As a clinical psychologist and academician, I OPPOSE this petition. Prior to 2013, Norfolk State offered 3 degree programs in Psychology (B.A., M.A. & Ph.D.). Until 2009, students in our M.A. program were eligible to sit for the LPC exam after completion of their supervised hours. They were successful in passing the examination indicating that the training was adequate in preparing them to be licensed counselors. But in 2009, the Virginia Board of Counseling altered its criteria for whom was eligible for the LPC in Virginia, and graduates from our master’s degree program in Psychology were denied the opportunity to proceed with licensure. At that time, the Virginia Board of Counseling appeared to have informally adopted the standards outlined in the 2009 Guiding Statements of CACREP regarding eligibility for faculty teaching in CACREP accredited programs. Specifically, CACREP guidelines stated “faculty should have earned doctoral degrees in counselor education and supervision, preferably from a CACREP-accredited program, or have been employed as full-time faculty members in a counselor education program for a minimum of one full academic year before July 1, 2013.” Although Norfolk State attempted to reorganize and reinvent our program so that our students would again be license-eligible, we were unable to do so since the majority of our faculty held their doctoral degree in Psychology rather than in Counselor Education. Thus, the changing standards that were implemented by the Virginia Board of Counseling in 2009 to be consistent with CACREP standards, played a significant role in Norfolk State having to make our master’s degree program in psychology inactive in 2013. In other words, although we had been successfully preparing mental health professionals for the LPC, we were forced to terminate our program because the Virginia Licensing Board would not approve our graduates for the LPC. This had a significant negative impact on a large number of our alumni from Norfolk State’s Master’s Program in Psychology, and has also led to fewer highly trained and competent mental health professionals in Virginia. Again, the limitations placed on individuals as a result of changes made by the Board of Counseling has had a detrimental effect on the field as well as training programs such as ours. The proposed regulations would likely have the same impact on other master’s level Psychology Programs in Virginia and would also prevent qualified mental health professionals from other states from being license-eligible in Virginia. As a clinician, I see the need in the field for an increase in licensed mental health professionals. I thus have two recommends. First, I urge you to OPPOSE the CACREP-only proposed regulation which would officially exclude graduates from the vast majority of Departments of Psychology in the country from being LPC-eligible. Although Departments of Psychology and Departments of Counselor may have different philosophical approaches to mental health, both produce competent professionals who can serve the Commonwealth. Second, the Virginia Board of Counseling should return to the more inclusive definition regarding LPC-eligibility used prior to 2009 that was not based on the restrictive guidelines used by CACREP. These restrictive CACREP guidelines that the Board appeared to informally adopt in 2009  resulted in the inactive status of the master’s program at Norfolk State, and will likely have an even greater negative impact on the citizens of Virginia if graduates from all master’s programs in psychology in the country are prohibited from being LPC-eligible in Virginia.

Ernestine A.W. Duncan, Ph.D. Department Chair, Psychology, Norfolk State University