Dear Governor McAuliffe,

On behalf of the members of the Kentucky Psychological Association (KPA), the KPA Board of Directors is urging you NOT to approve the proposed licensing regulations that would limit counselor licensure only to individuals graduating from CACREP-accredited programs.  

The CACREP-only licensure restriction has already occurred in Kentucky and we are now beginning to see the consequences. On the surface, ensuring that programs are accredited is a worthwhile endeavor. The reality in this case, however, is that when you exclude established graduate psychology programs in quality universities that provide excellent training it only serves to lessen the talent pool in a state that desperately needs good, qualified mental health providers. Talent is diminished in two ways: 1) fewer applicants to training programs in the state and 2) fewer individuals who are now licensable to work in Master’s-level positions.  These practitioners are typically the backbone of providing mental health services, particularly in rural or less populated areas. Kentucky has made this mistake and we urge you to not allow Virginia to follow suit.

Psychology programs that offer a clinical or counseling psychology master’s degree are not eligible for CACREP-accreditation even though the coursework and requirements are similar. This is a “turf issue” with monetary consequences, rather than one regarding competency and quality. In Kentucky, the Licensed Professional Counselor Board has touted that CACREP accreditation ensures that an applicant has a “counseling” identity. This, in our opinion, is an overreach. For example, counseling psychologists have historically held dual identities (e.g., maintaining membership both with the American Counseling Association and with the American Psychological Association).  CACREP should not be permitted to unilaterally define what “counseling” is with regard to a professional identity held by both counselors and counseling psychologists.  

The best method of assuring Virginians access to quality mental health care is to maintain the present regulations, which allow for multiple paths toward licensure for professional counselors, including counselor education programs and psychology programs.   

The people of Virginia, as well as in Kentucky, need the strong consumer protections provided in the current regulations. We urge you to take action to stop this proposal, thus ensuring that Virginians will continue to have access to quality mental health care, with no restrictions imposed by an organization with no oversight or accountability. 

Thank you for your consideration,

Best regards,

Lisa Willner, Ph.D.

Executive Director, Kentucky Psychological Association