The program at Boston University’s School of Education that I direct educates Master’s level mental health counselors. Our program is national in scope with our graduates practicing throughout the United States. I am writing in response to a Notice of Intended Regulatory Action in Virginia. Based on my belief in multiple paths to licensure as a Licensed Professional Counselor (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. There are many fine programs across the country, whose universities are regionally accredited, that have been training licensed mental health counselors for decades in accordance with state licensure regulations that choose not to pursue CACREP accreditation. 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. 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.
2. 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.
3. 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.
4. 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.
5. Several professions, including nursing, have two or more recognized accrediting authorities.  With variety comes a greater opportunity for a diversity of training to ensure a flexible and responsive counseling workforce for the unique needs of individual clients. 
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.

Please oppose this petition and work to make Virginia Counseling licensure inclusive for all counselors who meet the educational coursework completion standards, national testing and experience requirements for counseling. 

Sincerely yours,

David P. McAllister, MS, LMHC, MaCCS
Director - Ed.M. in Counseling Program
Boston University School of Education