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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10/17/18  8:14 pm
Commenter: Larry Epp, Ed.D., LCPC, Past President, Maryland Chapter (AMHCA/LCPCM)

Oppose: Non-CACREP Counselors Harmed by this Proposal
 

While this proposal appears on its face to enhance licensure portability, it does so based on the unproven assumption that graduates of CACREP approved programs are superior and deserve an unjustified advantage in the portability process. We know many of America's top universities were not CACREP accredited prior to the last two years, and that 70 percent of graduates of Counseling programs over the last 30 years came from Non-CACREP Programs. There is insuffient evidence to justify giving CACREP graduates this advantage over the majority of graduates who did not graduate from CACREP programs. We must examine carefully the hidden motivations of this proposal and wonder whether its real intent is to advantage CACREP graduates without merit. All independently licensed graduates should enjoy licensure portability without the endorsement of CACREP. CACREP should not be the arbiter of portability, but the qualifications, experience, and recommendations of the applicant for licensure. 

CommentID: 67986