Strongly Oppose

Dr. Steve Warren, Dean of the School of Behavioral Sciences, Liberty University

I strongly oppose the proposed requirement that would restrict LPC licensure to programs that are CACREP accredited.  I strongly oppose the proposed requirement for CACREP accreditation for educational programs and its potential intrusion in regulations governing the practice of professional counseling per 18 VAC 115-20.

The imposition of CACREP standards in a one-size-fits-all process fails to recognize existing academic quality standards, assumes unproven CACREP quality levels, applies a weak argument against the 2016 Economic Impact Analysis report, while stifling innovation with a redundant, costly, and complicated regulatory burden to good-actor institutions throughout the Commonwealth.

Failure to Recognize Existing Academic Quality

The licensure process currently in place ensures that students meet strict criteria for appropriate coursework from an appropriately accredited program.  Marginalizing this existing process to implement a lobbied CACREP requirement is not a guarantee of higher quality.  There are several quality counselor education programs in the Commonwealth that do not currently have CACREP accreditation. 

Liberty University real-world, teaching, faculty have described their privilege working with under-served populations in the Commonwealth at a Community Service Board (CSB). Faculty served by supervising clinicians from a number of counselor education programs—some of which had CACREP accreditation and others that did not.

Feedback from this on-the-ground experience clearly demonstrated that there was no systematic difference in the skills, knowledge, or ability of the students based on CACREP accreditation involvement. This experience also demonstrated that institutions that do not currently have CACREP accreditation are doing an adequate job of preparing students for entry level positions and residencies where their preparation for independent practice can be continued. Additionally, we concur with the Economic Impact Analysis and also have identified no evidence of CACREP graduates being better counselors or having less reported ethical violations.

Furthermore, direct experience with CSB informed our faculty by making them acutely aware of the need for more licensed practitioners. These agencies often work with under-served populations who have limited access to mental and behavioral health services. At a time when our communities are facing family crises, opioid abuse, and continuing financial pressures, creating an additional and unnecessary barrier to clinical licensure means that these high-need, high-risk populations will have even less access to quality care.

2016 Economic Impact Analysis – Agency Response

I do not concur with the Agency’s counter-analysis of the 2016 Economic Impact Analysis.  A representative example is contained in the language of the Agency memo dated June 1, 2016, Section 4.  The very first paragraph illustrates the limited perspective of the Agency.  When the Agency stated that “accreditation by a professional accrediting body is the only reliable measure of educational quality” it simultaneously states the obvious, sets aside the quality of the current licensure process (and its relationship to broader regional accreditation reviews) and fails to define “reliable” beyond involving a new regulatory entity.  

Hindering Thoughtful Innovation with Bureaucracy

The field of counseling is one that benefits from a richness of diversity and ingenuity. In fact, students pursuing these credentials are inspired by the unique characteristics of their institution and individualized mentoring of their faculty.  This unique dynamic could be stifled by artificially imposing a standard on counselor education programs that dictates the means by which counselor competencies are achieved. Assigning extensive curriculum requirements to a single body, limits advancements in the field by not allowing programs to deviate from norms.  This very stance is a step backward rather than a step toward innovation at a time when technology is changing the culture and connecting new communities online in new ways. CACREP curricular standards are years behind educational advances in online platforms.

Costly, Complicated, and Redundant Regulations

In a misguided effort to improve quality, CACREP is mimicking methods that are currently failing at the federal level.  The U.S. Department of Education (ED) has attempted to regulate curricular standards from the top-down, massively expanded required consumer information disclosures, usurped state-level autonomy for academic program approvals and attempted to compare diverse post-secondary academic programs using a one-size-fits-all approach.  Results have been very poor.  As a result, ED has provided conflicting information in academic matters, confusing consumer information (frustrating students) while driving up costs which hurt students and their families. Limiting licensure to CACREP programs adds a layer of redundancy, cost, and complication without clearly providing any improvement in counselor competence or ethical practice.  Especially concerning is that the imposition of new regulations could be cost prohibitive especially to small institutions and institutions serving high-need, at-risk populations in urban and rural America.       

I strongly oppose the proposed requirement that would restrict LPC licensure to programs that are CACREP accredited.  This misguided effort will burden institutions and not guarantee any quality improvement for our students and the communities they will soon serve.