September 4, 2018
Honorable Ralph Northam
Governor of Virginia
Dear Governor Northam:
The Alliance for Professional Counselors (APC), a national organization of counselors and counselor educators, urges you to reject all attempts to restrict counselor licensure in Virginia to graduates of programs accredited by the Council for Accreditation of Counseling and Related Educational Services (CACREP). We also urge you to reject recent regulations that limit graduates’ choice of supervisors to people with Licensed Professional Counselor (LPC) and Licensed Marriage and Family Therapist (LMFT) licenses.
We fully respect that these decisions are within the purview of the Commonwealth of Virginia. However, APC asks your consideration because these policies, as proposed and enacted, are detrimental to the citizens and economy of Virginia. Furthermore, given the potential for inter-state licensure portability and compact agreements, we urge you to consider the national implications of decisions about these issues. By rejecting efforts to restrict counselor licensure to graduates of programs accredited by CACREP and restoring previous regulations that permitted licensed psychologists, psychiatrists, and social workers to serve as residents’ supervisors, you and your administration have another opportunity to improve the health and well-being of Virginia residents and the State economy.
Opposition to CACREP licensure restrictions
We are particularly concerned about the Virginia Board of Counseling’s continued efforts to restrict licensure to CACREP graduates. Although that proposal was officially withdrawn, Board of Counseling minutes and reports from prospective licensees that board staff have told them that Virginia is moving quickly to restrict licensure to graduates of programs accredited by CACREP, have alerted us that this threat to Virginia and the nation remains viable.
We call your attention to the VA economic impact analyses (2016 and 2017) and overwhelming public comment opposition to the proposal to restrict counselor licensure to graduates of programs accredited by CACREP in 2017. Together, those sources demonstrate that the restriction of counselor licensure to graduates of programs accredited by CACREP would solely benefit CACREP, an independent organization, and by extension, programs that choose to pursue and maintain that accreditation. At the same time, that restriction would harm the citizens of Virginia as it would reduce the number of qualified counselors at a time when more are needed. It would also force George Mason University to reconfigure its internationally respected counseling program to meet CACREP requirements or close.
Although CACREP, which was founded in 1981, accredits the majority of Counselor preparation programs in Virginia, it accredits approximately one third of counseling programs nationally. Another 10% are accredited by the Masters in Psychology and Counseling Accreditation Council (MPCAC), which was founded in 2011. This leaves more than half unaffiliated with any program-level accreditor.
The American Psychological Association’s (APA) recent recognition of master’s level training in psychology does not, as minutes from the Board of Counseling incorrectly assume, address objections to CACREP-only restrictions. Furthermore, in addition to programs in which the faculty have decided not to pursue accreditation through CACREP, often despite professional pressure to do so, many other quality programs with long-standing records of success, including counseling psychology master’s programs and counselor preparation programs housed in psychology departments, are ineligible, by current CACREP requirements, for accreditation
Opposition to restrictions of counseling residents’ supervisors to LPC and LMFT holders
As part of the periodic review of regulations for the practice of professional counseling, we urge to you 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 restriction will pose a significant employment barrier to new graduates seeking employment in agencies and regions of the state where supervisors with LPCs and LMFTs are not available (and who would be able to offer supervision through licensed psychologists and social workers). This policy actually harms the employment prospects of new counselors and hampers the growth of the profession.
It appears that this regulatory change occurred as part of a much larger and broader Regulatory Review Initiative during 2012-2013, when, ironically, the impetus was on reducing regulation. As such, this particular change did not get the level of detailed scrutiny that it would have under the regular regulatory change process. There is no data to suggest that other licensed mental health practitioners, notably psychologists (whose profession supplies the bulk of the theory, techniques, and research base for mental health practice), provide supervision of lesser quality than LPCs or LMFTs. Furthermore, given the truncated review process, there may be unintended consequences, particularly in terms of in-state and interstate commerce. For example, the profession is currently exploring ways to enhance portability of counselor licensure. Restrictions in one state that are not shared by other, and particularly neighboring, states are likely to complicate efforts toward portability. Moreover, any regulation that advantages one sector of the profession over others, absent any evidence for improved service delivery, is unfair to consumers and professionals alike.
Overall, we urge you to take action to retain inclusive regulations and law, to reject governmental coercion to create a monopoly for CACREP, and reverse restrictions on graduates’ supervisors for licensure to include licensed psychologists, psychiatrists, and social workers.
Thank you for your consideration.
Respectfully,
Peggy Brady-Amoon, PhD, LPC
President, Alliance for Professional Counselors
&
Associate Professor
Department of Professional Psychology & Family Therapy
Seton Hall University
South Orange, NJ 07079
Cc: Dr. David E. Brown, Virginia Department of Health Professions
Dr. Daniel Carey, Secretary of Health and Human Resources
Ms. Elaine J. Yeatts, Department of Health Professions