While I am not a resident of Virginia, I think it is crucial to voice my opposition publicly as a licenced psychologist as this is a national and state issue. I am a graduate of a Master’s in Counseling program that was not CACREP accredited and a Ph.D. program in Counseling Psychology that was APA-accredited. I hold multiple identities that include counselor, counseling psychologist, and counseling educator. I am a licensed counseling psychologist who is an administration, educator, and supervisor in a Master’s of Counseling program that trains mental health, addictions, rehabilitation, and school counselors. In these roles, I have trained and supervised hundreds of Master’s level students in counseling and counseling psychology for over 13 years. 

      I strongly opposed the Board of Counseling’s continued efforts to restrict Virigina counselor licensure to graduates of programs accredited by CACREP, despite officially withdrawing this proposal last fall. This issue has national implications that limits graduate students from receiving diverse training from well qualified faculty, such as myself and my colleagues. Also this issues significantly burdens select academic institutions, and privileges others. 

      Along with the proposed Counseling licensure restriction to those who graduate from CACREP accredited counseling programs, the proposed restriction that these graduates can only receive supervisor for licensure from LPCs and LMFTs is NOT “necessary for the protection of public health, safety, and welfare or for the economical performance of important governmental functions”—two goals of the periodic review. In fact, these restrictions would only serve to decrease the accessibility of counseling to the general public and increase the health disparities evident for social groups who have limited access to healthcare. 

      CACREP-only restrictions will create a government-imposed monology and a restriction on trade. For example, in Virginia, itself, the CACREP-only restrictions and the push for supervision from only LPCs and LMFTs would force George Mason University, a well-respected counselor training program and the only counseling program in Virginia that is not accredited by CACREP to pursue this accreditation or close. This restriction does not taken into consideration other means of monitoring and maintaining educational quality nor does it acknowledge alterative accreditation paths offered by MPCAC and potentially other accrediting bodies in the future. CACREP is but ONE accrediting body. It does not represent the only standard. These proposed CACREP-only and supervision restrictions also does not take into consideration the strict process of program review at accreditation institutions of higher education across the US and internationally. Our Counseling programs reside in colleges and universities that are accredited themselves. 

    Rejecting this proposal would not harm any program that chooses to maintain CACREP accredition or any program that choose alternative means of monitoring and maintaining quality (which could include alterative accreditation).  
 

     Rejecting this proposal would maintain a path for licensure and service in Virginia for the majority of students in current Counseling programs across the US and internationally as well as alumni and faculty from these programs. 

      In the end, rejecting this proposal would support the need for greater access to mental health services. We need more qualified mental health professionals in the field, not less. 

Sincerely, 

Rachel L. Navarro, Ph.D., L.P. (ND #463)
University of North Dakota
Counseling and Counseling Psychology programs