Dear Governor McAuliffe and the Virginia Board of Counseling, Dr. Doyle, Chairperson:

I am writing to urge you to reject the proposed regulations, 18 VAC 115 ? 20, which would restrict initial counselor licensure in the Commonwealth of Virginia to graduates of counseling programs accredited by the Council for Accreditation of Counseling & Related Educational Programs (CACREP).

My primary reason is summarized in the conclusion of the Virginia Department of Planning and Budget Economic Impact Analysis which reads, “Given the significant costs associated with requiring CACREP accreditation, the uneven and uncertain benefits of doing so and the lack of empirical evidence that this proposal is necessary to protect the health and safety of Virginians, the costs of this proposed change appear to outweigh the benefits” (p. 14). Building on this excellent analysis, I argue the costs clearly outweigh the benefits and that the primary benefits of this and similar proposals are to CACREP, CACREP-accredited programs, including students and alumni, and people with doctoral degrees in counselor education and supervision, who according to CACREP (2009, 2016) standards are the only persons qualified to serve as core faculty in CACREP-accredited programs.

In addition to the monetary costs associated with pursuing and maintaining CACREP accreditation detailed in the aforementioned Economic Impact Analysis, this regulation would force George Mason University, one of the most highly respected counselor preparation programs in the US and internationally, to change their curriculum, organizational structure, and staffing - or close. This proposal would also require programs currently accredited by CACREP in Virginia to maintain that accreditation, regardless of future accreditation requirements, and foreclose the opening of new training programs in the Commonwealth. This proposed regulation would also unnecessarily restrict the type of training and core faculty credentials and reduce the number of potential counselors seeking initial licensure in Virginia at a time when more qualified licensed counselors are needed.

Founded in 1981, CACREP currently accredits less than half of the master’s training programs in counseling nationally. Most of these programs are geographically concentrated, with some states having few or no programs accredited by CACREP. Some of these programs are not eligible for CACREP accreditation for reasons unrelated to quality, others have chosen not to pursue this accreditation. As a long-time counselor, counselor educator, and past-chair of the NJ Counseling Coalition, which successfully reversed regulations that would have made NJ the first state to restrict initial licensure to graduates of CACREP programs, it seems to me that CACREP and CACREP affiliates are the primary beneficiaries of CACREP-only licensure restrictions. By extension, this means that programs accredited by CACREP, students and alumni of these programs, and people with doctoral degrees in counselor education and supervision, the required credential for new core faculty in CACREP-accredited programs, benefit from the monopoly created by CACREP-only policies, regulations, and laws. At the same time, CACREP-only policies present clear disadvantages to people who are not affiliated with CACREP and CACREP programs - and the public. Despite this, many programs remain unaffiliated and some have chosen to become accredited by the Masters in Psychology and Counseling Accreditation Council (MPCAC). MPCAC became an option for program level accreditation in counselor education in 2010. Currently, MPCAC accredits more than 40 graduate programs, most of which meet requirements for counselor licensure across the nation. Regardless of program-level accreditation, most counselor education programs are in regionally accredited colleges and universities. Some programs are housed in colleges of education that are accredited by the Council for the Accreditation of Educator Preparation (CAEP) and some share curriculum and faculty in departments with other accredited master’s and doctoral programs.

If this proposal is adopted, the majority of new counselors trained outside Virginia would be ineligible for initial licensure in Virginia. As just one example, please consider the impact this proposed regulation would have on military families and others who would benefit from returning or relocating to Virginia before they have attained initial licensure - and who would, in turn, while working towards and post-licensure, benefit Virginia residents. These people cannot wait for portability plans.

Furthermore, as detailed in the Economic Impact Analysis, there is no empirical evidence that graduates of programs accredited by CACREP are more ethical or effective than their peers from similar programs that are not accredited by CACREP. All candidates for licensure in Virginia (and indeed all 50 states) must have earned a master’s degree with coursework in specific areas, passed a national examination, and completed supervised experience. This is the time-honored way of demonstrating competency in counseling that the Commonwealth of Virginia has effectively employed for more than 40 years.

In closing, I urge you not to cede your responsibility to protect the public to an independent organization with no public oversight or accountability, to consider the significant costs of this proposal,  and to reject the proposed regulations, 18 VAC 115-20.

Thank you for your consideration,

Peggy Brady-Amoon, PhD, LPC

Seton Hall University

Advocacy Chair, Alliance for Professional Counselors (www.apccounseloralliance.org)

Immediate Past Chair, NJ Counseling Coalition (2009-2015)