October 9, 2018
Subj: Petition for Rule-Making (281) for National Counselor Licensure Endorsement Process
Dr. Kevin Doyle
Chairperson
Virginia Department of Health Professions
Virginia Board of Counseling
Perimeter Center
9960 Mayland Drive, Suite 300
Henrico, Virginia 23233-1463
Dear Dr. Doyle:
The National Board for Certified Counselors (NBCC) is writing to encourage the Board of Counseling to approve the petition for rule-making (281) and amend the requirements for licensure by endorsement to include the National Counselor Licensure Endorsement Process (NCLEP) as a route for counselor licensure in Virginia. NBCC is the national certification organization for the counseling profession, representing over 65,000 National Certified Counselors (NCCs) in the United States. NBCC also develops and administers the licensure examinations for professional counselors in all 50 states, Puerto Rico, and the District of Columbia.
The NCLEP was developed by the American Association of State Counseling Boards (AASCB), the Association for Counselor Education and Supervision (ACES), the American Mental Health Counselors Association (AMHCA), and NBCC. These four national organizations represent key counselor constituencies, including counselor licensing boards, counselor educators, mental health counselors, and board certified counselors.
NBCC understands that petition 281 and the NCLEP are on the agenda for the Nov. 1 Virginia Board of Counseling Board Meeting. We believe the NCLEP is the ideal model for counselor portability because it creates a reasonable and implementable portability process for all current and future counselors. The NCLEP was designed to accommodate innovative service delivery, such as tele-mental health services and military-friendly licensure processes.
AASCB, ACES, AMHCA, and NBCC agreed that the NCLEP must achieve the following objectives:
The NCLEP provides a flexible model of portability that ensures all out-of-state counselors have a path to licensure; qualified counselors can take advantage of a streamlined process. The model incorporates two national credentialing standards that provide quality assurance for expedited review: a graduate-level degree from a program accredited by the Council for Accreditation of Counseling and Related Educational Programs (CACREP) or the NCC credential issued by NBCC. The NCLEP also includes acceptance of any additional standards adopted by the licensure board. This allows states to continue with their existing endorsement process, but also establish an expedited review for those counselors who meet the national standards.
The national standards adopted into the NCLEP will facilitate portability for the vast majority of licensed counselors while establishing quality assurance for state regulatory boards. Incorporating the expedited review for the national credentials will simplify administration and reduce costs for state agencies.
CACREP
The establishment of a degree from CACREP as a platform for counselor portability is consistent with a growing national trend. CACREP maintains rigorous standards for counselor preparation that ensure high quality education and training. CACREP also promotes professional identity to ensure licensed counselors come from the counseling profession. The CACREP degree standard was recognized by the Institute of Medicine as a requirement for clinical practice in a 2010 report. Since that time, states and the federal government have increasingly adopted the standard for practice and participation.
CACREP is the sole accrediting organization for clinical counselors. Nationally, the number of CACREP programs has increased significantly over the past eight years, rising from 530 in 2009 to 767 in 2017. According to CACREP statistics, over 46,389 students were enrolled in CACREP programs in 2017. The job analysis for the National Counselor Examination for Licensure and Certification (NCE) from 2011 showed that 71 percent of practicing counselors came from CACREP-accredited programs.
National Certified Counselor
The NCC credential is equally rigorous. It requires a master’s degree or higher with a major study in counseling from a regionally accredited program, including at least 48 semester or 72 quarter hours of graduate-level academic credit in counseling. The degree must include one course in Professional Orientation to Counseling and at least six semester or 10 quarter hours of supervised field experience in counseling. It also requires coursework in the CACREP core curriculum areas, professional endorsement, and at least 3,000 hours of postgraduate counseling work experience over a minimum 24-month period. Finally, counselors must pass the National Counselor Examination for Licensure and Certification (NCE) or the National Clinical Mental Health Counseling Examinations (NCMHCE). NCCs must adhere to the NBCC Code of Ethics.
The NCC has served as the premier counseling certification since 1983. It is required for licensure in Delaware and is recognized by other state programs. Over 65,000 counselors currently possess the NCC, a number that has been growing each year.
The NCLEP provides a uniform standard for licensure endorsement built on national standards. NBCC urges the Virginia Counseling Board to adopt the NCLEP as the standard for licensure endorsement in Virginia. The NCLEP will make Virginia a leader in counselor portability and facilitate the flow of qualified counselors into the state. The plan balances the priorities of public protection with the demand for increased access to behavioral health services. The NCLEP also decreases costs while increasing quality.
Thank you for your consideration of our recommendation. If you have any questions or comments about this letter or the NCLEP, please contact Jolie Long, NBCC’s Director of State Affairs, at 336-482-2849 or Long@nbcc.org.
Sincerely,
Jolie A. Long
Director of State Affairs
National Board for Certified Counselors