At a time when the COVID-19 Pandemic has taught us that telehealth and license portability are critical to solving provider shortages, Virginia should be trying to create an easy to understand and streamlined licensure criteria to allow telehealth across state lines. When these conversations started, we did not have a national provider shortage, triggered by a secondary mental health pandemic, now that we do, our policies should be inclusive and allow the efficient portability of all counselors with three years of experience. The differentiation of CACREP versus non-CACREP counselors, and the punitive 10 year experience requirement for non-CACREP counselors, is not equitable and not justifiable based on the literature. This would exclude many of the graduates of Johns Hopkins from easily transferring their license to the Commonwealth, which has only had CACREP accreditation for 5 years, but is reputably one of the best programs in the US. Virginia should be modeling its regulations on the developing Counseling Compact and not diverging from this wise movement to eventually allow national telehealth portability. 

The Alliance for Professional Counselors (APC), a national organization of counselors and counselor educators that supports interdisciplinary cooperation and licensure portability, remains strongly opposed to a specific provision in the Virginia Board of Counseling’s proposal for licensure by endorsement that we objected to in 2019.

We particularly object to the provision that would permit licensed counselors who graduated from programs accredited by CACREP to qualify for licensure in Virginia with 3 years post-licensure experience while licensed counselors who graduated from programs that are not affiliated with CAREP would need 10 years post-licensure experience to qualify for licensure in Virginia. There is NO evidence to support this proposed discrepancy.

Furthermore, this proposal would harm the public by unnecessarily limiting the number of licensed counselors who would qualify for licensure (and therefore professional counseling work) in Virginia. This proposal would also harm the majority of licensed counselors who graduated from programs that are not affiliated with CACREP by making it seem, despite lack of evidence, that they are less qualified. We call your attention to the two successive Virginia Economic Impact Analyses (2016, 2017) for further information. Furthermore, as Virginia has historically been a leader in the profession, this proposal could set a negative precedent.

We fully respect that these decisions are within the purview of the Commonwealth of Virginia. However, APC asks your consideration because these proposed regulations are determinantal to the citizens and economy of Virginia – and have national implications. In our view, the Counseling Compact is a significantly better option for portability than the current (or previous) proposals.

Only people ignorant of therapy practice would assume cacrep does anything influencing the quality of therapist to the degree Virginia is trying to infer with the difference of requirements. Try looking at additional certificates of practice with quality of requirements like 2-4 years of training and supervision in addition to a license. EMDR, Brainspotting, prolonged exposure, psychodrama all took me years to earn with high level PhDs and we all see terrific therapeutic outcomes. All clients pay high dollar for these specific services. I don’t have a cacrep. Nobody who trains these certificates cares or even mentions cacrep. Anyone without those certificates have no clue what value they add to a practice. I can tell Virginia that if they did have a clue, they’d not make a cacrep the defining difference. I could easily outshine any recent graduate in skill level for years to come until they get the added value of advanced certification. This is the difference between a PA and a doctor with ten years surgery experience at a trauma center John Hopkins. Virginia is unaware enough to not know the difference or they’d even prefer a PA over the doctor because of their bachelors program. It’s nothing short of pure ignorance to try to infer such meaning from cacrep. The most important work is field training and advanced certification 

I have been licensed as a Professional Counselor in Virginia for 40 years, having graduated before CADREP existed.  I urge the Board to not adopt regulations which require 3 years of experience for those graduating from a CACREP program vs. 10 from other colleges and Universities before licensed by endorsement.  Only as I have been practicing for so long, and been a leader in the field (president of the state of Virginia affiliate of AMHCA), long term membership in ACA and AMHCA, do I know of the development of CACREP.  Were I a recent college graduate, seeking graduate school admission, I might not even know of CACREP to use it as a screen for application.  The current regulations screen effectively without adding a very biased 10 year requirement.  Further, there is no evidence of which I am aware which would allow the equating of 3 years of experience of a CACREP graduate with 10 of one from a different credentialing graduate program.  I would propose the Board instead adopt the Counseling Compact, which I know many of the Board members are following.  For those not familiar, I urge you to review the writings on the Counseling Compact by Counseling's national representation associations (ACA and AMHCA).  Now that all 50 states license counselors licensure by endorsement is in order and equitable measures from all 50 states is preferable.  Thank you for considering my point of view.  

There is zero (ZERO) evidence that training in CACREP programs is superior, leads to better trained professionals or better outcomes for patients and clients.  However, there is plenty of evidence of CACREP'S consistent and nonrelenting pressure to mislead legislators and consumers into believing that their brand is superior.  This is another market grab by CACREP that should be denied. They want to corner the market in training and mental health care. Please vote down this ridiculous proposal.

Dr. Fuertes 

The proposed move to require an additional 7 years of training for graduates of non-CACREP programs is based on a highly flawed and unsupported notion. If the Non-CACREP training programs meet the State educational requirements and the graduates of these programs demonstrate competence during the standard period of evaluation, then what is the sense of unnecessarily burdening these mental health providers  with an additional time requirement.  This seems like a shameless ploy to disenfranchise all non-CACREP training programs, many of which are not eligible for accreditation due to arbitrary reasons (e.g., too many clinical psychology affiliated faculty teaching courses and not enough with "counselor identity").  

The Counseling Compact is a significantly better option than this proposal!

The erroneous misconception that CACREP is the only accreditation body capable of designing or judging a rigorous counseling program is discriminatory, shortsighted and without merit. There are many universities in the nation that are recognized by regional and national accreditation bodies that have programs that are far better or at least as good as the standards put out by CACREP.

By discriminating against the students who attended those schools, you deprive the community of some of the best and most experienced therapists in the country.  You also heavily lean into age discrimination.  When I attended my Masters in Counseling Psychology program, my program far exceeded the number of classes and hours that were then required by CACREP,  which was a fledgling organization trying to corner the market in counseling education accreditation. They've largely succeeded in doing that by putting forth the notion that their programs produce "more ethical" and better educated counselors. That is simply untrue.  The behavior of the ACA during a recent election where they shut down pre-election comments is indicative of a group who wants to silence the majority of all counselors who graduated before CACREP even existed. CACREP, ACA and NBCC seem to have worked together in a highly questionable way, by structuring tests and counselor demographic/opinion/practice questionnaires in such a way as to diminish well educated and highly skilled, respected and qualified therapists. It's my understanding that one of the NBCC licensing tests was recently pulled because it lacked the normative, rigorous research required for standardized tests.  It's also my understanding that a recent head of NBCC was asked to step down because of highly unprofessional conduct and that the NBCC actually lost its ability to accredit continuing education programs for a time.  The 3 aforementioned entities seem to have set up a "you scratch my back..." arrangement that enriches them all, reduces educational choice, deliberately controls outcomes on testing and that attempts to shut out the majority of counselors in the field today.  

The ACA recently had an opportunity to break the glass ceiling of getting Masters level counselors approved by the VA, which we all know is serving combat veterans who are killing themselves at never before seen rates because they don't have adequate access to mental health care in a timely manner.  For most of modern history the VA only used Social Workers, who practice counseling but are not trained as counselors. There is some overlap in skillset but the training, almost complete lack of psychological theory classes, and basic theoretical foundations are entirely different.  Given this marvelous opportunity to improve the conditions for veterans everywhere, the ACA struck a deal with the VA that excluded all of the older,  most experienced counselors in favor of CACREP trained counselors, who again, do not represent the majority or the best.  I believe this was yet another self-serving move to corner the market in counseling education. 

I believe the attempt to punish and exclude non-CAPREP counselors, constitutes violation of anti-trust laws.  Discriminating against non-CACREP therapists violates anti-age discrimination laws and possibly violates the rights of faith-based colleges and their graduates since CACREP promotes positions that are not necessarily shared by faith-based counselors. Such colleges should feel free to pursue regional accreditation and opt out of CACREP without diminishing their students' ability to make a living. 

This proposal 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 evidence that CACREP program graduates are better trained than the graduates of other programs. Also, licensed counselors who graduated from MPCAC accredited programs would be treated as second-class citizens as a result, which is inappropriate as both CACREP and MPCAC are accredited by CHEA and thus programs accredited by CACREP and MPCAC are meeting similar standards, and their graduates should be held to the same kinds of licensure rules.

This proposal should be rescinded due to the above problem and, instead, the State of Virginia should pursue the Counseling Compact.

There is zero (ZERO) evidence that training in CACREP programs is superior, leads to better-trained professionals or better outcomes for patients and clients. 

However, there is plenty of evidence of CACREP'S consistent and unrelenting pressure to mislead legislators and consumers into believing that their brand is superior.  This is another market grab by CACREP that should be denied. They want to corner the market in training and mental health care. Please vote down this ridiculous proposal. I strongly urge the state of Virginia to push towards joining the counseling compact, a more inclusive route. If the pandemic, has taught us nothing, it has taught us that accessibility of mental health professionals is essential. Passing the proposal would be ignoring that. 

This is a further attempt to push CACREP only onto Virginia counselor licensure. As others have noted, having CACREP accreditation only indicates that a program meets baseline requirements for training counselors. Programs who have CHOSEN to not pursue CACREP are often equally if not more rigorous and graduate excellent counseling professionals. This field needs more counselors, not less, and there is no evidence that those who graduate from CACREP programs are any more qualified than those who do not. To make a distinction and limit the licensing based on that is inequitable. 

To add to what another commentor mentioned - I graduate with my MA in Counseling in 1993 - long before CACREP had increased their requirements to 60 credits and before most programs even thought of anything but regional accreditation. This not only punishes those who graduate now, but those who graduated years ago. 

This field and our state needs to be more inclusive not exclusive. 

I add my strong opposition to the the current proposal that would unfairly and discriminatorily penalize professionals who graduate from non-CACREP-accredited programs. This proposal is not based on any scientific data that suggests licensed counselors educated in CACREP-accredited programs are in any way better prepared, trained, or equipped to serve in their roles than those from non-CACREP-accredited programs. Moreover, adding superfluous obstacles to those who graduate from other programs is unnecessary and ultimately penalizes both those who graduated from non-CACREP-accredited programs and the Virginians they serve.

I am disturbed beyond words that you feel that graduates of any university that are not accredited by CACREP are somehow not worthy of practicing in the state of Virginia. There are many fabulous schools that provide extensive education in counseling and clinical psychology. I am enrolled in University of Baltimore and they offer an extensive program for graduate students, consisting of three years of education and internship opportunities. There are many universities offering fantastic programs in psychology as well as accrediting bodies that support and demand excellence in the field. I am not sure I understand your reasoning behind this discriminatory judgement, especially during times when people in our country desperately need counselors to help them deal with their problems. The number of people suffering from mental health issues is far greater than we have witnessed in the past. Psychology has come a long way in its methods and understanding of the field as a whole. Without counselors, people are dying needlessly as they suffer in silence. Now is not the time to be assuming that one accrediting body is superior to the others. 

Ashley Simon

To Whom It May Concern:

I'm writing in strong opposition to the provision in this law that would permit other-state licensed counselors who graduated from programs accredited by CACREP to qualify for licensure in Virginia with 3 years post-licensure experience while other-state licensed counselors who graduated from programs that are not affiliated with CACREP would need 10 years of post-licensure experience. There is no scientific evidence to support this proposed discrepancy and it is discriminatory to those who are not CACREP graduates. Most importantly, the residents of Virginia will suffer because this proposed regulation will limit the number of qualified licensed counseling professionals to serve individuals with mental health difficulties, particularly during a time of COVID when the mental health service needs are so great. Please do not pass this regulation.

sincerely,

Bryan Kim, Ph.D., LMHC

There is no scientific evidence stating that people who do not graduate from CACREP programs are any less qualified than those who do. This mandate would greatly restrict the amount of counselors who are in the mental health field at a time when practitioners are desperately needed. This is an elitist movement to discredit those who have graduated from programs that are perfectly qualified to educate counselors just because they don’t have an arbitrary badge of accreditation next to their name. Licensure requirements should be based on critical individual requirements being fulfilled by a degree program, not because it has the endorsement of an organization. This mandate cannot go through and restrict access to licensure. There is a shortage of mental health practitioners in the field and to deliberately deny perfectly qualified graduates from obtaining licensure is to the great detriment of the public that needs these mental health resources. This is an unethical mandate and should not be passed.

I am writing to urge you to reject the proposed new rule for counselor licensure, requiring graduates of programs that are accredited by organizations other than CACREP to have an additional 7 years of experience. I would like to remind the Virginia Board of Counseling that their role is to protect the public. There is no evidence to support this requirement, and it will seriously limit the availability of mental health services to Virginia residents, at a time when the need for mental health support has greatly increased. As an educator in a program that has been training counselors for responsible professional practice for decades, I cannot see this proposal as anything other than an effort by a large guild to provide its own graduates with a privileged position, at the expense of graduates of equally rigorous training programs. Please reconsider this ill-advised and clearly self-serving proposal.

Thank you.

There is no evidence that graduates from a CACREP accredited program are any more qualified than counselors who don't.  There are many universities that produce exceedingly qualified counselors, thereby invalidating the need for such a counselor to have 7 more years of experience than one graduating from a CACREP program.  In addition, by enacting such legislation, you are artificially limiting the resources and possibilities that citizens of VA have when looking for mental health help.  Not only are you limiting the options for your citizens, you are doing so during a time of greatly increased need.  Vote no on this regulation and vote for inclusion of all counselors! 

...now is NOT the time. Other commenters have raised valuable points against the merits of CACREP accreditation. To reiterate some, there is little research suggesting that CACREP accreditated counselors provide better care than non-accreditated counselors; CACREP's standards seem arbitrary and are hard to justify; CACREP does not recognize the value of counseling psychology. However, I'd like to emphasize a different aspect. During this difficult post-pandemic time, mental health practitioners are in high demand and many clinics have long waiting lists. The state of Virginia itself has a shortage of mental health providers (see here, here, here) According to NAMI, 22% of Virginians were unable to receive mental health care in February 2021. 56% of children 12-17 with depression were unable to receive treatment as well over the past year.  By requiring CACREP accreditation, these numbers are sure to increase. Any additional protection to the public that CACREP accreditation purports is likely to be canceled out by the damage of restricting the number of therapists. 

I am in full support of interdisciplinary cooperation and counselor license portability. Suggesting that licensed professional counselors who are graduates of CACREP accredited programs require only three years of post-licensure experience, whereas licensed professionals who are graduates of other counseling training program must have seven years of post-licensure experience is an example of unfounded differential treatment. This is clearly exclusionary. There is no evidence that licensed counselors from CACREP programs are better prepared than counselors who are graduates of other counseling programs. At a time of great need for mental health services in this country we should be working collaboratively across all counseling programs to train competent counselors, and facilitate licensure acquisition rather than engage in such divisiveness.

As a graduate student on track for licensure in clinical professional counseling in the state of Maryland who will actively seek to get licensure in Virginia (so I can work in the DMV), this proposal seeks to make the current mental health crisis much worse in the state of Virginia. There is no empirical evidence to support that graduates of CACREP-accredited institutions are more qualified or prepared for licensure in the state of Virginia than graduates from, say, MPCAP-accredited institutions.

With this proposal, the state of Virginia is severely restricting the number of counselors who may apply for licensure in the state of Virginia in the coming years. Why? There are only three CACREP-accredited clinical mental health counseling programs in the entire state of Maryland, none of which are in the DMV area. That means the graduates from Maryland clinical mental health counseling programs most likely to want to apply for licensure in the state of Virginia in the coming years would have to wait an entire decade to qualify.

How on earth could this be considered a solution for the current mental health crisis in the state of Virginia? Make access to licensure equitable for all qualified mental health professionals, and put this decades-long feud between the American Counseling Association (who, without evidence, insists their accrediting body is superior) and the American Psychological Association to rest.

Research has indicated that there is no identifiable difference in the preparation or competence between graduates of CACREP-accredited Counseling Programs and those from programs which did not choose to apply for this accreditation. There is no rationale therefore to create these stringent standards for graduates from the latter group. Please reconsider.

I’m writing to express my opposition to this endorsement proposal that would require licensed counselors from non-CACREP programs be required to show 7 more years of experience than their peers who graduated from CACREP programs. 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.  This proposal would harm the public by unnecessarily limiting the number of licensed counselors who would qualify for licensure (and therefore professional counseling work) in Virginia at a time when the people of Virginia need greater, not reduced, access to mental health care. 

I’m writing to express my opposition to this endorsement proposal that would require licensed counselors from non-CACREP programs be required to show 7 more years of experience than their peers who graduated from CACREP programs. 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.  This proposal would harm the public by unnecessarily limiting the number of licensed counselors who would qualify for licensure (and therefore professional counseling work) in Virginia at a time when the people of Virginia need greater, not reduced, access to mental health care. 

This regulatory action would harm Virginians, who need greater access to qualified (i.e., already licensed) counselors, not lesser access.  There is no documented evidence that licensed counselors from CACREP programs are better prepared than licensed counselors from programs accredited by other accrediting bodies such as MPCAC.  So why give special treatment and create an arbitrary caste system to one group of professionals over another?  And for anyone that cares about market access, fostering competition, and a healthy free market economy, this makes even less sense.

I’m writing to express my opposition to this endorsement proposal that would require licensed counselors from non-CACREP programs be required to show 7 more years of experience than their peers who graduated from CACREP programs. 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.  This proposal would harm the public by unnecessarily limiting the number of licensed counselors who would qualify for licensure (and therefore professional counseling work) in Virginia at a time when the people of Virginia need greater, not reduced, access to mental health care. 

I'm writing to express my opposition to the Virginia Board of Counseling's current proposal that would require licensed counselors who graduated from CACREP-accredited programs to only require three years of post licensure experience whereas licensed counselors from non-CACREP-accredited programs would require ten years of post licensure experience.  There is no current evidence that counselors graduating from CACREP-accredited programs are better prepared than their peers who graduated from other programs.  Given the immense need for affordable mental health that licensed professional counselors can provide, this proposal risks harming the public good by limiting the number of licensed counselors who would qualify for licensure (and, therefore, professional counseling work) in the state of Virginia.  

I am strongly opposed to this endorsement proposal that would require licensed counselors who graduated from non-CACREP programs to have 7 more years of professional experience than their peers from CACREP programs. There is no research evidence to support this requirement and the proposal is a highly unusual attempt to discriminate against programs not affiliated with CACREP. This proposal would harm the public by unnecessarily limiting the number of licensed counselors in Virginia at a time when there is a shortage of licensed behavioral health treatment professionals. It would also be embarrassing for the State of Virginia to impose such a discriminatory requirement.

I’m writing to convey my opposition to this endorsement proposal that would require licensed counselors from non-CACREP programs be required to show 7 more years of experience than their peers who graduated from CACREP programs. 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.  This proposal would harm the public by unnecessarily limiting the number of licensed counselors who would qualify for licensure (and therefore professional counseling work) in Virginia at a time when the people of Virginia need greater, not reduced, access to mental health care. I would hope that any policy change would stem from a data-informed position. 

As a graduate of a Virginia university (Ph.D., Virginia Commonwealth University, 2002), I am writing to express my opposition to this endorsement proposal that would require licensed counselors from non-CACREP programs be required to show 7 more years of experience than their peers who graduated from CACREP programs. 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.  This proposal would harm the public by unnecessarily limiting the number of licensed counselors who would qualify for licensure (and therefore professional counseling work) in Virginia at a time when the people of Virginia need greater, not reduced, access to mental health care. 

I’m writing to express my opposition to this endorsement proposal that would require licensed counselors from non-CACREP programs be required to show 7 more years of experience than their peers who graduated from CACREP programs. 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.  This proposal would harm the public by unnecessarily limiting the number of licensed counselors who would qualify for licensure (and therefore professional counseling work) in Virginia at a time when the people of Virginia need greater, not reduced, access to mental health care. 

There are a considerable number of alternatives (identified in other messages related to this very issue) that would add value to VA's mental health practitioner pool as contrasted with the loss of value that this proposal would create. 

I am writing to express my opposition to this endorsement proposal that would require licensed counselors from non-CACREP programs be required to show 7 more years of experience than their peers who graduated from CACREP programs. 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, particularly as there are other national accrediting bodies (e.g., MPCAC, which is a CHEA-recognized accrediting organization) that prepare students with rigorous training standards. Many MPCAC programs (ours included) meet and exceed CACREP's training requirements, with the sole exception that the Ph.D. degrees of our faculty are in Counseling Psychology rather than Counselor Education. This proposal would harm the public by unnecessarily limiting the number of licensed counselors who would qualify for licensure (and therefore professional counseling work) in Virginia at a time when the people of Virginia need greater, not reduced, access to mental health care. 

This issue has been raised (and struck down) again and again in Virginia. No evidence exists that counselors trained in CACREP programs are superior in any way to counselors trained in programs accredited by MPCAC (recognized by CHEA as accrediting science-based counseling programs) or programs that remain unaccredited but have nonetheless been graduating license-eligible counselors for many decades. Many of these programs actively choose not to pursue CACREP accreditation due to values differences or because of the discriminatory hiring practices for counselor educators only as core faculty in CACREP programs (yes, the 50% core faculty rule exists, but almost no program can afford to double its faculty to satisfy this inane requirement, which coincidentally works against a multidisciplinary approach to training and mental health care). None of CACREP's attempts to legitimize itself as the sole authority on counselor education are based in empirical fact and none are actually working on behalf of the public, which is the role of the regulatory board. At a time when mental health needs are at an all-time high, this attempt to prioritize CACREP graduates in practice (based on not a shred of evidence) is not only tone deaf, but dangerous for the mental health of Virginians who desperately need care from duly trained, licensed and experienced therapists, many of whom did not and will not graduate from CACREP programs.

I’m writing to express my strong opposition to this endorsement proposal that would require licensed counselors from non-CACREP programs be required to show 7 more years of experience than their peers who graduated from CACREP programs. 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.  This proposal would harm the public by unnecessarily limiting the number of licensed counselors who would qualify for licensure (and therefore professional counseling work) in Virginia at a time when the people of Virginia need greater, not reduced, access to mental health care. 

At a time of a crisis in mental health in our country the last thing we need is an act limiting the practice on a counselor for 7 years because they are not from a CACREP school.  Where is the evidence for such a recommendation?  It does not exist.  I actually wish that even in the accredited programs individuals would have more training.

 

I am writing to express my opposition to the proposal that would require non-CACREP programs be required to demonstrate seven more years of experience than those graduating from CACREP programs. There is no documented evidence that licensed counselors who graduated from programs accredited by exclusively one group (CACREP) are better trained or perform better than those who graduated from other programs. Especially in this time of huge mental health distresss post-COVID-19 (health care providers, first responders, educators, students, etc. etc.), in Virginia and beyond, I believe this proposal would harm the public by needlessly limiting the number of counselors who would quality for licensure (and therefore professional counseling work) in Virginia. 

 

I’m writing to express my opposition to this endorsement proposal that would require licensed counselors from non-CACREP programs be required to show 7 more years of experience than their peers who graduated from CACREP programs. 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. This proposal would harm the public by unnecessarily limiting the number of licensed counselors who would qualify for licensure (and therefore professional counseling work) in Virginia at a time when the people of Virginia need greater, not reduced, access to mental health care. 

Good afternoon,

I graduated from an CACREP Accredited University and have been in practice for at least three years now at an OMHC in Salisbury Md.  I have a Co-Worker who is equally as competent and educated as I am who has worked as a Mental Health therapist for the same amount of time but did not graduate from an Accredited program.  To allow me to practice and not her hurts the people we are here to serve in a time where we are most needed.  

Please consider opposing this limiting legislation.  

Thank you,

Tammy Kintzer, NCC, LCPC

I'm writing to express my strong opposition to this proposal that would require licensed counselors from non-CACREP accredited programs to be required to earn 7 more years of experience than their colleagues graduating from CACREP accredited programs.

There is no evidence that licensed counselors graduating from CACREP programs are better prepared than their colleagues who graduated from others. Two of my clinical supervisors graduated from non-CACREP accredited programs and their clinical acumen has been invaluable to my development as a clinician. This proposal would even further limit the number of licensed counselors available to serve Virginians in a climate where mental health services are more needed than ever. 

I graduated from a non-CACREP program.  I have been practicing since 2009 and prior to my graduation from graduate school I completed 60 credits.  Individuals who attended non CACREP program are just as knowledgeable and have the clinical skills to support clients.  This legislation will not be helpful during the current mental health crisis.

As a therapist in Maryland, I have had many clients reach out to me desperately seeking services from bordering states and Washington, DC. Many individuals have expressed not being able to find providers who have availability and/or take their insurance. By making the licensing process smooth and easy for ALL licensed providers in neighboring state could reduce the number of individuals in need of services. By requiring providers who have not graduated from school to CACREP accredited school to have 7 additional years of experience is discouraging and not a requirement that is based on facts. There is no research to support that providers who graduated from CACREP accredited school are more prepared than providers that graduated from non-CAREP accredited school. Therefore, if this legislation is passed this will be a disservice to the residents of Virginia.

Legislation that would put the credentials of CACREP-accredited practitioners over a broader portability of licensure ultimately hurts those vulnerable populations that need support the most. Unnecessarily limiting the ability to practice based on no evidence would only limit the accessibility of therapy. The state of Virginia can and should do better for its people.

As a Licensed Clinical Professional Counselor in Maryland, I received my training from a clinical psychology program that emphasized evidence based practice, understanding and promoting scientific research, and ethical best practices. This program was not CACREP accredited, yet I received a comprehensive and thorough training. While I admire some the goals of CACREP, there is insufficient evidence to support the notion that CACREP is the sole arbiter of qualified counselors. 

In this mental health crisis, when the demand for qualified therapists is higher than ever and clients are struggling to find mental health providers who are able to accept new clients, this is a very ill-advised time to pass legislation that would exacerbate this problem even more. 

CACREP only agendas are politically motivated, we need one based on data! 

Any legislation that restricts rather than broadens access to services based upon insufficient data should not go into effect. There is no evidence that clinicians from CACREP schools are better prepared than those who did not. This proposal needlessly requires people to show 7 more years of experience if they did not go to a CACREP school, in effect limiting access to services. The Counseling Compact is a better option than this proposal.

As a Mental Health Counselor in the state of Maryland who works with the College population; many of my clients are from DC, MD, VA, NJ and NY. When my clients have to withdrawal from school due to a medical reason or are returning to their home state for the summer, it is extremely difficult to find them a psychotherapist who is able to work with them long term. I want my clients to be able to establish a relationship with a therapist in their community where they can continue getting care even post-graduation. Outside of the DMV area, it is very difficult to find providers...you have no idea how helpful telemedicine has been during the past few years of the pandemic. Suddenly we were able to connect people with the perfect therapist for them, who specialized in their needs specifically, students that were restricted to their homes due to negative home lives, were still able to receive treatment. People who were inconsistent coming to therapy in person, suddenly had a 100% show rate. Moreover, there has been a great benefit to seeing the living spaces our clients are in, we are able to see just how bad their depression has become, we are able to see that they are unable to get out of bed, but still making the motivation to come to therapy because we are the only people who have not given up on them. 

Moreover, if individuals who were able to get help, no longer can receive services due to the state lines, where does that leave them? Who is going to help them? It is unethical to leave people without the care they need. Furthermore, the licensing restrictions in the VA make it really difficult for anyone with an out of state license to transfer their license over, so it sounds like VA will lose a lot of mental health care for their citizens and given the drastic increase in depression rates across America...this is not the time to pull back. 

I’m writing to express my strong opposition to this endorsement proposal that would require licensed counselors from non-CACREP programs to be required to show 7 more years of experience than their peers who graduated from CACREP programs. There is no evidence that licensed counselors who graduated from programs accredited by CACREP are better prepared than their peers who graduated from other programs.  This proposal would harm the public by unnecessarily limiting the number of licensed counselors who would qualify for licensure in Virginia at a time when the people of Virginia need greater, not reduced, access to mental health care.

Please allow reciprocity and equal licensing across the state line with Maryland. We all have many clients who work for the government and move back and forth across Maryland, DC and Virginia, and we need to offer these clients services without restrictions. All Masters level clinicians are trained and capable of working with clients in the region. Why would you put restirctions on any license from another state.

At some point in time it would be nice to come together and have one national license for all Masters level counselors. And as of this date- more than half of my clients are still being seen through telehealth.

CACREP programs were just getting started when I was in graduate school, I started graduate school in 2009. The school I went to was CACREP aligned and I had to meet the same educational requirements that were required by CACREP, at that time.

In order to get licensed you have to show proof that you took specific courses. That means if a counselor has all the required courses (60 credits) to get a license then they are qualified whether they went to a CACREP accredited school or not. Clinicians that have 60 credits and 3 years of experience have the same qualifications regardless of whether the program was accredited by CACREP.

Clinicians with more experience shouldn't be excluded because they did graduate school before CACREP was a thing. It doesn't make us less qualified clinicians. We have also done more training since licensure.

As a resident of Maryland--a state with close ties to and a border with Virginia--I and many I know will be affected as we seek mental health care close to where we work and when we must travel.  As such, I strongly oppose this proposal.  It would be unfair and discriminatory against non-CACREP program graduates. There is no evidence that licensed counselors from CACREP programs perform any better than those from other programs. This is a thinly veiled attempt by CACREP to create a cartel that would hurt the people who need qualified counselors the most. All licensed counselors should be accorded the same status and treatment. Regulators need to ensure that as many qualified professionals as possible are available to meet the growing demand for mental health therapy. This proposal will work against those goals and only cause confusion and suffering. 

Thank you.

The proposed regulation amounts to restraint of trade. Licensed counselors who'd bring knowledge and skill to VA in order to serve the public would be restricted from professional practice for 10 years post-license at a time when there are public health and labor force crises. Qualified applicants would be unable to practice, earn a living, and pay taxes in VA based upon an unproven implication that CACREP trained counselors are competent in 3 years, but others are not competent for 10 years.  Most importantly, the public would be harmed by limited access to competent counselors at a time of crisis and by limited competition. The legislature in Florida recently passed legislation to eliminate a similarly restrictive law involving the educational requirements of counselors (see FLA SB 566: Mental Health Professional Licensure).  The regulation is also unnecessary.  There is a national legislative initiative underway (with the support of the ACA and AMHCA) to establish interstate compacts with the reasonable universal license portability standard of 3-years post-license practice.  The Dept of Defense offered support for such interstate compacts to protect the spouses of active duty personnel who are harmed by restrictive trade practices.  The FTC issued a 2018 report (which cited the DoD) that is also in favor of the interstate compact as the most efficient and effective way to resolve this issue. In sum, the proposed regulation amounts to restraint of trade and is unnecessary.