I strongly OPPOSE the CACREP-only regulations because I am one of the people whose career was harmed in 2009 when the Virginia Licensing Board changed the eligibility requirements for the LPC. I want to emphasize that I was born and raised in Virginia, earned both my undergraduate and graduate degrees from Virginia Universities (Virginia Wesleyan and Radford), had an assistantship from Radford University, completed a year-long clinical internship at a hospital in Virginia (Lewis Gale), and then had my application to proceed with licensure denied by the Virginia Licensing Board and was then forced to take my education and training to another state (Georgia) where I am now a Licensed Professional Counselor.  It's disheartening that despite my education, training, and experience, it appears that I will not be able to return to Virginia and practice as a Master's level clinician in the state where I was born and educated and where I would have liked to have continued to reside to be near my family.

My experience of being denied the opportunity to proceed with licensure while I lived in Virginia has caused significant unnecessary hardship for me - relocating to another state was costly and time-consuming. It also has had a negative impact on my career, delaying my professional counseling licensure by several years (which has, in turn, affected my salary and position level).

I graduated from Radford University with a Master of Science degree in Clinical Psychology in May of 2009. One of the primary goals of this program (and the reason I chose to attend it) was due to its reputation of being an outstanding program to train master’s level mental health professionals who successfully were able to go on and receive licensure as a Professional Counselor in Virginia. Prior to 2009, students in Radford University’s graduate program in psychology had never had difficulty applying for, or achieving licensure. But in 2009 the Licensing Board apparently decided to adopt CACREP guidelines for faculty credentials to evaluate applicants (please note: the Board did not officially state that they had adopted CACREP guidelines, although it seems that the reasons stated when they rejected my application were directly in line with CACREP guidelines). As best I understand it, in 2009, the Board began to deny students the opportunity to proceed with licensure because they had been trained by psychologists in a psychology program rather than by counselors in a counselor education program.  The changes they informally implemented in 2009 have already had a detrimental impact by excluding graduates from master’s degree programs in psychology from LPC-eligibility. The proposed CACREP-only regulations now seek to formally and explicitly exclude graduates from all non-CACREP accredited programs (regardless of whether they are in psychology or counselor education) and will have a detrimental impact on a far greater number of students as well as universities. Reducing the number of qualified mental health professionals by requiring CACREP accreditation will have significant negative consequences for mental health services in Virginia, so I urge you to OPPOSE the proposed regulations.

 My experience attempting to obtain an LPC in Virginia is outlined below:

I was shocked when the Virginia Board of Licensing informed me that my application to be licensed as a professional counselor did not meet board requirements. Here is the exact quote from the letter I received:

 “Your application to proceed with licensure as a Licensed Professional Counselor did not meet the requirements set forth in regulation 18VAC115-20-49, specifically because:

1) There was insufficient emphasis on counselor preparation in the academic curriculum and program description.

2) There was a clear intent to prepare students to become clinical psychologists rather than counselors”.

Given that that Board denied my application to proceed with licensure and made it clear that I would not be LPC eligible in Virginia, I ultimately moved to Georgia where I had no trouble earning my LPC. Georgia does not discriminate between students trained in master’s level psychology programs and those trained by counselor educators. Any philosophical distinction between the two professions that may exist has not prevented me from pursuing counseling licensure in Georgia. Georgia also does not require CACREP accreditation to be eligible for the LPC. Rather, Georgia evaluates applicants based on their qualifications, and not on whether they approach counseling from the “professional identity” of someone trained in psychology or someone trained in counselor education. A thorough vetting of the coursework and faculty from the degree I earned in Virginia by the licensing board in my current state resulted in my being allowed to finally become licensed as a Professional Counselor.

What is most disturbing is that I know individuals who graduated from Radford University’s Clinical Psychology program prior to 2009 were able to become licensed as Professional Counselors in Virginia. The program did not change and was not different for individuals who graduated prior to 2009 from when I graduated in 2009. If the coursework and clinical program were the same, why were some allowed to become licensed as counselors in the state of Virginia and others were not?  It was not because the program suddenly started churning out unqualified graduates. It seems like some other external variable changed, namely the Licensing Board’s criteria (formal or informal) for determining LPC eligibility.  I submit that if graduates from Radford University’s master’s degree in Clinical Psychology program after 2009 we were unqualified, we would not have been able to go to other states, pass the required competency exam, participate in appropriate supervision and be able to be licensed and practice as Licensed Professional Counselors. I further submit that Virginia should return to the standards they used prior to 2009 that did not discriminate against individuals trained by psychologists to become master’s level mental health professionals. Additionally, requiring CACREP accreditation would make this situation worse. I suggest that the Board should use criteria for evaluating competence in the way that the majority of other states do (including  Georgia) and not rely on an outside accrediting agency such as CACREP which would exclude a significant number of qualified mental health professionals from LPC eligibility.

I STRONGLY OPPOSE proposed legislation that would limit LPC-eligibility in the state of Virginia to individuals who have graduated from a CACREP-accredited program. This is not just about Radford University or other master’s level psychology programs in the Virginia. This is also about graduates from virtually all master’s level graduate programs in psychology in the country. If the proposed regulations are passed, the career disrupting experience that I had with licensure in Virginia will have a far greater negative impact because it will affect hundreds of graduates from psychology programs around the country. The availability of fewer qualified mental health professionals is detrimental for individuals with mental health needs at a time when providing mental health treatment is even more vital, especially to underserved populations. Does Virginia want our highly trained graduates from non-CACREP accredited programs to do as I did and be forced to leave Virginia to become licensed in another state? Likewise, does Virginia want to prevent highly trained graduates from non-CACREP accredited programs from other states from relocating to Virginia because they will not be license-eligible? If not, I urge you to OPPOSE the CACREP-only proposal.

Respectfully,

Deborah Pérez-López, M.S., LPC