American Mental Health Counselors Association
675 N. Washington St. Ste. 470, Alexandria, VA 22314
Phone: 800-326-2642 Fax: 703-548-4775
October 19, 2018
RE: Petition for Rule-Making (281) for the National Counselor Licensure Endorsement Process
Dr. Kevin Doyle
Chairperson
Virginia Department of Health Professions
Virginia Board of Counseling
Perimeter Center
9960 Maryland Drive, Suite 300
Henrico, Virginia 23233-1463
Dear Dr. Doyle:
The American Mental Health Counselors Association (AMHCA) 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.
AMHCA is the national association representing clinical mental health counselors consisting of 7000 members from around the nation.
The NCLEP was developed by AMHCA, the American Association of State Counseling Boards (AASCB), the Association for Counselor Education and Supervision (ACES), and the National Board for Certified Counselors (NBCC). These four national organizations represent key counselor constituencies, including counselor licensing boards, counselor educators, clinical mental health counselors, and board certified counselors.
AMHCA understands that petition 281 and the NCLEP are on the agenda for the November 1st 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:
Significantly increase public access to qualified care.
Establish minimum standards for safe practice.
Reduce administrative burdens for both state regulatory boards and licensees.
Create consistency in licensure standards across state lines.
Ensure protection of the public and the continued development of the profession.
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.
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 me at 703-548-4474 or at jmiller@amhca.org.
Sincerely,
Joel E. Miller
Executive Director and CEO
American Mental Health Counselors Association