I am strongly opposed to this legislation. I have served the Commonwealth for many years as a licensed clinical psychologist, professor at VCU, and at one point, Chair of the Mental Health Planning Council of Virginia. I have been a faculty member in the PhD Counseling Psychology program (APA-accredited), Director of Training for the Program, and Chair of the entire Department of Psychology. Counseling Psychology at VCU trains competent master's degree students and it is not CACREP-accredited. I would match our students against those of any CACREP program in the country. The legislation under consideration (a) restricts trade (by denying well-trained MS psychologists to practice and placing an unfair burden of proof on them relative to those in CACREP programs), especially if no alternative is provided, (b) restricts trade by making it difficult for people moving to VA without CACREP credentials to get a job or places an unfair burden in making them justify their program differentially from those in CACREP programs, and (c) restricts trade in the employment of psychologists, who will not , by CACREP fiat, be allowed to be employed as faculty in CACREP programs in spite of having APA-accredited PhDs. The result of these restrictions on trade, even though not intended, would be to restrict access of patients to the mental health treatment they need and deserve. As a former Chair of the Mental Health Planning Council, I know that this is not something that mental health providers or patients or advocates of patients want. I believe this legislation is simply a result of the squabble between the American Psychological Association, which does not accredit master's programs and the CACREP consortium. But whereas master's programs cannot meet the rigorous standards of PhD education and training, the APA-accredited doctoral training programs that require a master's degree en route meet the same training standards of any CACREP program.

It is encumbent on the commonwealth to provide a reasonable alternative to CACREP-only approval. I would suggest that CACREP or graduating with at least a master's in an APA-accredited program should be acceptable for licensure and, if neither qualification is met, then the licensure candidate should be able to justify on a course-by-course, practicum-by-practicum and post-degree supervision equivalence.