I am writing to strongly OPPOSE the proposed CACREP-only regulations. Below I submit a list of negative consequences that adoption of the CACREP-only regulation would likely have for citizens of the Commonwealth, for graduates from non-CACREP accredited programs, and for Universities and Mental Health Agencies. I do not claim to know or even understand all of the issues and implications of the proposed regulations, so this is in no way meant to be an exhaustive list. Rather, this is a list of concerns I have compiled from a variety of sources.

I ask you to pay particular attention to how changes instituted by the Virginia Board of Counseling in 2009 regarding LPC eligibility have systematically excluded graduates from Radford University’s Clinical-Counseling Psychology program from being license-eligible in Virginia. Not only has this seriously disrupted the careers of our alumni, it has also placed the viability of the program in jeopardy. Please refer to Ann Elliott’s extensive discussion of these issues in her posting on the public opinion forum (dated 7.14.17). In short, let me reiterate that the changes implemented by the Virginia Board of Counseling in 2009 regarding LPC-eligibility are consistent with the exclusionary criteria advocated by CACREP, which refuse to acknowledge that graduates from master’s level psychology programs meet the definition of “counselor”, and thus denies these graduates the opportunity to earn the LPC in Virginia.  The current proposed regulation is an attempt to formalize those exclusionary criteria that have been informally applied to applicants for licensure in Virginia since 2009.

Thus, I urge you to do two things. First, OPPOSE the proposed CACREP-only regulations. Second, find a way to ensure that the Virginia Board of Counseling no longer prohibits graduates from master’s level psychology programs from being eligible for the LPC. The Board of Counseling needs to be willing to grant LPC licensure to all qualified mental health professionals, including those trained in psychology.

Negative consequences likely to result if the proposed CACREP-only regulation is adopted

For Citizens of the Commonwealth

• There is a documented shortage of mental health providers in Virginia.

• According to the Economic Impact Analysis regarding this proposed CACREP-only legislation, “since fewer than 20% of colleges and universities with counseling programs nationwide appear to have CACREP approval, this proposed change has the potential to shrink the pool of professional counselors licensed in other states who would be eligible for licensure in Virginia.”

• Reducing the number of qualified mental health professionals may be particularly detrimental to clients in rural settings and areas traditionally underserved.

• Reducing the number of qualified mental health professionals will likely decrease the quality of mental health services, due to understaffing and limited time and resources of professionals.

• The proposed regulation would severely impact graduates from non-CACREP accredited Universities in Virginia, including Radford University’s Clinical-Counseling Psychology Master’s degree program and George Mason’s Counselor Education program. If students graduating from these Virginia universities are not license-eligible, the proposed regulations will likely encourage professionals to leave Virginia and relocate to one of the other 46 states where they will be license-eligible.

• Additionally, the proposed regulation would prevent LPC eligibility to graduates from non-CACREP accredited Universities around the country, and would discourage relocation to Virginia by otherwise qualified mental health professionals.

• Again, the primary conclusion by the Virginia Department of Planning and Budget Economic Impact Analysis regarding the proposed regulations was as follows: “Costs will likely outweigh benefits for this proposed change” (page 2).

   

For Graduates from non-CACREP accredited programs seeking master’s level licensure in Virginia

• Students who graduated from a non-CACREP accredited program in Virginia or any other state, will no longer be eligible for the LPC in Virginia. This proposal would prevent the majority of graduates from Clinical or Counseling Psychology programs in the country from becoming license eligible in Virginia.This applies to students graduating from non-CACREP accredited programs in Virginia as well as those hoping to move to Virginia. This may result in hardship in many ways.

  • Students may feel compelled to move to one of the other 46 states that does not require CACREP accreditation. Effectively, this means that otherwise qualified professionals will take their education, training, and expertise elsewhere.

  • Other students who have not yet graduated may feel compelled to transfer into a CACREP accredited program given the current Board of Counseling’s definition of “counselors” and who is qualified to earn the LPC in Virginia, which could be unnecessarily expensive and time-consuming.

  • Other students may feel compelled to return to graduate school to earn a second degree from a CACREP-accredited program. This too could be unnecessarily expensive and time-consuming. Other students may return to graduate school to earn a different degree (such as the MSW).

  • Some may feel compelled to switch career paths due to reduced professional opportunities associated with not being license eligible. Again, expensive and time-consuming.

  • Some may feel compelled to pursue a doctoral degree instead, which would be costly both in terms of time and money. Again, expensive and time-consuming.

  • The professional development of students intending to seek doctoral level degrees may be stunted by their inability to obtain licensure and gain important professional experiences between completing the master’s degree and applying to doctoral programs, resulting in fewer doctoral level practitioners (of which there is a severe shortage in the state).

  • Many will have reduced career opportunities, including ineligibility to be hired or promoted for a mental health position that requires licensure or inability to be promoted.

  • Even seasoned professionals from other states who do not graduate from CACREP accredited programs may not relocate to Virginia if they are not license-eligible.

  • Some students may opt to live in Virginia but work elsewhere, such as Washington D.C., where they are license-eligible, as one graduate from Radford University is currently doing.

For Universities in Virginia

• In the “Proposed Regulation Agency Background Document” the chart on page 7 states that only one entity in Virginia is impacted by this proposal (George Mason University). The board neglected to acknowledge concerns raised by faculty and alumni of Radford University, Norfolk State, and Virginia State that were cited in the “Town Hall Public Comment Forum Link” on a 2013 petition that also addressed issues related to CACREP accreditation (the Acceptance of Clinical-Counseling Psychology degree for licensure). http://townhall.virginia.gov/L/comments.cfm?petitionid=195).

• As discussed above, CACREP has strict faculty eligibility criteria for “core faculty” which will likely exclude the vast majority of Psychology programs in the country from being CACREP accredited, including Radford University’s Clinical-Counseling Psychology Program. This means that while Radford University can continue to trains master’s level clinicians to obtain the LPC in 46 other states, their graduates would not be eligible to practice in Virginia. This would dramatically hinder Radford’s ability to recruit high quality students and may ultimately call into question its viability altogether.

• The majority of colleges and universities nationwide with graduate programs in counseling are NOT CACREP-accredited (ONLY approximately 20% have CACREP accreditation).  Many graduates from the other 80% are LPC or LCPCs, such as those at George Mason University, and have met rigorous licensure standards in their states without requirement of CACREP accreditation. Again, the requirement of CACREP accreditation is an exception, rather than the standard in the profession.

• The proposed regulations may result in a reduced number of Virginia citizens who choose to attend graduate school at a Virginia University. Rather, they may choose to attend graduate school at an out of state university in a state where they will be LPC eligible.

• Relatedly, if the proposed regulation passes, it will likely reduce the influx of students from other states choosing to study in our universities. Why study in Virginia when they can get their degree from a state in which they will be license-eligible?

• Costs of gaining CACREP accreditation may be prohibitive for many universities without the resources to afford the application and annual CACREP costs.

• CACREP standards require that ALL counseling program concentrations be 60 credits. There is no evidence or research exists to support that 60 credit programs provide higher quality training than programs with fewer credit hours. Requiring 60 credits increases tuition and has significant impact on low income students.

• By increasing required costs to start a counseling program, this proposed change may limit the number of counseling programs that are instituted in the future.

• Doctoral Programs may lose a valuable pool of applicants if there is a reduced number of master’s level students trained in Virginia.

• Students who earn a master’s degree en route to earning their doctoral degree in Psychology will not be license eligible (this concern has been voiced by faculty at Virginia Commonwealth University).

• The reduced number of master’s degree students in psychology will cause universities to lose valuable Graduate Teaching Assistants, Graduate Teaching Fellows, and Research Assistants.

   

For Mental Health Agencies in Virginia

• Many of the negative consequences potentially associated with the proposed CACREP-only regulations cited above for the Commonwealth of Virginia are applicable for Mental Health Agencies in Virginia.

• Restricting the pool of professionals eligible to earn the LPC ultimately reduces the pool of qualified mental health workers.

• Again, given shortages of mental health professionals around the state and particularly in rural areas, mental health agencies cannot afford to be unable to hire otherwise competent and qualified professionals.

• This will prevent mental health agencies from being able to promote otherwise qualified individuals who are not licensed or license-eligible.

   

Lack of evidence that the proposed changes will improve quality of mental health services in Virginia

• To my knowledge, this is the first time in Virginia’s history that it has been proposed that license eligibility should be granted only to students who have graduated from CACREP accredited programs.

• The Board of Counseling in Virginia has successfully evaluated and granted licensure to competent applicants for licensure for many years. While such an evaluation of credentials is a time-consuming and burdensome task for the Board, the benefits of doing so far outweigh the costs of requiring graduates from CACREP accredited programs.

• As concluded in the Virginia Department of Planning and Budget Economic Impact Analysis, as well as by the large number of individuals who posted to the public opinion town hall cited above, CACREP accreditation does not assure competence.

• There is a lack of empirical evidence that CACREP graduates are better prepared or that CACREP programs are superior. There is no compelling evidence that they are more competent, have fewer ethical violations, etc.

• Rigorous licensure standards have been applied in Virginia and other states without requirement of CACREP accreditation for many years. For example, as stated in the Virginia Department of Planning and Budget Economic Impact Analysis (page 13), “under existing regulation, there are multiple requirements to ensure competence of applicants for licensure. The Board currently requires that individuals licensed as professional counselors receive an education adequate to prepare them for future practice by 1) specifying the coursework that they must complete at an accredited college or university, 2) requiring a fairly lengthy residency and 3) requiring passage of a licensure exam that measures the counseling knowledge of applicants. The requirements are located in 18VAC 115-20, sections 49, 51, 52, and 70, are not proposed for repeal as part of this action, and will remain in force. If a candidate can pass the examination for licensure, has completed the Board required education without having earned a degree from a CACREP/affiliate-accredited program, and successfully complete a 3,400-hour supervised residency, then the candidate has presumably demonstrated significant knowledge and experience. Given this, the additional value of requiring CACREP/affiliate-specific accreditation appears to be limited.”

• As seen in many of the town hall postings referenced above, many supervisors of master’s level mental health professionals in the field reported that graduates from clinical or counseling psychology programs or counselor education programs are both very well-trained and well-qualified.

Respectfully submitted,

Dr. Jeffery Aspelmeier, Chair of the Department of Psychology, Radford University