As a member of the community that trains licensed professional counselors (LPC), I am writing in response to a Notice of Intended Regulatory Action in Virginia. Based on my belief in multiple paths to licensure as an LPC, I strongly oppose any regulatory change in Virginia that would limit LPC licensure to graduates of master’s programs accredited by the Council on Accreditation of Counseling and Related Educational Programs (CACREP). My stance is neither anti-CACREP nor is it anti-accreditation. Rather, the field benefits from graduates of diverse programs, benefits from multiple paths to licensure, and benefits from inclusivity of graduates from programs accredited by CACREP as well programs that are not affiliated with CACREP. My perspective on the proposed regulatory change is shaped by the following rationale:

1. The role of the licensing board is to protect the citizens of Virginia through the regulation of licensure, and not accreditation. To cede the power of setting educational requirements that meet the needs of Virginians to a single, out-of-state accrediting agency does not protect the citizens of Virginia. Further, doing so may step beyond the charge of the counseling board.

2. There is no evidence to suggest that graduates of CACREP programs are more effective or more ethical providers, and commonly cited evidence to the contrary is methodologically unsound.

3. Counseling programs in Virginia that are not affiliated with CACREP are renowned. For example, in 2013, the counseling program at George Mason University – a program that is not affiliated with CACREP – was awarded the Outstanding Master’s Program award by the Southern Association for Counselor Education and Supervision.

4. The proposed regulatory change would unnecessarily restrict trade of LPCs in Virginia and LPCs considering a move to Virginia. This includes LPCs from neighboring states that do not have a similar restrictive policy.

5. There are other paths to accreditation of counseling programs. For example, the Masters in Psychology and Counseling Accreditation Council (MPCAC) accredits counseling programs and requires that programs meet a standard that meets (and in some domains exceeds) the rigor of CACREP standards.

6. Given the needs of the Commonwealth, more service providers – rather than fewer service providers are needed. For example, according to the National Association for Mental Illness (NAMI), only 19% of Virginians with serious mental illness receive services from Virginia’s public mental health system. And, as of 2013, Virginia had 47 federally designated mental health care professional shortage areas (Signer, 2014). Addressing this shortage requires that Virginia protect and support valuable counselor training programs – rather than close them due to the administrative and financial limitations of achieving CACREP accreditation.

I urge the Commonwealth of Virginia NOT to approve this change in regulation. Rather, I strongly believe that Virginians will be best served by a diverse body of LPCs, and not only those with degrees from programs affiliated with CACREP. 

Sincerely yours,

Tim Balke, Ph.D.

Director, MA and Certificate Programs

Graduate School of Professional Psychology

College of Education, Leadership, and Counseling

University of St. Thomas

1000 LaSalle Avenue

MOH 217

Minneapolis, MN 55403

(651) 962-4641