Dear Governor Terri McAuliffe and the Virginia Board of Counseling,

I oppose the regulatory requirement for individuals seeking licensure as professional counselors in the state of Virginia be required to complete education approved by CACREP or its affiliate CORE. I believe that professional identity & portability of licensure is important, however this measure would significantly limit the amount of qualified individuals seeking licensure and/or approved for reciprocity for licensure in the state of Virginia. I support an inclusive model, and I believe the current laws governing counseling/licensure in the state of Virginia currently provide rigorous standards for individuals seeking licensure. 

Currently, there is no empirical evidence that supports requiring CACREP improves the quality of counselors or efficacy of practice between counselors that have CACREP education and those that have non-CACREP education. In addition, there is no empirical evidence that supports that counselors from CACREP programs are better prepared to serve as professional counselors. There is lack of empirical evidence to support that CACREP protects the health and safety of Virginia citizens. There is no evidence to support improved outcomes for citizens seeking counseling services from counselors from CACREP/CORE programs.

Additional concerns:

The proposed regulatory change could adversely impact individuals seeking licensure as professional counselors from the Board for neighboring states.

Individuals who were licensed and attended counseling programs prior to the development of CACREP/CORE may be adversely affected.

Thank you for reviewing and considering my comments.

Respectfully submitted,

Kimberly Nichols, M.A., Resident in Counseling