September 10, 2019

To Whom it May Concern:

In response to the NOIRA Action 5230 / Stage 8544 (http://www.townhall.virginia.gov/l/ViewStage.cfm?StageID=8544), we are writing this letter to ask you to reject the changes proposed in this action that would unduly restrict or limit counselors from other jurisdictions from securing licensure in the state of Virginia without unnecessary hardship, thus preventing qualified professional counselors from obtaining Virginia LPC licensure and providing services to Virginia’s public.

From our read of the document, these proposed changes to Virginia Board of Counseling regulations for licensure portability suggested in this action would marginalize counselors who do not graduate from CACREP -accredited programs (who are the majority of counselors nationwide). 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). A better and more inclusive plan is offered by the American Counseling Association (ACA), the professional organization representing all counselors. (https://www.counseling.org/knowledge-center/aca-licensure-portability-model-faqs#)

The current proposal indirectly limits graduates of non-CACREP-accredited programs (the majority of programs in the country) by requiring that they either

1) meet all requirements for initial licensure in Virginia including specific coursework, supervised experience, and residency, (which indirectly preferences CACREP standards) or

2)  have 2 years post-licensure clinical practice in counseling in the last 5 years, which includes teaching graduate courses in counseling, or

3) hold NBCC’s Certified Clinical Mental Health Counselor (CCMHC) for which the NCC and therefore, effective 2024, graduation from programs accredited by CACREP, are prerequisites, or

4) have held an active license in the other jurisdiction for 10 years, or

5) have held an active license in another jurisdiction for 3 years and have either graduated from a program accredited by CACREP or hold the NCC credential (which, as noted above, will be limited to graduates of programs accredited by CACREP effective 2024).

Although not stated explicitly, these restrictions clearly preference graduates of CACREP programs when there is no substantive evidence that CACREP graduates are better prepared than their peers to become licensed counselors. In fact, there are other accrediting bodies (notably, the Masters in Psychology and Counseling Accreditation Council, or MPCAC) that accredit counseling and counseling psychology programs. Moreover, most state licensing boards require only regional accreditation of the institution in which the counseling program resides – not accreditation of the program itself.

The University of Baltimore (UB) is an institution with a thriving non-CACREP accredited counseling psychology program that prepares professional counselors for licensure. Our students boast a 98% pass rate on the National Counselor Exam. We have many current and former students who wish to practice in Virginia beyond their time at UB, providing necessary mental health services to the public in Virginia. We are concerned about the continued efforts in Virginia to restrict licensure in ways that would exclude many well-prepared counselors (including our graduates) from around the country from obtaining licensure as easily as their CACREP-graduate peers. Licensure requirements in Maryland do not restrict graduates of Virginia counseling programs from seeking licensure in Maryland based on program accreditation. Furthermore, restrictions between states interrupt the good efforts being made toward national licensure portability for all counselors.

Again, we urge you to reject these changes to licensure by endorsement regulations in Virginia’s counseling regulations.

Thank you for your time and attention to this matter.

Sincerely,

Darlene Brannigan-Smith, Ph.D.                                                                   

Executive Vice President and Provost

University of Baltimore

Christine Spencer, Ph.D.                                                                                

Dean

College of Arts and Sciences

Sharon Glazer, Ph.D.                                                                                     

Chair

Division of Applied Behavioral Sciences

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

Program Director

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