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]
Action Changes resulting from periodic review
Stage NOIRA
Comment Period Ended on 9/18/2019
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9/13/19  10:37 am
Commenter: Sidney Trantham / Lesley University

OPPOSED
 

As the head of a master’s level mental health counselor program that prepares professionals to work as Licensed Mental Health Counselors (LMHCs) in Massachusetts, I am writing to encourage Virginia to oppose the current proposal related to CACREP requirements for counselor license portability. 

The current proposal, while offering several options for all licensed counselors, falsely suggests that licensed counselors who graduated from programs accredited by CACREP (who would need 3 years post-licensure experience) are more qualified than those who graduated from other programs (who would need 10 years post-licensure experience).

There is no documented evidence that licensed counselors who graduated from programs accredited by CACREP are better prepared than their peers who graduated from other programs! For example, it is rare to find CACREP accredited programs in all of the New England states, in yet we have many mental health counselor training programs that produce exceptional licensed mental health counselors.  There are approximately 36 master’s level training programs in Massachusetts and only seven of them are CACREP accredited.  We know that programs in Massachusetts that are not CACREP accredited are producing exceptional mental health counselors! In addition, there are other accreditation bodies for mental health counselor training programs such as the Masters in Counseling and Psychology Accreditation Council (MPCAC) that set standards for counselor training and education and have accredited programs in approximately 22 states.  Why then, should the majority of licensed counselors who did not graduate from programs accredited by CACREP be required to show 7 more years of experience than their peers who graduated from programs accredited by CACREP?  Finally, at time when there is clear evidence of the need for more mental health counselors across this nation, why support a licensing requirement that prohibits well trained, licensed mental health counselors from practicing? The CACREP proposal does not make sense. 

The Alliance for Professional Counselors fully supports portability for all counselors and the American Counseling Association’s (ACA) 2016 Portability Plan. 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.  Please see their website for more information about ACA’s model if you have not already done so:

https://www.counseling.org/knowledge-center/aca-licensure-portability-model-faqs#

I hope that Virginia (and other states) will support a more inclusive approach to license portability and oppose CACREP’s attempt to unduly and unfairly influence mental health counselor training and the counseling profession. 

Sincerely,

Sidney M. Trantham, Ph.D.

Associate Professor / Division Director

Division of Counseling & Psychology

Lesley University

Cambridge, MA

CommentID: 76150