The board appears to me to be continuing a headlong charge into a major licensure change despite significant opposition from the field, and, since the regulation change was first drafted, which now conflicts with a more recent, broader position statement by the American Counseling Association. 

The board held an education summit last year about this, inviting CACREP representatives to present their position to educators, but not including representatives from any other accrediting bodies to offer their positions.  I would estimate minority support among educators for the statute as written, partly due to the extent of the current field that will be excluded from future licensure, and partly due to the problematic CACREP requirements that allow only doctoral CACREP graduates to be considered core faculty in CACREP programs.  And clearly the submitted comments in this town hall page are overwhelmingly opposed.

The board includes some members who perhaps rightfully should consider recusing themselves from voting on this regulation due to individual CACREP ties or positions in universities with programs already CACREP-accredited, whose enrollment and stature stand to benefit from the regulatory change, creating a likely or at least perceived conflict of interest.  Others on the board may be unaware of the seeming steamrolling of the field and misrepresentions of legislative efforts by CACREP staff (who seem to have been clearly revealed in leaked internal documents to be influencing the earlier IOM decision that provides a basis for the current Virginia action, despite their public claims to the contrary). 

The tide nationally is now shifting away from the CACREP-only standard for counseling in military environments, which was posed as one of the main purposes of the initial draft (to prevent two tiers of LPCs in Virginia, one that could serve in TRICARE and veterans and military organizations and one that could not).  There is no substantive empirical data supporting the need or benefit of this change for Virginia (CACREP offered some very limited and non-representative data in support of itself, but other published studies contradict it).  The only coherent support I can find for it is an experintial belief among some that CACREP-accredited programs are better than programs not accredited by CACREP, and to mimic psychology and social work, two fields with very different histories of development, but which are seem by some as having greater professional cache than counseling.  In my opinion, the counseling field has been served well by a "big tent" approach, allowing it to be vital and broad in a way that psychology and social work aren't, and this change will effectively narrow the field of counseling in Virginia to a particular subset of the earlier range of practicing counselors.  The grandparenting clause is meant to lessen the blow of the regulatory change and limit opposition based on self-interest, but the opposition stated in other comments does not appear to be largely self-interested, and so still persists.

CACREP is a good standard, overall, despite some problems.  However, if this initiative passes, it is being foisted upon the field as a sole qualifying creiterion by vested decision-makers, rather than through the lengthier, messier process of consensus development among practicing counselors and educators that may modify the rigidity of the proposed regulation.  At a minimum, I believe the board should revise the proposed change to be consistent with the less restrictive current American Counseling Association position, which does not require CACREP accredition as a clinical mental health counseling program for TRICARE reimbursement.  For reference, please see:

http://www.counseling.org/news/updates/2015/05/12/more-lpcs-to-be-included-under-new-tricare-language