I am vehemently opposed to the proposed regulation that would restrict counseling supervisors to only those professionals with an LPC or LMFT credential. As it stands, there is a great need for mental health services in Virginia and other states. Limiting supervisors to only LPCs and LMFTs would effectively prevent mental health counselors from delivering much needed services to the wider population of citizens in Virgina.   Rather, I suggest the regulation should continue to include qualified licensed psychologists, licensed clinical social workers and licensed psychiatrists as supervisors. Not only are these professionals highly trained, but it would prevent a potential dearth of supervision, thereby availing the populace to effective affordable mental health care access.

Furthermore, I oppose any efforts to restrict licensure to graduates of programs accredited by CACREP. There are many excellent graduate counseling training programs, not accredited by CACREP, that have produced extraordinary licensed counselors who have demonstrated professional skills and knowledge that exceed CACREP requirements. Therefore, a CACREP-only restriction would decrease consumers' access (especially underserved communities), increase costs to consumers, and ultimately leave the mental health need of Virginia's citizenry unaddressed.

Respectfully,

Peggy Farrelly, PhD