As the Chair of the Department of Psychology at Radford University, I am writing on behalf of our former, current, and future students to express my opinion about the necessity and urgency for the board to establish clear and consistent guidelines regarding the educational requirements for the LPC and to improve the transparency of the process whereby applicants are approved to sit for the LPC.
Several points seem particularly important:
I believe that the board has the responsibility to make a determination on whether the philosophical distinction between counselors and psychologists is so great that it will exclude graduates from psychology programs from being eligible for the LPC. Additionally, it is also clear to me that the board has the responsibility to assure that the guidelines are so explicit that there will be no question to the programs, or to the students entering and graduating from the programs, as to whether their degree will include or exclude them from being LPC eligible in Virginia. Clearly the lack of clarity has caused considerable concern and debate, and thus I encourage the board to act quickly and put the confusion to rest. I offer three possible options for the board to consider.
One option would be to simply require that all students must graduate from a CACREP accredited program, period. If the program meets the standards set forth and enforced by CACREP, then the licensing board could remove section B of the regulations which suggests that graduates from other programs would potentially be eligible. That would end the confusion. Programs that are not CACREP accredited would then know that they either have to become CACREP accredited, or let students entering their program know, in no uncertain terms, that they will not be eligible for the LPC in Virginia under any circumstances.
A second option would be that no students who have graduated from any program housed in a Department of Psychology would be eligible for licensure, regardless of whether the program is CACREP accredited or not. Period. Needless to say, this option would create problems for programs such as JMU, which is CACREP accredited, housed in a department of psychology, and has several psychologists as identifiable counselor training faculty.
A third option would be to operationally define “counselor training faculty”, based on objective and measurable criteria rather than on subjective interpretations of this highly ambiguous term. As the regulations currently read, neither programs nor individual faculty members have any way of assessing whether or not the faculty or the program meets the regulatory guidelines. As another individual previously questioned, “Do the faculty have to have graduated from a Counseling Program in a Department of Education? Can the faculty have graduated form a Counseling Program in a Department of Psychology? Do the faculty have to have their LPC? Any or all of these would represent objective criteria that would remove the ambiguity of language which seems to be at the core of the problem. I urge you to remove the ambiguity from the language currently used in the regulations. This lack of clarity has led to considerable hardship for many graduates from such programs as evidenced by many of the postings to this petition. This lack of clarity also provided the impetus which led to the current petition. If graduates from a program are denied the opportunity to sit for the LPC in Virginia because their program did not have “a sequence of academic study with the expressed intent to prepare counselors as documented by the institution,” then the board must make explicit how this can be documented. Presumably, a sequence of academic study with the expressed intent to prepare counselors would be evidenced by the program description listed in the University’s Graduate Catalogue and the Program’s Mission statement posted on the Department’s website. If a program explicitly states that its intent is to prepare counselors and it has a sequence of academic study that directly maps onto the coursework dictated by the regulations, then presumably the program has met this criterion. If such evidence is not sufficient, what specific type of evidence would be necessary?
In conclusion, regardless of which option it ultimately chooses, I urge the board to act with speed, with clarity, and with due consideration for the students, faculty, and alumni of Virginia university graduate programs. I also request that, regardless of how the criteria are settled and clarified, serious thought be given to the option of grandfathering in the many individuals who have been most hurt by changes in the LPC eligibility regulations..