Dear Dr. Brown and the Board of Counseling:
The Alliance for Professional Counselors (APC), a national organization of counselors and counselor educators that supports interdisciplinary cooperation and licensure portability, strongly urges you to reject the current proposal to adopt the National Counselor Licensure for Endorsement Process (NCLEP). The NCLEP is NOT a portability plan. It is another plan to promote CACREP, NBCC, and their allies at the expense of the public and the majority of licensed counselors nation-wide.
The current proposal, which was submitted by a member of the CACREP Board of Directors, would restrict portability (i.e., licensure by endorsement) to licensed counselors who graduated from programs accredited by CACREP or hold the National Certified Counselor (NCC) credential issued by the National Board for Certified Counselors (NBCC). The NCC will be restricted to graduates of programs accredited by CACREP effective January 2024. The NCLEP would do nothing for the majority of licensed counselors who graduated from programs that are not affiliated with CACREP – and in fact, could further limit their employment options.
The American Counseling Association’s (ACA) 2016 Portability Plan is a significantly better option than the NCLEP, which ACA declined to endorse in 2017. The ACA Portability Plan would permit counselors licensed at the independent level in one state (who do not have any disciplinary actions against them) to qualify for independent licensure in any other state in which they are seeking residence. Duly licensed counselors would be treated equally across the nation under this plan. Compared with the NCLEP, the ACA plan respects all counselors, the licenses they hold, and doesn't require a waiting period.
APC continues to advocate against all efforts to restrict licensure to graduates of programs accredited by the Council for the Accreditation of Counseling and Related Educational Services (CACREP). Although not currently under formal consideration, we note multiple attempts by the Board of Counseling and CACREP allies to impose a government-sanctioned monopoly in Virginia. Similar to the above, a restriction of this sort would harm, not protect, the public and would reduce counselor employment opportunities in Virginia. We call your attention to the two successive Virginia Economic Impact Analyses (2016, 2017) for further information.
We fully respect that these decisions are within the purview of the Commonwealth of Virginia. However, APC asks your consideration because these proposed regulations are detrimental to the citizens and economy of Virginia. Furthermore, we urge you to consider the national implications of these decisions and take action to prevent the adoption of NCLEP in Virginia and all proposals to restrict Virginia counselor licensure to graduates of programs accredited by CACREP.
Thank you for your consideration.
Respectfully,
Peggy Brady-Amoon, PhD, LPC
President, Alliance for Professional Counselors; www.apccounseloralliance.org
and
Associate Professor
Department of Professional Psychology & Family Therapy
Seton Hall University
South Orange, NJ 07079