The proposed restriction that would limit licensure to graduates of programs accredited by CACREP and restrictions of graduates’ supervisors to LPCs and LMFTs are clearly NOT “necessary for the protection of public health, safety, and welfare or for the economical performance of important governmental functions,”  which are the goals of the periodic review.

CACREP-only restrictions would create a government-imposed monopoly of a private organization that is not accountable to the citizens of Virginia. It would also force George Mason University, an internationally respected counselor training program and the only counseling program in Virginia that is not, by choice, accredited by CACREP, to pursue that accreditation or close. Rejecting this proposal would not harm any program that chooses to pursue accreditation through CACREP; they can still do that. Rejecting this proposal would, however, maintain a path for licensure and service in Virginia for the national (and international) majority of students, alumni, and faculty in counseling programs that are not affiliated with CACREP.

We also urge you to urge decision-makers to strike the regulation that restricts graduates’ choice of supervisors to people with LPC and LMFT licenses. That current regulation specifically excludes the majority of qualified supervisors in hospitals and related clinical settings, most of whom are licensed as psychologists, psychiatrists, and social workers. If this regulation is not changed, the experience in other states has been that this will pose a significant employment barrier to new graduates seeking employment in agencies and regions of the state where these supervisors are not available (and who can only offer supervision through psychologists or social workers). This policy actually harms the employment prospects of new counselors and hampers the growth of the profession. In addition, it should be noted that this regulation, which has yet to go into effect, was adopted outside the normal processes after a public comment period in which all commenters opposed the then-proposed regulation.