Dear Governor McAuliffe, 

I am writing to you today to express my concerns about the upcoming regulation 18 VAC 115-20 concerning the practice of Counseling in Virginia and the requirement that only CACREP accredited degree graduates are eligible to become a Licensed Professional Counselor in the Commonwealth. I am greatly OPPOSED to this regulation and I urge you to OPPOSE this proposed regulation as it:

• Decreases the licensure candidate pool in a field of study that is already crippled in many parts of the country, to include Virginia;
• Directly impacts Virginia’s ability to properly care for the high density of Veterans in the Commonwealth; and 
• Conveys that Virginia is engaging in program endorsement versus focusing on increasing candidate competency.

In writing to you today, my hope is to provide you with evidence based upon my own personal experience regarding the history of this debate, offer statistical support relevant to the mental health welfare of residents of Virginia and provide a closing argument detailing some costs, additional considerations and my concerns as a voting resident of the Commonwealth of Virginia. 

Decreases the licensure candidate pool – The Virginia licensing board has been slowly restricting the graduate degree programs required to obtain a LPC in the state. This debate has been a long one and has greatly impacted the career of many graduates including my own. With these increasing regulations others, like me, who have received substantial academic training and clinical experience, are limited in terms of job prospects in the Commonwealth of Virginia. Master's level psychology students are being limited to careers in case management,  working as part of a larger facility or hospital program, or providing support services to clinical teams. It is true that these positions are critical to the overall mission of a clinical team; however, it is wasteful to have these master's level graduates who are fully capable of providing clinical care in the form of psychotherapy or group facilitation when there is a greater need for clinicians on the ground providing services. Graduates are forced out of the state to others that are willing to recognize their potential, academic training, and compassion to assist others. I also once considered moving west where there were more available job prospects. 

As a child of a military family, it was an easy decision for me to pursue a career in serving our nation’s veterans. I began my academic college career at the age of 16. I gravitated to the field of psychology due to its balance of both research and clinical practice in its training programs. When I made this decision the lines delineating the various related mental health fields were more defined; though, those lines were beginning to blur. I felt that psychology was the best fit for me and the intent to pursuing my doctoral degree. Rather than pursing my doctorate immediately after my bachelor’s I chose to obtain my master’s in a clinical-counseling psychology program so that I could obtain more life experience before moving on with my academic career. 

In 2013 I graduated from my master’s program with a 4.0 grade point average, with more than 500 internship hours (individual psychotherapy, biopsychosocial training, and group facilitation) and research experience. Despite my high academic performance, clinical hours, and undergraduate clinical internship experience it took me almost six months post-graduation before I received a job in the field of mental health at a residential inpatient facility. This job was part-time with no available healthcare or sick leave benefits. I worked in non-field specific positions and trades until I received this position and I continued to work off and on to supplement my income. I often worked 50 to 60 hour weeks in order to live paycheck to paycheck while I paid off my student loans. 

Though I finally had a job in my field I was unable to work at my highest potential because of the limitations of my eligibility for licensure and thus was forced resumed my job search. Despite loving my job as well as receiving one of the highest performance appraisals at the facility and receiving glowing compliments from the Joint Commission Auditor about the development of my department since my hire, my hours were cut by the facility because I was “non-billable,” not eligible for licensure supervision, and not able to bring in additional funds to the facility. 

Around 2015, I received a verbal job offer as a full time employee. A full written offer was contingent upon the agency’s lawyers reviewing the new regulations passed by the Commonwealth of Virginia about the qualifications to be a mental health responder/provider  in the state. Based on these new regulations, I was disqualified even though I was their first choice candidate. Despite my tumultuous career post-graduation, I eventually found a position in research and am currently working in mental health research for our nation’s veterans. In addition, I have decided to return to academia part-time to further my education as I am not licensure eligible in this state. 

Virginia’s ability to properly care for the high density of Veterans –  As a professional working with veterans, and as someone who was raised in a military family, it is incumbent upon me to at least mention the impact of this proposed regulation on the overall mental welfare of our Veterans. The Nation is currently in a mental health crisis. The need for mental health services is ever increasing with a limited number of providers available to meet this demand. Those individuals who have dedicated their lives to protecting our country are at even a great risk and in need of mental health services. Based on research that has been promoted by national awareness campaigns, it is common knowledge that roughly 20 veterans commit suicide every single day in the United States that means a rough estimate of 275 veterans commit every year in Virginia. That is based on a US Census Bureau 2014 Veteran population of 19.3 million and a 2014 Virginia Veteran population of 726,470. With Virginia and surrounding states having a high density of the nation's veteran population we should be focused on how we can increase those eligible for licensure to provide those veterans the care they deserve. By restricting the number of eligible practitioners to provide compassionate mental health services to not only our nation veterans but to every resident of the state we are hindering progress and adding to this growing crisis. (Please note that all statistics were gathered online from public access information from the United States Census Bureau and SAMHSA.)

Virginia engaging in Program Endorsement versus Candidate Competency – Previously there were specific foci between the diverse mental health fields; however, today they are more ambiguous and you can often find licensed clinical social workers practicing as counselors or as psych technicians on research teams, counselors diagnosing patients, and psychology majors moving more into clinical practice. Training amongst all these fields has become more integrated and they tend to overlap more than they differ. If this proposed regulation is a matter competency then I implore that evidence be provided to support that argument. In a simple google search one can find that all of these fields provide training in diagnostics, therapeutic techniques, theory, individual counseling, group facilitation and above all most programs require clinical internships and practicums. If the concern of this regulation is about competency to provide quality mental healthcare then the mandatory 2000 hours of supervision post-graduation and successful completion of the state-board should assist to prevent unqualified individuals from slipping through the system and becoming licensed professional counselors. And if the concern is about competency then there are other ways to ensure that unqualified personnel do not obtain licensure while still allowing diversity amongst master's level mental health degree program.  Why is the state focusing on our differences and denying fellow Virginia residents compassionate and highly trained professionals when we live in a day and age when we frequently hear about increased wait times between appointments, egregious caseloads per provider (e.g., 10 patients a day), and significant levels of provider burn-out and turn-over? If the proposed regulation is accepted, as a Virginia resident I want to know how the Commonwealth of Virginia intends to address the following: 1) the student debt of those recently graduated from non-CACREP accredited institutions (student loan debt is another growing concern and debate in our nation that I will not address in this letter), 2) the reduction in available competent and compassionate mental health providers, 3) and how the state intends to meet the growing demand mental health services?

Now that I have detailed my professional struggle as a graduate from a non-CACREP accredited institution in Virginia, my experiences as a working professional in non-mental health trades, and as someone serving our nations Veterans I would like to close my letter with some concerns that I have as a tax paying, law-abiding, and voting resident of the Commonwealth of Virginia. The responsibility of the State and its elected officials is to intercede by proposing regulations and minimal standards of competency of a licensed trade for the protection and safety of its citizens, especially when it concerns healthcare. It is NOT the responsibility of the state to participate in professional biases, academic/professional debates, nor to endorse one particular program over another.  This regulation would be a VIOLATION of political oversight as it WOULD BE an endorsement of a specific program as the standard of care over another. With that said, I hope this debate is finally concluded in the near future, regardless of the outcome. This debate in various ways has been prolonged for years. It has consumed the time, energy, and finances of those involved. As a Virginia resident I am disheartened that my elected representatives choose to overstep their political office and seek to prioritize THIS issue when we currently are in a mental health crisis with a deficit of providers. While no issue should be considered insignificant when it concerns our state it is the responsibility of our representatives to prioritize the issues to be addressed, maintain appropriate professional and financial boundaries when it concerns issues of the state, and to be the voice of its citizens- to make decisions in the BEST interest of EVERY Virginian. 

In closing, Governor McAuliffe, I hope that you take into consideration the comments of others and me but also to consider the impact that this regulation may have on those who may not be able to provide their voice in this debate. I implore you to OPPOSE this regulation that would limit the eligibility for a Licensed Professional Counselor in the Commonwealth of Virginia to only those graduates from a CACREP accredited degree program. If you have any questions or concerns or would like additional information about the statistics or information described, please feel free to contact me. 

Respectfully,

Natalie Kiddie

Radford University Alumni, 2013