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]

141 comments

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10/5/18  11:06 am
Commenter: Masterful Couples of Northern VA

Supporting Comment
 

 

I support this Petition for Rulemaking and do hope it passes!!  I plan to relocate in the next 6-7 years and want to be able to have a seamless transition with my licensure and NBCC certification from VA to the next state in which I relocate.  Thank you.

 

 

CommentID: 67481
 

10/5/18  12:34 pm
Commenter: Caitrin Allingham, Oakton Primary Care Counseling

In support of
 

Type over this text and enter your comments here. You are limited I support this Petition for Rulemaking and I do hope it passes!!  I do not plan to relocate.  However, I believe for all states and U.S. territories to attract and maintain quality counselors for much needed mental health services, both here in Virginia and all states and U.S. territories, Professional counselors  with NBCC certification(s) should be able to have a seamless transition to the next state/territory in which they relocate.  Thank you.to approximately 3000 words.

CommentID: 67482
 

10/6/18  9:00 pm
Commenter: Rebecca K Hogg, Resident in Counseling

Support for this rule
 

I support this petition for rule making. Accepting the NCLEP will place Virginia in the position as. Or only the first state to license professional counselors but also the first state to take the needed step towards licensure portability. NBCC certifies counselors at a level equivalent to licensure requirements. Steps towards license portability are critically needed in our increasingly mobile society. This change would not impede any current counselors and counseling students from achieving licensure but instead provide a critical guide for future counselors and counseling education programs to follow. 

CommentID: 67491
 

10/9/18  5:32 pm
Commenter: Jolie Long, National Board for Certified Counselors

Petition for Rule-Making (281) for National Counselor Licensure Endorsement Process
 

October 9, 2018

Subj: Petition for Rule-Making (281) for National Counselor Licensure Endorsement Process

Dr. Kevin Doyle

Chairperson

Virginia Department of Health Professions

Virginia Board of Counseling

Perimeter Center 
9960 Mayland Drive, Suite 300
Henrico, Virginia 23233-1463

Dear Dr. Doyle:

The National Board for Certified Counselors (NBCC) 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. NBCC is the national certification organization for the counseling profession, representing over 65,000 National Certified Counselors (NCCs) in the United States. NBCC also develops and administers the licensure examinations for professional counselors in all 50 states, Puerto Rico, and the District of Columbia.

The NCLEP was developed by the American Association of State Counseling Boards (AASCB), the Association for Counselor Education and Supervision (ACES), the American Mental Health Counselors Association (AMHCA), and NBCC. These four national organizations represent key counselor constituencies, including counselor licensing boards, counselor educators, mental health counselors, and board certified counselors.  

NBCC understands that petition 281 and the NCLEP are on the agenda for the Nov. 1 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.   

CACREP

The establishment of a degree from CACREP as a platform for counselor portability is consistent with a growing national trend. CACREP maintains rigorous standards for counselor preparation that ensure high quality education and training. CACREP also promotes professional identity to ensure licensed counselors come from the counseling profession. The CACREP degree standard was recognized by the Institute of Medicine as a requirement for clinical practice in a 2010 report. Since that time, states and the federal government have increasingly adopted the standard for practice and participation.

CACREP is the sole accrediting organization for clinical counselors. Nationally, the number of CACREP programs has increased significantly over the past eight years, rising from 530 in 2009 to 767 in 2017. According to CACREP statistics, over 46,389 students were enrolled in CACREP programs in 2017. The job analysis for the National Counselor Examination for Licensure and Certification (NCE) from 2011 showed that 71 percent of practicing counselors came from CACREP-accredited programs.

National Certified Counselor

The NCC credential is equally rigorous. It requires a master’s degree or higher with a major study in counseling from a regionally accredited program, including at least 48 semester or 72 quarter hours of graduate-level academic credit in counseling. The degree must include one course in Professional Orientation to Counseling and at least six semester or 10 quarter hours of supervised field experience in counseling. It also requires coursework in the CACREP core curriculum areas, professional endorsement, and at least 3,000 hours of postgraduate counseling work experience over a minimum 24-month period. Finally, counselors must pass the National Counselor Examination for Licensure and Certification (NCE) or the National Clinical Mental Health Counseling Examinations (NCMHCE). NCCs must adhere to the NBCC Code of Ethics.

The NCC has served as the premier counseling certification since 1983. It is required for licensure in Delaware and is recognized by other state programs. Over 65,000 counselors currently possess the NCC, a number that has been growing each year.

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 Jolie Long, NBCC’s Director of State Affairs, at 336-482-2849 or Long@nbcc.org

Sincerely,

Jolie A. Long

Director of State Affairs

National Board for Certified Counselors

 

CommentID: 67505
 

10/10/18  12:28 pm
Commenter: Cynthia Miller

Oppose adoption of NCLEP as it currently reads
 

I OPPOSE the adoption of NCLEP.  I am completely in favor of making it easier for counselors to transfer their licenses from one state to another but I believe the NCLEP proposal makes the process of portability overly restrictive.  The proposal states that a counselor who is fully licensed for independent practice in one state would be eligible for licensure by endorsement in another state only after that counselor has acquired at least 3 years of post-licensure experience.  I see no reason for a 3-year timeframe.  It essentially forces a counselor to remain in the state they are licensed for at least three years after licensing before they can move somewhere else and have their license be recognized.  I know of no other profession that requires someone to practice for three years in the state they are licensed before becoming eligible to move.

 

If the Board of Counseling wants to make portability easier I would encourage it to adopt the American Counseling Association's which states:  A counselor who is licensed at the independent practice level in their home state and who has no disciplinary record shall be eligible for licensure at the independent practice level in any state or U.S. jurisdiction in which they are seeking residence. The state to which the licensed counselor is moving may require a jurisprudence examination based on the rules and procedures of that state.”
—Approved by the ACA Governing Council, June 2016

CommentID: 67507
 

10/10/18  1:03 pm
Commenter: Edil Torres Rivera

No evidence
 

I do see why people need to be in practice in another state for three years, as long as they meet the requirements of couser work and ethical behavior.

CommentID: 67508
 

10/15/18  4:28 pm
Commenter: Simone Lambert, American Counseling Association

Opposition of the American Counseling Association to the petition for endorsement of the National Co
 

October 15, 2018

 

Jaime Hoyle, Executive Director

Virginia Boards of Counseling, Psychology, and Social Work

9360 Maryland Drive

Suite 300

Richmond, VA  23233

 

Subject:  Opposition of the American Counseling Association to the petition for endorsement of the

                 National Counselor Licensure Endorsement Process

 

Dear Mr. Hoyle:

 

The American Counseling Association (ACA) is opposed to the petition to the Virginia Board of Counseling requesting endorsement of the National Counselor Licensure for Endorsement Process (NCLEP).  As background, ACA is the largest association for professional counselors with more than 53,000 members. This includes 2,269 members who reside in Virginia.  I am one of those professional counselors. In addition to being the president of ACA, I am a licensed professional counselor in the Commonwealth of Virginia.

 

Licensure portability—the ability to transfer a professional counseling license when a practitioner moves to a different state—is one of the foremost concerns of professional counselors. Even the most experienced counselor can be required to obtain additional supervision hours or meet other requirements before they can secure a new license after a move across state lines. In some cases, counselors with decades of experience are told that they cannot transfer their license to their new home state under any condition.

 

In order to promote licensure portability, ACA has promulgated a portability model that calls for professional counselors to be able to seamlessly transfer their license when they move to another state or jurisdiction. The ACA licensure portability model calls for counselors who are licensed in one state and have no disciplinary record to become eligible for license “in any state or U.S. jurisdiction in which they are seeking residence.” The model recognizes that a state may require these counselors to take a jurisprudence examination to verify that they are knowledgeable about mandated reporting and other pertinent laws in that particular state. The ACA model focuses on the issuance of a state counseling license as the key to portability.  

 

The ACA licensure portability model states:

 

“A counselor who is licensed at the independent practice level in their home state and who has no disciplinary record shall be eligible for licensure at the independent practice level in any state or U.S. jurisdiction in which they are seeking residence. The state to which the licensed counselor is moving may require a jurisprudence examination based on the rules and procedures of that state.”

—Approved by the ACA Governing Council, June 2016

 

The ACA licensure portability model takes into account the increasing standardization of training and postgraduation supervision requirements, is inclusive of all independently licensed professional counselors, and is respectful of the training that counselors undergo. It was designed with the intention of protecting the public. The model clearly stipulates that portability is contingent upon a violation-free practice. Licensure portability for professional counselors can help the public by:

 

·        Encouraging counselors to consider relocating to areas where more than 100 million Americans live with an officially recognized shortage of mental health care professionals. Rural areas, in particular, face a documented and dire shortage of counselors.

 

·        There are approximately 7.6 million people who move to a different state each year. That number includes professional counselors who are spouses of military personnel and other families of federal government employees. Here in Northern Virginia, families are often moving with deployments every two or three years.

 

·        Helping licensing boards to better meet the needs of underserved populations such as older adults, people of color, and individuals living in poverty.

 

Due to the fact that the ACA portability model provides the least restrictive and most seamless approach possible to portability, we oppose the petition that asks the Virginia Board of Counseling to endorse NCLEP.  NCLEP is an unfounded restrictive approach that places unnecessary restrictions and barriers for professional counselors who seek relocation.  As such, it is not in the best interest of the public or counselor licensure boards.

 

As a final note, the counseling profession is currently exploring the feasibility of a single, national interstate compact to address the myriad needs of professional counselors while encompassing public protection. This approach would have many benefits including the ability to regulate tele-counseling across state lines.  Thus, there are multiple portability options for the Virginia Board of Counseling to consider beyond the restrictive NCLEP approach. Ultimately, portability can promote standardization of state laws regulating counseling. Professional counselors are struggling now. The interstate compact option is a possible avenue to accomplish portability, while we also work to standardize state regulations. As more information about the national interstate compact option becomes available in the near future, this information will be forwarded to the Virginia Board of Counseling, as well as other state licensing boards. Thank you for your service and ongoing consideration of how we can best strengthen the counseling profession, increase access to counseling services, and provide safeguards that protect the public.

 

Best wishes,

Simone Lambert, Ph.D., LPC, NCC

President, American Counseling Association

CommentID: 67728
 

10/16/18  11:14 am
Commenter: Dr. Babatunde Adekson

Support of petition and request to reinstate my LPC and CSAC
 

I am writing in support of petition 281 titled Licensure by Endorsement. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia. It is jointly proposed by four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) and will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public. Now is the time to remedy this problem. Thank you.

If it's at all possible, please encourage the board of counseling in the state of Virginia to retract my suspended status of my LPC and CSAC so I can return to practice therapy in whatever jurisdiction I chose to look for gainful employment. The license was suspended without due process. Thanks!

Dr. Babatunde Adekson

 

CommentID: 67814
 

10/16/18  11:22 am
Commenter: Christina Morris, LPC

Petition 281 Licensure by Endorsement
 

 
I am writing in support of petition 281 titled Licensure by Endorsement. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia. It is jointly proposed by four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) and will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public. Now is the time to remedy this problem. Thank you for your consideration.

CommentID: 67815
 

10/16/18  11:27 am
Commenter: Dawn McComb

Oppose
 
From what I understand the ACA has a portability plan that is inclusive of all counselors. I believe that a national standard, perhaps met through a national ciriculum should afford a national licensing process. Although CACREP might be the way to achieve that end it seems at this point that this legislature could negatively effect through discrimination a large portion of individuals beginning with those currently in school to those currently practicing. Bravo to your beautiful state for having the courage to make moves in an area that is in great need of revision but I do not feel that this proposition is the answer.
CommentID: 67816
 

10/16/18  11:30 am
Commenter: Dr. David Julius Ford, Jr.

Support for Adopting the NCLEP
 

I am a Counselor Educator and am fully licensed in Virginia and in North Carolina. As a Counselor Educator who earned his Ph.D. in a CACREP-accredited Counselor Education program in VA and began his career at a CACREP-accredited Counseling program in VA, I know the importance of having the CACREP background. I also hold my NCC credential, which is the credential that provides the foundation for your Counselor Identity.

As a Counselor Educator who is early in my career, I have moved to two different states and the endorsement process can be a grueling process. I am also sensitive to other Counselors like those who are in military families who have to move around a lot. Virginia is a leader in licensure as we are the first state to get Counseling licensure. We could also be a leader in adopting a more streamlined Endorsement process that recognizes the importance of have a CACREP foundation and having the NCC credential. As such, I am writing in support of petition 281 titled Licensure by Endorsement. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia. It is jointly proposed by four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) and will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public. Now is the time to remedy this problem. Thank you for your consideration.

CommentID: 67817
 

10/16/18  11:36 am
Commenter: Beatriz Balbontin

Petition 281 titled Licensure by Endorsement
 

I am writing in support of petition 281 titled Licensure by Endorsement. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia. It is jointly proposed by four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) and will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public. Now is the time to remedy this problem. Thank you for your consideration..

Best regards,

Beatriz Balbontin, LPC, NCC

CommentID: 67818
 

10/16/18  11:44 am
Commenter: Dr. Joseph H. Hammer

Oppose adoption of NCLEP
 

I oppose this amendment because the American Counseling Association (ACA) Portability Plan (http://www.counseling.org/knowledge-center/licensure-requirements/licensure-portability-model-fact-sheet) is better than the NCLEP.  

NCLEP would only increase the portability of licenses held by CACREP graduates (as they would not need to meet additional state requirements).  It would do nothing for the *majority of licensed counselors* who graduated from or are currently enrolled in programs that are not affiliated with CACREP – and in fact, could further limit their employment options.  Virginia needs more, not fewer, qualified mental health professional to serve the needs of Virginians.  Why hurt the job prospects of qualified mental health professionals who graduate from high-quality programs unaffiliated with CACREP?

Virginia should instead go with the ACA Portability plan, endorsed by ACA in 2016.  

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.

Thank you for your consideration,

Joseph H. Hammer, PhD, LP

CommentID: 67821
 

10/16/18  11:56 am
Commenter: Heidi Hutman, Temple University

Opposition of proposal to adopt NCLEP
 

I strongly oppose the proposal to adopt the NCLEP

CommentID: 67823
 

10/16/18  11:56 am
Commenter: Andrés J. Consoli

grave concerns regarding this petition
 

I have been a member of ACA and ACES for almost 30 years. I am a past president of WACES. As a bilingual (English/Spanish) scientist-practitioner and educator, I have grave concerns about this petition. There is ample evidence that there aren't enough licensed MH professionals to care for the most vulnerable in our society. This petition will severly and unnecessarily limited the number of qualified professionals able to practice and serve people in need. This petition does not seem in the best interest of the people of Virginia; perhaps in the interest of guild. Respectfully submitted.

 

CommentID: 67824
 

10/16/18  12:01 pm
Commenter: Michaella Beatty, NCC

In support of petition 281
 

I am writing in support of petition 281 titled Licensure by Endorsement. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia. It is jointly proposed by four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) and will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public. Now is the time to remedy this problem. Thank you for your consideration.

CommentID: 67825
 

10/16/18  12:14 pm
Commenter: Catherine Love

Allowing LPC's to be acknowledged in each state = portability
 

 
I am writing in support of petition 281 titled Licensure by Endorsement. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia. It is jointly proposed by four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) and will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public.

I am hoping that this issue/problem can be solved.

Thank you for your consideration.

CommentID: 67829
 

10/16/18  12:18 pm
Commenter: Nancy Ellmann Leonard

Thanks!
 

I am writing in support of petition 281 titled Licensure by Endorsement. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia. It is jointly proposed by four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) and will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public. Now is the time to remedy this problem. Thank you for your consideration.

CommentID: 67831
 

10/16/18  12:35 pm
Commenter: Deron Ernst, LPC TX, TN; NCC

please allow portability of counseling licenses from other states and the national certificate.
 

CommentID: 67834
 

10/16/18  12:36 pm
Commenter: Cynthia Palmaz

Portability for Counselors
 

To Whom It May Concern:

I am writing in support of petition 281 titled Licensure by Endorsement. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia. It is jointly proposed by four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) and will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public. Now is the time to remedy this problem. Thank you for your consideration. 

 

 

 

 

CommentID: 67835
 

10/16/18  12:41 pm
Commenter: Marie Paddock, LPC

Support of Petition 281 - Licensure Portability
 

I am writing in support of petition 281 titled Licensure by Endorsement. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia.   Virginia has been a leader and path forger in the clinical mental health arena and I hope this forward-thinking leadership continues with the passing of Petition 281.  I have personally known of Licensed Counselors from other states moving to Virginia and having to jump through multiple paper-trail hoops, and wait years for their credentials to be approved in Virginia.  This has put unnecessary financial and emotional strain on qualified mental health provders and their families relocating to the Commonwealth.  

Petition 281 is well thought out, simple and precise, and is jointly proposed by four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) and will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public. Now is the time to remedy this problem. Thank you for your consideration and support.

 

Marie R. Paddock, LPC

CommentID: 67836
 

10/16/18  12:43 pm
Commenter: Stephen C. Combs (Insight Psychological Services, PLLC

Counseling Portability
 

I am writing in support of petition 281 titled Licensure by Endorsement. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia. It is jointly proposed by four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) and will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public. Over the course of my experience in the counseling community I have met many counselors in Virginia who had to research the question of how their licensure would be received in other states as they contemplated relocation due to family issues (i.e., spouse transfers, etc), and similarly, for those contemplating a transfer into Virginia. Now is the time to remedy this problem and establish a uniformly accepted manner in which to recognize and easily establish the ability to continue to serve the public. Virginia is a leader in many ways, and this opportunity opens yet another door for Virginia to be the first, establishing a precedent for other states to catch up to. Thank you for your consideration.

CommentID: 67837
 

10/16/18  12:49 pm
Commenter: Julie A. Day, LPC

I support The Counselor Portability Plan
 
CommentID: 67840
 

10/16/18  12:51 pm
Commenter: Mary Feamster, Resident in Counseling

Support for Petition 281/ Inclusion of the NCLEP
 

I am writing in support of petition 281 titled Licensure by Endorsement. This measure will increase access to care at a critical time.  Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia. It is jointly proposed by four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) and will play a vital role in addressing the portability problem that faces the profession while protecting the public.  Thank you for your consideration.

CommentID: 67841
 

10/16/18  1:11 pm
Commenter: Joan Normandy-Dolberg, LPC

Support for Petition 281
 

I am writing in support of petition 281 titled Licensure by Endorsement. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia. It is jointly proposed by four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) and will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public. Now is the time to remedy this problem. Thank you for your consideration.

CommentID: 67843
 

10/16/18  1:11 pm
Commenter: Blake Steagall, LPC

Support of National Counselor Licensure Endorsement Process
 
I am writing in support of petition 281 titled Licensure by Endorsement. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia. It is jointly proposed by four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) and will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public. Now is the time to remedy this problem. Thank you for your consideration.
CommentID: 67844
 

10/16/18  1:15 pm
Commenter: Valerie Mitchell, Living Well Counseling

NCLEP Endorsement
 

I am writing in support of petition 281 titled Licensure by Endorsement. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia. It is jointly proposed by four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) and will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public. Now is the time to remedy this problem.

CommentID: 67847
 

10/16/18  1:18 pm
Commenter: Karen Beth Johnston-Sabat

LPC
 
I am writing in support of petition 281 titled Licensure by Endorsement. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia. It is jointly proposed by four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) and will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public. As a military family life counselor, this change would allow me and many others to provide services to military personnel and their families in locations across the country. Thank you for your consideration.
CommentID: 67848
 

10/16/18  1:37 pm
Commenter: Janice Lebron, HRCPI

Counseling Portability
 

 

Portability makes sense. Not allowing it limits the opportunity for Hampton Roads to gain clinical talent. This is a highly transient area due to the many military bases. Once Professional counselor spouses leave when family member separate from the military, and leave the area, that talent leaves too.There aren’t enough providers to go around especially those that specialize in children and military populations. I provide services on based as well as in private practice. Military bases have difficulty recruiting counselors and often operate at a deficit. Portability makes sense. 

 

CommentID: 67852
 

10/16/18  1:53 pm
Commenter: Carolyn Hersh, LPC

Portability for Counselors
 

I am writing in support of petition 281 titled Licensure by Endorsement. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia. It is jointly proposed by four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) and will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public. Now is the time to remedy this problem. Thank you for your consideration.

Carolyn Reed Hersh, LPC (Virginia)

 

 

CommentID: 67853
 

10/16/18  1:56 pm
Commenter: Camille Karcher, LPC

I support petition 281 Licensure by Endorsement
 

I am a Licensed Professional Counselor in Virginia and am wanting to improve client's access to care. I am writing in support of petition 281 titled Licensure by Endorsement. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia. It is jointly proposed by four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) and will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public. Now is the time to remedy this problem. Thank you for your consideration.

CommentID: 67855
 

10/16/18  2:40 pm
Commenter: Professor and Clinical Supervisor

Strongly opposing the proposal to adopt the NCLEP
 

While the underlying goal of creating a path that facilitates portability for licensed professional counselors moving to Virginia is admirable, the NCLEP does the opposite and sets a dangerous precident for the field of counseling. Furthermore, it has to potential to overburden an often overwhelmed mental health system by limiting the number of providers.  It should be noted that  the American Counseling Association (ACA) , the worlds largest association exclusively representing professional counselos, declined to endorse the NCLEP. In turn ACA developed their own portability plan that avoids the dangerous ptifalls associated with the proposed NCLEP portability plan.  I have had former students and supervisees licensed here in Georgia (which has a stringent licensure process) move to Virginia. They have all been very successfull as each are competent mental health counselors. They love working and living in Virginia. Adopting a measure such as this would eliminate eliminae qualified professionals such as these from prusueing a career in Virginia. 

CommentID: 67860
 

10/16/18  3:30 pm
Commenter: Arpana G Inman

Oppose proposal to Adopt the NCLEP
 

The NCLEP proposal continues to be restrictive and favor CACREP only graduates. HRSA report of 2015 clearly notes the need for more counselors; further there is no evidence that CACREP graduates are more competent than non-CACREP graduates. Please consider the already great health disparities -- Oppose the proposal to adopt the NCLEP in VA

CommentID: 67861
 

10/16/18  4:11 pm
Commenter: Leta Sharkey, MS, NCC, CDMS, CRP, CLCP, MSCC

Support of Petition 281 Licensure by Endorsement
 

I am writing in support of petition 281 titled Licensure by Endorsement. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia. It is jointly proposed by four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) and will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public. Now is the time to remedy this problem. Thank you for your consideration.

Leta Sharkey, MS, NCC, CDMS, CRP, CLCP, MSCC

CommentID: 67863
 

10/16/18  4:23 pm
Commenter: Amie Manis, Capella University

Promote Accessible Mental Health Care with Licensure Portability for Counselors
 

I am writing to register my support of petition 281 - Licensure by Endorsement. The need for accessible, professional mental health care has never been more clear, or more critical. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia.

Four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) have proposed a resolution to the challenges and barriers for counselors and the clients they could serve. They will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public. Acting now is urgent!

Thank you for your consideration.
 

CommentID: 67865
 

10/16/18  4:47 pm
Commenter: Johanna Nilsson

Oppose the NCLEP proposal, it can have serious consequences on the field
 

CommentID: 67866
 

10/16/18  5:27 pm
Commenter: Beth Henry

Please streamline the portability standards
 

I am writing in support of petition 281 titled Licensure by Endorsement. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia. This measure would make it easier for qualified counselors to practice in this state and increase the mental health resources available to Virginia residents.

It is jointly proposed by four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) and will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public. Now is the time to remedy this problem. Thank you for your consideration.
 

CommentID: 67868
 

10/16/18  6:24 pm
Commenter: Dr. Anne Cornell

Please vote yes
 

I am writing to register my support of petition 281 - Licensure by Endorsement. The need for accessible, professional mental health care has never been more clear, or more critical. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia.

Four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) have proposed a resolution to the challenges and barriers for counselors and the clients they could serve. They will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public. Acting now is urgent!

Thank you for your consideration

CommentID: 67870
 

10/16/18  8:54 pm
Commenter: Sataunya Greer, BCC, MA

Vote Yes
 
am writing in support of petition 281 titled Licensure by Endorsement. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia. It is jointly proposed by four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) and will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public. Now is the time to remedy this problem. Thank you for your consideration.
CommentID: 67873
 

10/17/18  1:37 am
Commenter: MARY E KIRKPATRICK, Resident Counselor, Phoenix Counseling

Portability is Essential
 
I am writing in support of petition 281 titled Licensure by Endorsement. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia. It is jointly proposed by four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) and will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public. Now is the time to remedy this problem. Thank you for your consideration.
CommentID: 67877
 

10/17/18  2:04 am
Commenter: Christine Currie, New Hope Counseling Services, LLC

In support
 

I am writing in support of petition 281 titled Licensure by Endorsement. Inclusion of the NCLEP into the endorsement rules will pave the way for a simple, clear, and reasonable portability path for counselors in Virginia. It is jointly proposed by four leading counseling organizations (AASCB, ACES, AMHCA, and NBCC) and will play a vital role in addressing the portability problem that faces the profession by increasing access to care while protecting the public. Now is the time to remedy this problem. Thank you for your consideration.

CommentID: 67878
 

10/17/18  7:02 am
Commenter: Michelli Simpson

Portability
 

I believe portability is one of the first step recognizing the importance of mental heath professionals within the community. We represent a key factor in changing stigma and keeping our community healthy. However, such role is not respected or taken into consideration when the professional is moving to other state. Our profession has evolve but the behavioral board needs to evolve also. I fully support he portability. It is a great step and it will be an example to the other states e board. 

CommentID: 67879
 

10/17/18  7:49 am
Commenter: Danielle Holmes

Oppose
 

I love the idea of portability for counselors and typically support NBCC policies but I greatly disagree with this policy as I believe three years is too long. Especially if someone gets licensed in one state and is forced to move unexpectedly elsewhere and have to start again. Personally I value the current 2 year endorsement policy.

CommentID: 67881
 

10/17/18  7:50 am
Commenter: Mary Ann St John

Licensure in VA by endorsement
 

I was recently licensed in VA by endorsement. I have been licensed as a LPC in SC for 5 years, working in private practice and in an outpatient hospital setting. I did not graduate from a CACREP school (the University was going through the credentialing process while I was a student and they now are CACREP appproved). I met all the other requirements listed in the NCLEP proposal, had to provide proof of such. and I am pleased to say that it was a seamless process.  I was expecting at least a 2-3 month wait, but I had my license in 2 weeks. 

I do endorse the NCLEP proposal!

CommentID: 67882
 

10/17/18  8:42 am
Commenter: Thom Field, PhD, LPC

In support of NCLEP adoption
 

I am a counselor educator, and licensed professional counselor in Virginia (0701005508). I graduated from two graduate counseling programs in Virginia (Lynchburg College, James Madison). I am in full support of adopting NCLEP portability provisions in VA. NCLEP represents the collective efforts of all major counseling organizations (AASCB, ACES, AMHCA, NBCC) besides ACA. The portability requirements represent a common standard among states that have very different regulations. Virginia is known for having among the highest regulations for the counseling license, and adopting the higher standards of the NCLEP (e.g., three years of post-license experience) makes good sense for Virginia. - Thom Field

CommentID: 67883
 

10/17/18  9:07 am
Commenter: Lydia P Buki, PhD

Oppose
 

I applaud the state of Virginia for trying to deal with a critical problem--the shortage of adequately prepared mental health professionals at the master's level to address the needs of the state's constituents. However, I submit that this proposed rule may not be the best answer. By being overly restrictive, it would actually limit the ability of qualified counselors to cross state lines. It should be noted that the ACA has not endorsed this proposed rule. By opposing this rule, an opportunity would be created for a long-term solution that will actually do what it is intended to do, rather than privilege the education and experiences of a few in the short term.

CommentID: 67885
 

10/17/18  9:08 am
Commenter: Kathleen Edelen, LPC in Private Practice

Support Licensure Portability for Professional Counselors
 

We live in a culture where one spouse/partner is transferred for work and the other needs to follow, where the birth of grandchildren, the care of elderly parent, or semi-retirement causes a move to a different state, where some of our practice locations are near state borders.  To prevent licensed therapists from continuing practice across state lines is akin to holding them hostage.  Please vote for an easy way to continue practicing even when a relocation occurs.  Vote to approve license portability.  

CommentID: 67886
 

10/17/18  9:11 am
Commenter: Willard Vaughn, LPC

Support. Please ratify
 

I am in support of any legislation that makes the process and reciprocity easier for professionals that have earned it. 

CommentID: 67887
 

10/17/18  9:26 am
Commenter: Robert Castle, LCPC and Clinical Supervisor

Strongly Oppose the NCLEP standard
 

While the underlying goal of creating a path that facilitates portability for licensed professional counselors moving to Virginia is admirable, the NCLEP does the opposite. It creates a restrictive precident for the field of counseling in VA, and perhaps other states, that also could overburden the country's mental health system by limiting the number of providers who can transfer between states. 

Informed and thoughtful legislators should take note that the American Counseling Association (ACA) , the worlds largest association exclusively representing professional counselors, declined to endorse the NCLEP. 

The ACA developed their own portability plan that avoids the dangerous ptifalls associated with the proposed NCLEP portability plan. This includes removal of the CACREP education standard. Many seasoned professional counselors obtained their masters in counseling degrees long before CACREP accrediation was available, or from institutions that had legitimate reasons for not pursuing a CACREP endorsement. Adopting the NCLEP standard would prevent these licensed professional counselors from moving to Virginia, with their years of valuable clinical experience, which would undermine the goals of portability and increasing license mental health providers. 

 

CommentID: 67888
 

10/17/18  9:33 am
Commenter: Blaine Fowers, Ph.D.

Strongly oppose NCLEP
 

I strongly oppose the NCLEP plan. It is not a simple licensure portability plan. Rather, it provides portability only for the segment of licenced counselors who attended CACREP approved programs. This is unacceptable becuase there are many high-quality counselor training programs that have chosen not to seek CACREP accreditation. I teach in one such program at the University of Miami. Some of our graduates want to practice in Virginia. Their licensure portability should not be blocked or impeded by this initiative. This is an unacceptable guild initiative that constitutes restraint of trade.

CommentID: 67889