We are writing on behalf of LCPCM, the Maryland chapter of the American Mental Health Counselors Association (AMHCA) to express concerns regarding the proposal by Virginia’s Board of Counseling to adopt NCLEP as Virginia’s interstate portability plan. NCLEP would provide three paths to Virginia LPC licensure for out-of-state licensees:
Since Maryland borders Virginia, portability is a prominent concern for Maryland’s Licensed Clinical Professional Counselors (LCPCs). The purpose of portability plans, in our understanding, is to facilitate interstate licensure. However, NCLEP would not improve license portability for the vast majority of our LCPCs, who DID NOT graduate from a program accredited by CACREP, and therefore could not receive the advantages that NCLEP offers. NCLEP provides similar advantages to counselors who hold the NCC credential, but the NCC will be closed to all but CACREP program graduates in 2024. LCPCM opposes a plan that would require (even during the relatively brief window in which this would be possible) Maryland LCPCs to obtain another costly certification to be eligible for Virginia licensure. Our state has stringent criteria for the LCPC license, very comparable to Virginia’s criteria. We would argue for a much more inclusive portability plan.
We are aware that the American Counseling Association’s portability plan (www.counseling.org/knowledge-center/licensure-requirements/licensure-portability-model-fact-sheet) would allow counselors in one state to receive licensure in another. We see this as a far better option than NCLEP for Virginia to adopt.
A related concern is that two of Maryland’s counselor preparation programs are approved by the Master’s in Psychology and Counseling Accreditation Council (MPCAC; http://mpcacaccreditation.org/) and more are in the pipeline for this approval. MPCAC-approved programs are often, though not exclusively, programs that CACREP does not serve.
Since Maryland’s LCPCs are primarily graduates of programs that are not affiliated with CACREP, and increasing numbers are from MPCAC-approved programs, we strongly urge the adoption of a portability plan that would not disadvantage professionals trained in these programs.
A final, and great, concern relates to Virginia’s past and likely future attempts to require a degree from a CACREP-approved program for licensure. If NCLEP is intended to replace Virginia’s license by endorsement policy (which we understand to be the current “portability” option), either now or in the future, a CACREP requirement would make it impossible for Maryland’s LCPCs, (or those from any other state) who hold degrees from non-CACREP programs to ever become licensed in Virginia. In this scenario, the final provision of NCLEP, to allow counselors to meet state requirements, would be closed to them, as well.
For all of these reasons, we are strongly opposed to the adoption of NCLEP as the portability plan for LPC licensure in Virginia. Virginia’s current regulations for licensure by endorsement allow a pathway for out-of-state applicants to achieve the LPC. We strongly support either no change to the current endorsement policy, or a change to a more inclusive portability plan.
Thank you for your attention.
Mollie Thorn, LCPC
President, Licensed Clinical Professional Counselors of Maryland
Elaine Johnson, Ph.D.,
Board Member at Large