I am a full professor (22 years of service) in the graduate program in counseling at Arcadia University in Glenside, PA. In 2013, our graduate program in counseling won the Pennsylvania Counseling Association (PCA) Outstanding Counselor Education Award. Several of our students have won awards from PCA: two have won the Graduate Student Leadership Initiative Award and two have won the PCA Graduate Student of the Year Award. Since 2005, six of our students have won the Montgomery County Counseling Association (MCCA) Outstanding Graduate Student Award. One of our students won the American Counseling Association (ACA) Conference Student Scholarship, and one has won the Scholarship for Graduate Students in Guidance and Counseling from the Pennsylvania School Counseling Association. We abide by and train our students in the American Counseling Association ethical standards and we train our students in evidence-based, multiculturally attentive, and trauma informed approaches to counseling and psychotherapy, all of which are the standards in the field. Additionally, Arcadia University is approved by the National Board for Certified Counselors as a site for administration of the National Counselor Examination for Licensure and Certification.

Yet we are accredited by the Masters in Psychology and Counseling Accreditation Council (MPCAC), not CACREP. Our program meets all of the same standards under our MPCAC accreditation as are required by CACREP, except that MPCAC does not force programs to only hire faculty with degrees in Counselor Education. We can hire any applicant with a doctoral degree in counseling-related fields so long as they meet our high ethical and professional standards. To be clear, however, this does not at all affect the identity of our students as professional counselors. Many of our students perform so well in internship that they are offered counseling jobs at the end of their internship year and they all strongly identify as professional counselors as a result of their training in our program.

I make this last point about professional identity only because the Virginia Board has posted a NOIRA (Notice of Intended Regulatory Action) that includes this issue.  However, this actually has nothing to do with protection of the public good, professional competence, or public safety, which, in my understanding, are the key functions of a professional board of licensure. Professional competence is the important issue in licensure, not professional identity. By putting restraints on who can accredit counseling programs, the Virginia Board would only be harming the public by restraining the practice of innumerable well-trained and competent counselors and reducing public access to much needed mental health counseling services.

I urge you NOT to approve this proposal (Regulations Governing the Practice of Professional Counseling 18 VAC 115 – 20); ensure that Virginia’s citizens in need of mental health counseling can rely on the Board to license counselors by competence, NOT by accreditation body.