I am an educator who has actively trained masters and doctoral level counselors and psychologists for the past 27 years. I am writing to state my opposition to the current regulations that restrict counseling residents’ supervisors to individuals who hold an active Licensed Professional Counselor (LPC) or Licensed Marriage and Family Therapist (MFT) license rather than following more inclusive supervision requirements that allow supervision by licensed psychologists (who frequently have more education, training, and experience in clinical supervision), psychiatrists and social workers. The restriction is not based on any evidence about the relative quality of supervision by LPC or MFT individuals compared to other appropriately trained and licensed mental health providers. As a scientist, I am skeptical about regulations that have no empirical support and that bypass the standard levels of review for regulatory change.  Rather than enhancing services to the citizens of Virginia, the current regulation is likely to restrict their access to services because new graduates from clinical mental health training programs will not be able to meet their supervision requirements, rendering them unable to be employed and offer services to the public.  In other words, it creates a problem where none existed. 

In a similar vein, there is no empirical support for the ongoing efforts by the Board of Counseling to restrict Virginia counselor license to graduates of programs accredited by CACREP. Again, rather than protecting the citizens of Virginia, restricting licensure only to graduates of CACREP accredited programs ignores the established quality of other programs and restricts the number of mental health workers available to serve the needs of the population. This is hardly in the best interest of the state. However, it does appear to be based in a guild mentality focused on establishing a state-sanctioned monopoly by a private accrediting body.