Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Counseling
 
chapter
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]
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9/4/18  2:28 pm
Commenter: James Bludworth, Director of the Counselor Training Center

Strongly opposed to CACREP restrictions
 

I am writing to express my strong opposition to any regulation or law that would exclusively restrict counseling residents’ supervisors to only those with Licensed Professional Counselor or Licensed Marriage and Family Therapist licenses.  I request a return to inclusive supervision requirements which allow for a range of qualified licensed mental health professionals to provide required clinical supervision of counselor trainees.  Excluding psychologists, psychiatrists, and social workers from providing clinical supervision to counselor trainees unnecessarily limits the training experiences available to such students.  Moreover, it essentially excludes them from integrated models of behavioral health care which are now the cutting edge of the mental health profession.

I also strongly oppose efforts to restrict counselor licensure in any state to graduates of CACREP accredited programs only.  Such a proposal, in essence, creates a government-sanctioned monopoly of a private organization (CACREP) which is not accountable to the citizens of the state in which the restriction is granted.  The licensure process for counselors and other mental health professionals is meant to protect the public welfare.  What CACREP proposes far surpasses the mandate to protect the public welfare and moves toward excluding qualified candidates simply because they chose an educational institution whose professional principles diverge from those of CACREP.  The state licensing board must not abdicate its responsibility to protect the welfare of its citizens to a private organization such as CACREP.  Please keep eligibility to sit for licensure a fair process wherein those who are qualified are granted the ability to apply for licensure based on their knowledge and abilities and not solely on what any one accrediting body has to say about the matter.    

 

CommentID: 66960