I am writing in opposition to the regulation, adopted under former Governor O’Donnel’s Regulatory Review in 2013, that eliminated psychologists and social workers as possible supervisors for counseling residents in Virginia.  I am a psychologist and retired counseling educator.  Across 4 decades   I supervised students, taught in, and directed graduate counseling and psychology programs.  My own training and that of the many hundreds of students I have known have been enriched by learning from psychiatrists, family therapists, social workers, addictions professionals, counselors, and psychologists.  I can tell you, based on a lifetime of experience, that effective professionals from these various branches of the mental health field, when working with mental health clients, are all far more alike than different.  Furthermore, the differences add rich perspective rather than detract from one’s educational experience.   Excellent supervision, including nurturing trainees’ identity as professional counselors, is not the sole province those who hold the LPC or LMFT degree.  Moreover, disallowing trainees to seek out supervision from the professional with expertise in a given specialty area they want to learn, does a disservice to both students and the public.

Counseling trainees who wish to develop expertise in evidence-based treatments for trauma or brain injury might be best served by psychologists who have trained and worked in the VA system.  Those wanting to specialize in working with autistic children may find their best supervision from a behavior analyst, just as those with interest in couples or family therapy may be best mentored by an LMFT, competency in addictions by addictions professionals, and so on.  In a given locale or setting, an LPC may be the best supervisor for each of these scenarios.  But the opposite is also possible, and the choice should be available to the trainee.

Creating training silos that separate developing counselors from supervisors and mentors who may otherwise be best positioned to facilitate their professional development, is a mistake.  This thinking guided my choice of faculty and clinical supervisors for multiple areas of training in the counselor training programs that I directed.  I strongly believe that drawing from multiple disciplines is the best model for counseling training, and therefore I strongly suggest that the current restriction on the supervision be removed from the Virginia regulations.

For similar reasons, I oppose the Board of Counseling’s intention to require a degree from a CACREP-accredited counseling program for licensure as an LPC.  Again, much is lost when the diversity of intellectual and professional traditions during training is limited, as is required under CACREP rules.  Furthermore, there is no substantiated evidence that CACREP-accredited programs provide superior training.  This is a national as well as a state concern, as all states grapple with how to best serve the public interest.  Only three states require a CACREP degree for initial licensure, and in one state the restriction applies only to in-state applicants.  Thus, overwhelmingly, states have not adopted CACREP as a licensure standard.  The majority of counseling programs in the country are not CACREP-accredited, many (those based in psychology departments) cannot be, and many elect not to be, out of preference or due to the very high costs of obtaining and maintaining the accreditation.   A CACREP-only policy in Virginia would put it out of synch with most states, limit training and employment opportunities across state lines, complicate attempts to establish portability of licenses among states, and, importantly, threaten the viability of one of Virginia’s premier counseling programs, at George Mason University, which has not chosen this accreditation.

For all of these reasons I strongly urge a return to inclusive policy in qualifications for supervisors of counseling residents, and rejection of any proposal to limit LPC licensure to graduates of CACREP programs.