmoil,or psychotic symptoms but it will also severely impact public health.The population will be in more stress and will have less resources to draw from. You are depriving people from a basic services by limiting their availability and aiding in damaging their health!
CommentID: 59258
 

5/17/17  4:13 pm
Commenter: Lifes Foundation

Against CACREP only
 

Against the CACREP only, as it favors schools and graduates.  A state license and degree is good for all persons, and we need not discriminate.  Let's be inclusive!

CommentID: 59260
 

5/17/17  4:20 pm
Commenter: Dr. Robins.

Against the Trump ban!! I mean CACREP monopoly!
 
CommentID: 59261
 

5/17/17  4:22 pm
Commenter: Janet Glover-Kerkvliet, LCPC

I graduated from Johns Hopkins University when it was a non-CACREP program
 

I understand the need for accreditation and standardization. However, licensing CACREP-only graduates will deplete a great deal of talent and experience in Virginia and any other state where such a regulation is passed. If Virginia and other states do this, there should be a grandfathering clause and/or have the non-CACREP counselors take another exam. The mentally ill are already underserved for a variety of reasons. I urge Virginia not to further deprive their residents of mental health services.

 

 

CommentID: 59262
 

5/17/17  4:27 pm
Commenter: Maureen O'Brien,LCPC Inspirit Counseling Services & UMSJMC Medical Center

As a clinical supervisior for many years of counseling students I have witnessed a certain frustrati
 

CommentID: 59263
 

5/17/17  4:31 pm
Commenter: Dr. Pamela Rice, The Rice Counseling Service

I am against the proposed CACREP only policy.
 

CommentID: 59264
 

5/17/17  4:37 pm
Commenter: Jolene Farmer, M.A., NCSP, LGPC

Against these standards
 

I am very opposed to restricting licensure this way. This disqualifies people who come to the mental health field from other similar fields, such as myself. We need to look at having more qualified counselors and therapists, not less. Not everyone graduates from a specific masters program and then practices. For example, I am a school psychologistt with a Master's plus 30 degree. I only needed 6 additional classes to qualify for licensure in Maryland. Having this opportunity has given me greater experience in brining new techniques and therapies to the students I work with on a daily basis. Please do not enact this restrictive licensure plan. 

CommentID: 59267
 

5/17/17  4:58 pm
Commenter: Mollie Thorn, LCPCM Board President

Please do not block Mental Health counselors from practicing in Virginia
 

I am concerned that Virginia is considering not accepting for practice any mental health therapists who did not earn their graduate degree at a university which was accredited  by CACREP. When a state decides to arbitrarily restrict the practice of mental health in this manner, the public is prevented from exercising the freedom to choose a therapist to treat them by an unreasonable standard. All 50 states already have stringent standards for licensing mental health counselors. The CACREP standard is an unreasonable one that unfairly restricts the public from choice, as well as restricting the pool of potential mental health practicioners from providing a needed service to the community.

 

CommentID: 59271
 

5/17/17  5:13 pm
Commenter: Kathleen Russo-Garcia

Against the CACREP only policy
 

Requiring graduation from a CACREP only graduate program to become a  licensed mental health counselor in Virginia is dangerous.  Many experienced, highly qualified professionals will be unable to continue practicing in Virginia, leaving a shortage of providers.  A shortage of providers could become a public safety issue. 

CommentID: 59273
 

5/17/17  5:15 pm
Commenter: Heidi Lindorf, MFT Resident

Strongly Opposed
 

I am strongly opposed to this regulatory action.  The CACREP standards are fairly broad.  We need highly trained mental health professionals, which means specialization--not being exposed to broad standards.  Having graduated from a COAMFTE accredited program, which is specialized in Marriage and Family Therapy, I can say that if I needed help with my marriage, I would only go to a therapist/counselor who graduated from a COAMFTE progam. 

We also need more mental health professionals (there is a huge need).  Obviously, we need to have a standard because we want competent mental health professionals.  Creating this regulation would not help accomplish either more or competent mental health professionals.  This regulation creates narrower standards, but not higher standards.  I don't see the benefit to people in need of mental health care by making this regulation.

 

CommentID: 59274
 

5/17/17  5:19 pm
Commenter: Dalphine Cager, Ph.D., LCPC

Cacrep only policy
 

I am against a Cacrep only policy.

CommentID: 59276
 

5/17/17  5:20 pm
Commenter: Brenda von Rautenkranz,LCPC

Opposition to Making CACREP -Only State
 

Opposition to Making CACREP-Only State

CommentID: 59277
 

5/17/17  5:27 pm
Commenter: Dalphine Cager, Ph.D., LCPC

I oppose a CaCrep only policy
 

A CaCrep only policy is discriminatory and very inconsiderate of professional counselors and other mental health specialists who have met all requirements, are licensed and qualified to practice, and have acquired years of experience in private practice.   It is just rediculous and selfish.  This is becoming like a sorority or club designed to single people out and to include people of one's individual choice. 

CommentID: 59278
 

5/17/17  5:48 pm
Commenter: LuAnn Oliver

CACREP will not ensure good therapists
 

CACREP will not ensure good therapists and will make it a difficult process to get a license.  Let's find other ways to encourage therapists to seek ongoing post graduate training.  But the real training doesn't happen in college it's aftter.  So this is unnecessary.  

 

CommentID: 59280
 

5/17/17  8:02 pm
Commenter: Tyisha Woodroffe,LCPC

Think of the clients we serve
 

The decision to make the state of Virginia a CACREP only state is quite dangerous.  I don't believe that this decision is based on sound evidence that CAPCREP programs better equip clinicians to go out into the workforce. I know many highly skilled clinicians that did not graduate from a CACREP program.  In certain rural areas where having a licensed clinician is invaluable this decision will negatively impact the community.  Please take these comments into consideration before th law is changed.  

CommentID: 59285
 

5/17/17  8:04 pm
Commenter: Scott Alpert

take your license and stick it where the sun don't shine. over 28 years in this field and thits is
 
CommentID: 59286
 

5/17/17  8:05 pm
Commenter: Edward G. Lambro, Ph.D, CCMHC, LPC - Private Practice Associates

Competency builing not business building
 

Most Master's level counseling programs in the US are first rate.  There is no need to add an additional hurdle for students to negotiate. Demanding CACREP accreditation is an insult to some very fine schools and their programs. On first blush, it seems to have a business cache to it, not a clinical one.

CommentID: 59287
 

5/17/17  8:24 pm
Commenter: Rachel Soifer

opposition to CACREP only
 

Opposed: this policy will dimish the diversity and that empowers mental health professionals and the programs we attend to be high quality, vibrant and attractive.  Please do not pass.

CommentID: 59290
 

5/17/17  8:50 pm
Commenter: Amy M. Cohen, LLC

Against
 

Against CACREP ONLY. Discriminatory and unnecessary. 

CommentID: 59295
 

5/17/17  8:55 pm
Commenter: Becky Riley Olin, LCPC, MT-BC

Opposition to CACREP only
 

I am strongly opposed to this CACREP only initiative. At a time when mental health professionals are so deeply needed, a regulation like this would only decrease the services and supports to the people of Virginia! This initiative would narrow standards for mental health practice, but it certainly would not improve or provide for higher standards. Shame on those who seek this educational monopoly. This will only harm the people of Virginia who need quality supports! 

CommentID: 59296
 

5/17/17  10:36 pm
Commenter: Patricia Simpson, MS, LCPC, C-IAYT, LCPCM

Dummying down the counseling profession serves no one.
 

The citizens of the Commonwealth of Virginia will suffer if CACREP is given full rein of training professional counselors. 

CommentID: 59305
 

5/17/17  10:41 pm
Commenter: Toni Maxwell

Opposed to CACREP only state.
 

These standards would hinder licensed professionals from fulfilling their career goals. 

CommentID: 59307
 

5/17/17  11:36 pm
Commenter: Madrical Thompson, M.A., LPC, LCPC

No to Carep only
 

Limiting the diversity and talent in the mental health professions does a disservice to our clients, professors and various fields.  This is not a one size fits all, cookie cutter profession and I doubt any client or clinician would want it to be.  Schools should be as diverse as are the multitudes of people who will utilize the services.

CommentID: 59309
 

5/18/17  12:11 am
Commenter: Christy Gordon

I oppose Virginia as a CACREP-only state
 

I refer many clients over to Virginia and this will make mental health services providers more difficult to locate or access

CommentID: 59311
 

5/18/17  2:43 am
Commenter: Rodrick D. Williams

Opposition to CACREP Requirement
 

 

Dear Virginia-

It really saddens me to know that VA will potentially move to a CACREP only state.  This will harm many individuals who seek mental health and especially our veterans.

I am in a unique situation because I am a Marriage and Family Therapy degree holder who is licensed as a LPC/LCPC (I did the extra work to obtain my LPC because it was important to me).  This will not only hurt service delivery to our US citizens, but it will hurt many experienced mental health providers. 

Please reconsider for this will harm many lives in a negative manner. 

V/R,

Rodrick Williams 

CommentID: 59314
 

5/18/17  5:09 am
Commenter: Karen Diggs

OPPOSE CACREP ONLY PROGRAM
 

MENTAL HEALTH CLIENTS WILL SUFFER.

CommentID: 59315
 

5/18/17  6:00 am
Commenter: Nakitta McLean, M.Ed; LGPC; Turning Point Clinic

Opposition to make Virginia a CACREP-only state
 

I am opposed to making Virginia a CACREP-only state.  I believe that it will gradually eliminate or harm graduate programs that offer Masters degrees in Counseling Psychology, Marriage and Family Therapy, Creative Arts Therapy, Clinical Psychology, Sports Psychology, Forensic Psychology, among others, that qualify for licensure as a mental health counselor and have prorams approved by othr accredidating boards. I do not believe that one accrediation board should have a monopoly on the profession of mental health counseling.

Further more, it will limit the professionals who are working so diligently within the field. This is suppose to be a realm where we are able to assist our fellow man, if we began to limit the professionals that are qualified to assist them how can we say we are giving them the best advantage to move forward? 

CommentID: 59316
 

5/18/17  6:08 am
Commenter: Nathan Calvino, LGPC

Virginia will only lose more therapists
 

I already left Virginia to practice in Maryland due to clinical psychology degrees not being accepted in Virginia. Everyone in the field knows why an individual with a Master's degree in clinical psychology is not allowed to practice in Virginia. Is it because of evidence that clinicians with counseling degrees provide better psychotherapy than individuals with clinical psychology degrees? Certainly not! Rather, it is because lawmakers have listened to special-interest lobbyist groups, and not to their own common sense. This is an appeal for decision makers to start listening to common sense, rather than to lobbyist money.

CommentID: 59317
 

5/18/17  7:50 am
Commenter:  

CACREP Only State
 

I oppose making Virginia a CACREP only state. This will restrict qualified service providers from providing needed services.

CommentID: 59318
 

5/18/17  8:29 am
Commenter: Wayne Marshall LCPC

Va. Is attempting to monopolize the system $. At the consumers detriment. I wholly OBJECT!
 
CommentID: 59321
 

5/18/17  9:07 am
Commenter: Leslie Stanbury, L.C.P.C.

Oppose CACREP only requirement
 

CommentID: 59323
 

5/18/17  9:13 am
Commenter: Nicole Barber, LCPC

I strongly oppose this proposal
 
Istrongly oppose this proposal
CommentID: 59325
 

5/18/17  9:53 am
Commenter: Melissa Wesner / LifeSpring Counseling Services

Strongly Oppose CACREP-Only Proposal
 

I am writing to communicate strong opposite to the CACREP-only proposal.  Many highly regarded institutions are not CACREP accredited, and yet they produce competent, highly-trained clinicians.  CACREP and it's affiliates have made unsubstantiated claims that providers who graduated from CACREP universities are more competent. It is important for those voting to understand CACREP and their affiliate's motives for encouraging this change and for disseminating inaccurate and misleading information about the benefits and necessity of graduating from a CACREP school. 

CommentID: 59328
 

5/18/17  9:55 am
Commenter: Marlene K. Backert, LCPC; NCC, BCPCC

CACREP only
 

I strongly oppose the proposal to limit all LCPC's for licensure based on the school they attended for their education.  If they can pass your current licensing test and requirements, they should be given the opportunity to serve the people of VA.  This seems to be a way for certain schools to have a monopoly on the counseling profession.  You will be excluding many seasoned professionals who attended schools prior to the CACREP era being implemented.

 

B.Marlene K. Backert, LCPC, NCC, BCPCC

 

CommentID: 59329
 

5/18/17  10:14 am
Commenter: Shaun Robbs LCPC

A bridge to far
 
People in leadership making bad choices. License takes care of those issues after you graduate
CommentID: 59330
 

5/18/17  10:22 am
Commenter: Tammerra Hewitt, Anew Care Counseling Service, LLC

I oppose CACREP only professionals in Virginia.
 

I am a supervisor in the state of Maryland.  When I compare my interns masters programs to the non cacrep programs, I am truly confused about the fuss.  Most of the CACREP programs do not require and comprehensive exam or a masters thesis.  The requirements for non CACREP programs are equivalent, if not, superior to these newer curriculums.  I think the pioneers of the mental health profession should be respected for their rigor, instead of being treated like we are obsolete and being pushed aside.  We have just as much, if not, more to offer to the mental health profession.

CommentID: 59331
 

5/18/17  10:39 am
Commenter: Earlene Williams, LGPC

Stop! CACREP-only state in VA
 

"We feel this initiative is an implicit attempt by CACREP accredited universities to secure market advantage in licensure. It will gradually eliminate or harm graduate programs that offer Masters degrees in Counseling Psychology, Creative Arts Therapy, Clinical Psychology, Sports Psychology, Forensic Psychology, among others, that qualify for licensure as a mental health counselor. In a CACREP-only state, these degree programs would not be recognized or approved by the state professional board; and the degree holder would be unable to practice as a mental health counselor.ype over this text and enter your comments here. You are limited to approximately 3000 words." LCPCM

CommentID: 59332
 

5/18/17  12:13 pm
Commenter: Kathleen LaVina, LCPC, LCADC, RN

Oppose CACREP Only
 

Opposed to CACREP only regulations for mental health counselors.  This type of regulation assumes accreditation is the only measure of quality and that is just not true.  

CommentID: 59334
 

5/18/17  12:45 pm
Commenter: Arthur Flax, LCPC

Oppose CACREP
 

 

It is my professional opinion both as a LCPC and as an practictioner registered with the Workers Compensation Commission, the issue is quality of education provided, practical training and experience and not the "acceditation" designated by a particuar organization.  These so called acceditations are self serving, promoting a set of values consistent with the organizations mission, rather than the needs of the patient. I have witnessed this in the social work profession where the primary national organization places a cri;teria of certain values over the self determination of both professionals and clients. This is what you want for professional counselors, a monoliithic agenda. Education must be based on respecting the self determination of both the client and professional. Learning counseling skills does not require and is restricted when a particular organization dictates the agenda a college /professional training must adhere too in order to qualify for membership. It becomes policitized valueing one set of propective other another.  All you have to do is understand history and how well meaning counselors and physicians began a process to improve the quality of peoples lives by endorsing and participating first in the euthenasia of "defective" newborns, then the disabled, until a population accepted it and which resulted in the holocast.  No one organization and it's philosphy should be dominate let alone required. Comprehensive quality education is required respecting all people.

 

CommentID: 59335