October 18, 2018

To the Virginia Leadership:

In response to the Licensure by endorsement Petition 281 forwarded by Charles R. McAdams, III, to the Virginia Board of Counseling, the University of Baltimore and its M.S. in Counseling Psychology Concentration join with the Virginia Counselors Association and the American Counseling Association in their opposition to the adoption of the National Counselor Licensure for Endorsement Process (NCLEP) plan in Virginia.

As a neighboring state, counselor preparation programs in Maryland have a vested interest in the counselor licensure regulations in neighboring states. Students often travel between states for school and work in the D.C. Metro / DelMarVa area, and portability of licensure is a vital issue for all counselors, especially those who live and work fluidly between different jurisdictions. The University of Baltimore supports counselor licensure portability itself, but not the NCLEP plan as it is discriminatory and fundamentally flawed.

The NCLEP plan essentially continues an attempt to restrict all counselors’ ability to practice by providing preferential treatment of programs accreditated by the Council for the Accreditation of Counseling and Related Educational Programs (CACREP). The proposed criteria for licensure by endorsement are:

“The licensee complies with ONE of the following:

a. Meets all academic, exam and postgraduate supervised experience standards as adopted by the state counseling licensure board.

b. Holds the National Certified Counselor (NCC) credential, in good standing, as issued by the National Board for Certified Counselors (NBCC).

c. Holds a graduate-level degree from a program accredited by the Council for Accreditation of Counseling & Related Educational Programs (CACREP).”

https://www.nbcc.org/Assets/Portability/Portability-Statement-Endorsement-Process.pdf

Graduates of non-CACREP programs cannot comply with (c). In January 2024, the NCC credential will no longer be available to non-CACREP graduates thus our students cannot comply with (b) after 2023. Finally, for any state that requires a CACREP degree for initial licensure (Maryland does not), our graduates cannot then meet (a). Thus, our graduates are effectively shut out of any state with CACREP-only requirements (right now, Kentucky and North Carolina) that then chooses to adopt the NCLEP plan. No state has yet adopted the NCLEP plan in its counseling board regulations; Virginia would be the first to do so.

Given the Virginia Counseling Board’s history of continued attempts to restrict licensure to graduates from CACREP programs, we believe adoption of NCLEP is one step removed from effectively shutting the door on well-educated and talented counselors from Maryland (and other states) who hope to serve Virginia’s public and stimulate the Virginia economy. Reciprocally speaking, the Maryland Board of Professional Counselors and Therapists has no requirement of program accreditation for counselor licensure, is not currently considering adoption of NCLEP, and in terms of licensure by endorsement, recognizes the educational degrees and professional experiences of licensed counselors who graduated from regionally-accredited institutions in professional counseling.

The American Counseling Association has declined to endorse this plan, and instead created their own proposed national portability of licensure plan (www.counseling.org/knowledge-center/licensure-requirements/licensure-portability-model-fact-sheet). This plan is much less restrictive and allows for potability of licensure among states for any counselor who has been licensed in another state with no disciplinary action, pending a passing score on the intended state of residence’s jurisprudence exam. We support this inclusive path to license portability.

We appreciate your time and attention to our concerns regarding these important issues.

Sincerely,

(signature on file)

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Darlene Brannigan-Smith, Ph.D.                                                                    Date

Executive Vice President and Provost

University of Baltimore

(signature on file)

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Christine Spencer, Ph.D.                                                                                Date

Dean

College of Arts and Sciences

(signature on file)

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Sharon Glazer, Ph.D.                                                                                      Date

Chair

Division of Applied Behavioral Sciences

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Courtney Gasser, Ph.D., L.P., N.C.C.                                                            Date

Program Director

Master’s of Science in Applied Psychology-Counseling Psychology Concentration