I am gravely concerned about the elitism that the Regulations Governing the Practice of Professional Counseling [18 VAC 115 ? 20] will engender for the state of VA, thereby deterring citizens of the state from receiving still excellent services from still excellent mental health counselors who aren't able to attend CACREP-accredited (or CORE) schools.

I have been a mental health provider for nearly 25 years to low-income, underserved, and marginalized people in three different states, and my ability to engage in high quality, outcomes-driven care for them has nothing to do with my not having attended CACREP-accredited schools. I nonetheless received a fully CACREP-related education from my schools (I have a PhD in counseling psychology) and, because of my interests, passions, and proclivities to deeply care about the people I serve, it's my perception as well as my data-driven understanding that the work I engage in--supervision of a seven-staff mobile treatment program that provides mental health services to high-risk, behaviorally disordered children and familiies in their homes, schools, and neighborhoods--is entirely oriented to provide the best-quality treatment, case management, and advocacy for those children and families. Our treatment outcomes a repeatedly high, resulting in substantively decreased misbehavior; improved school attendance and performance; reduced hospitalizations; enhanced family functioning; increased access to resources for well-being; and systems changes that assist Social Services, schools, Juvenile Justice, and other community players to be more caring and justice-oriented for the children and families we serve.

Certainly all mental health counselors in VA should be required to demonstrate their learning by taking the NCE as indicative that they have learned the basics to engage in this profession--and those are only the basics--but that standard requires no need for CACREP accreditation to demonstrate the value of counseling schools to educate appropriately.

Moreover, you must be are aware that all structures and systems fall on a curve, resulting in some CACREP-accredited schools being better than others dependent on myriad factors. This portends that many of the non-accredited schools will prove to provide better educational outcomes than some of the lower CACREP schools, of course, but more so once you abide by hierarchies of the nature your rule change proposes you buy into marginalizing those individuals or schools who don't as easily have access to the resources necessary to participate in the likes of the CACREP-accredited.

Thus, this very rule smacks of a higher standard that doesn't necessarily result in higher outcomes except on the surface while relegating the potential of many more who can't quite meet it to demonstrate that they, in fact, are as high as the standard even when they don't have access to it. This is, to be sure, what we do with people who have low-income: We ensure they don't have access to the resources they need for healthy human development, and yet many of them still find the way to demonstrate their abilities to be just as resourceful to society as those who do have resources from the outset.

By enlisting the CACREP standard as noted below, you will not only be deterring many people from becoming essential, top-notch mental health counselors no matter from whence they have come in the hierarchy. And, additionally, you will be limiting access to counseling services around the state of VA to those who don't have easy access to vital mental heatlh care.

Ultimately, please rethink your strategy to care about the citizens of VA and choose NO to the following:

"In response to a petition for rulemaking, the Board is publishing a Notice of Intended Regulatory Action to add a requirement for all counseling programs leading to a license as a professional counselor to be clinically-focused and accredited by the Council for Accreditation of Counseling and Related Educational Programs (CACREP) or an approved affiliate, such as the Council on Rehabilitation Education (CORE). This would be a phased-in requirement, allowing seven years from the effective date for students to complete their education in a non-CACREP program and for programs to achieve accreditation standards."

Thank you.