Agencies | Governor
Virginia Regulatory Town Hall
Department of Health Professions
Board of Counseling
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]
Public Comment Forum

On this Periodic Review

Review Announcement

Pursuant to Executive Order 17 (2014) and §§ 2.2-4007.1 and 2.2-4017 of the Code of Virginia, the Board of Counseling is conducting a periodic review and small business impact review of VAC citation:
18 VAC 115 15 Regulations Governing Delegation to an Agency Subordinate

18 VAC 115 20 Regulations Governing the Practice of Professional Counseling

18 VAC 115 50 Regulations Governing the Practice of Marriage and Family Therapy

18 VAC 115 60 Regulations Governing the Licensure of Substance Abuse Professionals

The review of this regulation will be guided by the principles in Executive Order 17 (2014).

The purpose of this review is to determine whether this regulation should be repealed, amended, or retained in its current form. Public comment is sought on the review of any issue relating to this regulation, including whether the regulation (i) is necessary for the protection of public health, safety, and welfare or for the economical performance of important governmental functions; (ii) minimizes the economic impact on small businesses in a manner consistent with the stated objectives of applicable law; and (iii) is clearly written and easily understandable.

The comment period begins August 6, 2018, and ends on September 5, 2018.

Comments may be submitted online to the Virginia Regulatory Town Hall at Comments may also be sent to:

Elaine J. Yeatts
Senior Policy Analyst
Department of Health Professions
9960 Mayland Drive, Suite 300
Richmond, VA 23233

Comments must include the commenter's name and address (physical or email) information in order to receive a response to the comment from the agency. Following the close of the public comment period, a report of both reviews will be posted on the Town Hall and a report of the small business impact review will be published in the Virginia Register of Regulations

CLOSED     Opened on 8/6/2018 and Ended on 9/5/2018

More about public comment forums and policies
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 Comment Title  Commenter
Strongly oppose supervision restriction John L. Romano, Ph.D., University of Minnesota, emeritus  9/5/18  11:06 pm
Opposed to supervision restrictions Dr. Sherry Ceperich, University of Richmond  9/5/18  10:39 pm
Opposed George Mason University  9/5/18  9:01 pm
I Oppose! Carly Johnston, Seton Hall University  9/5/18  7:23 pm
Strongly Opposed to CACREP Only Licensure & Supervision Restrictions Melissa Wesner, LifeSpring Counseling Services  9/5/18  6:45 pm
strongly support inclusiveness, not restrictions, for mental health counselors Sidney Trantham / Lesley University  9/5/18  6:23 pm
American Psychological Association urges inclusiveness in counseling rules Jared L. Skillings, PhD, ABPP, Chief of Professional Practice, APA  9/5/18  5:14 pm
Opposed to CACREP only Seton Hall University, College of Education and Human Services  9/5/18  3:06 pm
Strongly Opposed to CACREP-only licensure and supervision restrictions Ruth E. Fassinger, University of Maryland (Professor Emerita)  9/5/18  2:05 pm
Strongly opposed Wonjin Sim, Chatham University  9/5/18  1:27 pm
Strong opposition to the proposed regulation Mary Ann McCabe, Ph.D., ABPP, Independent Practice  9/5/18  12:02 pm
Opposition to proposed restrictions on program accreditation and supervision requirements Rachel L. Navarro, University of North Dakota  9/5/18  10:24 am
Strongly Opposed Kathryn Kominars, Florida International University  9/5/18  10:16 am
Opposition to CACREP-only policy in Virginia New York University  9/5/18  10:12 am
Strongly Opposed Jane Stafford, University of SC Aiken  9/5/18  9:58 am
Strong Opposition to Proposed Regulation Mark R. Ginsberg, Ph.D. George Mason University  9/5/18  7:36 am
Oppose restricting counselor residents' supervisors, oppose CACREP accreditation requirement Dr. Willow Pearson & Dr. Helen Marlo, Notre Dame de Namur University  9/5/18  12:07 am
OPPOSE RESTRICTION OF COUNSELOR LICENSURE Co-Chairs, Department of Professional Psychology and Family Therapy  9/4/18  10:53 pm
Professional Counseling Regulations Public Comments Eve Adams, New Mexico State University  9/4/18  10:42 pm
Urge all to reject CACREP only licensure and expand options for counselor supervision Peggy Brady-Amoon, PhD, LPC, Alliance for Professional Counselors (APC)  9/4/18  10:12 pm
Opposed Alex Hilert, M.Ed.  9/4/18  7:54 pm
Opposed to the Proposed Regulations Marley Lebrecht- Discover Center and Seton Hall University  9/4/18  7:54 pm
Strongly opposed to CACREP-only legislation Catherine A. Fiorello, Coordinator of Counseling Program, Temple University  9/4/18  6:11 pm
Opposed to the proposed regulation Peggy Farrelly, Ph.D., Seton Hall University  9/4/18  5:26 pm
strongly oppose CACREP efforts to restrict counselor training & practice Ruth Palmer, PhD, Eastern University  9/4/18  4:53 pm
Opposed Nicole DiCarlo, Univeristy of Baltimore  9/4/18  4:29 pm
Bad idea to support this Dom Scalise Ph.D.  9/4/18  4:17 pm
STRONGLY OPPOSED Jenny Yount, Johns Hopkins Bayview Adult Autism Clinic  9/4/18  4:10 pm
Strongly opposed to CACREP-only legislation Shay Long  9/4/18  4:09 pm
Opposed Emily Conte, Seton Hall University  9/4/18  2:49 pm
Strongly opposed to CACREP restrictions James Bludworth, Director of the Counselor Training Center  9/4/18  2:28 pm
Opposed to CACREP Restriction Noelany Pelc, Seton Hall University  9/4/18  12:09 pm
STRONGLY OPPOSED Jill Paquin, Chatham University  9/4/18  11:18 am
Opposed to restriction on supervisors and CACREP only Jennifer Q. Morse, PhD, Chatham University  9/4/18  11:12 am
Opposed! Seton Hall University  9/4/18  9:37 am
opposed Deanna Hamilton, Chatham University  9/4/18  8:40 am
Why We Need Counselor/ CACREP, Accredited, Collaborative, Supervision Nicole Lashane Ellis  9/4/18  6:36 am
Opposition to limitations on approved supervisors and proposals for CACREP restrictions on licensure Elaine Johnson, Ph.D., Retired, University of Baltimore  9/3/18  11:27 pm
Statement opposing restrictive counselor licensure and preparation Suzanne Lease, University of Memphis  9/3/18  11:09 pm
Opposed to restrictions on Supervisors and CACREP only accredidation Paul Bello, LPC Privage Practice Lexington VA  9/3/18  9:38 pm
Opposition to regulation Tori Stone, PhD, LPC George Mason University  9/3/18  10:54 am
Opposed restriction to only LPC and LMFT Rita Chi-Ying Chung, George Mason University  9/2/18  2:20 pm
Proposal to limit licensure to CACREP Program graduates John E. Smith, Ed.D.  9/2/18  11:59 am
Strongly oppose proposed regulation Fred Bemak, George Mason University  9/2/18  11:23 am
opposition Allie Minieri  9/2/18  11:21 am
Opposed Kristy Keefe, Western Illinois University  9/2/18  11:08 am
Regulation Would Limit Career Opportunities for New Graduates Larry Epp, Ed.D., Past President of the Maryland Chapter, AMHCA (LCPCM)  9/1/18  2:17 pm
Opposed Matthew Graziano, MSW, PhD, Seton Hall University  9/1/18  11:12 am
Opposed Seton Hall University  9/1/18  11:11 am
Opposed Tatyana Ramirez, Ph.D., University of St. Thomas  9/1/18  8:47 am
OPPOSED Sandra S. Lee, PhD, Seton Hall University  9/1/18  5:19 am
In Opposition to Proposed Regulation Dr. Rob Rotunda, University of West Florida  9/1/18  2:05 am
Strongly opposed to restriction of licensure and supervision Corinne Datchi, PhD, ABPP, Seton Hall University  8/31/18  6:42 pm
Comments on CACREP Anneliese Singh, University of Georgia  8/31/18  5:35 pm
Opposed to Board of Counseling Proposal to limit supervision Michael Scheel, Society of Counseling Psychology  8/31/18  4:36 pm
Oppose CACREP exclusionary supervisor licensure requirements Heidi A. Zetzer, Ph.D.  8/31/18  4:30 pm
RE: "18 VAC 115 20 Regulations Governing the Practice of Professional Counseling” and "18 VAC 115 5 Bedford Palmer II, Ph.D., Saint Mary's College of California  8/31/18  4:05 pm
Regulations regarding Counselor Training LaVerne Berkel, University of Missouri - Kansas City  8/31/18  3:26 pm
Opposed Heather Noble, PhD, Avila University  8/31/18  2:44 pm
Opposed Anthony Isacco,, PhD, Chatham University  8/31/18  2:14 pm
Oppose CACREP exclusionary supervisor licensure requirements Carla Prieto  8/31/18  12:52 pm
Opposed Pamela Foley, Ph.D., Seton Hall University  8/31/18  11:37 am
CACREP Loyola University Maryland  8/31/18  10:19 am
Opposed Daniel Walinsky  8/31/18  10:03 am
Opposing the Unnecessary Restriction of Counseling Residents' Supervisors Dr. Joseph Hammer, University of Kentucky  8/31/18  8:51 am
Oppose CACREP's attempt to monopolize Michael V. Ellis, Ph.D.  8/30/18  11:22 pm
Oppose Bryan S. K. Kim, Ph.D.  8/30/18  9:18 pm
Opposed Mary Jo Loughran, Chatham University  8/30/18  6:25 pm
Oppose Chris Hall, LGPC, Thrive Behavioral Health  8/30/18  5:09 pm
Uphold inclusive supervision requirements and oppose CACREP only regulations Arpana Inman  8/30/18  1:39 pm
Opposed Darlene Brannigan-Smith, Provost, University of Baltimore  8/30/18  1:32 pm
Opposed efforts to restrict licensure Amy Reynolds, University at Buffalo  8/30/18  12:45 pm
oppose Megan Foley Nicpon  8/30/18  12:33 pm
Opposed Sarah Miles, Student, University of Baltimore  8/30/18  12:18 pm
Opposed Sam Daniel, Private Practice  8/30/18  11:20 am
OPPOSED Meghan Powers  8/30/18  11:03 am
Opposed to the CACREP attempt to monopolize Debra Mollen  8/30/18  10:51 am
OPPOSED Sarah Rasch  8/29/18  9:49 pm
OPPOSED to objective to restrict counseling licensure to CACREP-only programs El Schoepf  8/29/18  6:13 pm
opposed David Swain  8/29/18  11:35 am

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