Virginia Regulatory Town Hall
Department of Health Professions
Board of Counseling
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]
Action Requirement for CACREP accreditation for educational programs
Comment Period Ended on 7/1/2015
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6/1/15  3:43 pm
Commenter: Nick B, LAC/Addiction 3 states, 3 Licenses, Trainee in 4 methods of therapy

OPPOSED : CACREP Only is a shot in the dark attempt at nothing

Hello VA etc.

In comparing humans to the animal world, there are 3 types of people I see in society : Those that when they see another animal licking their wounds they either let them have their healing time and keep moving forward, they stop and help them out, or the get hungry.  This last one is what I see happening in the cacrep only movement.  Its motive is not to mind our own or to help others, it's to feed off the wounded, the vulnerable adults who repeatedly request better treatment of our profession.


We shouldn't have to be having this conversation or beg for sanity here.  While a part of me wants an accreditation standard for the usually outlined reasons (of uniformity, ease, credibility or whatever), there is not one REASON (or a collection of them) at all that trumps the underlying and overt negative consequences to people without cacrep titles in their future (as already seen in public treatment).  The greater part of me cares about the greater part of reality and the humans involved.  


The grandfathering or other currently shown fallback solutions are a joke, not even close to preparing for or preventing undue harm.  Without the thousands of non-cacrep individuals who founded the counseling field, cacrep would not exist.   Then you/they don't mind if you enable/promote the slaughtering of professional stature that the non-cacrep people go through? 


If a state is geared toward helping people find work (or let's say survive and not be homeless in school debt), then the limiting of several credible excellent educational backgrounds to one quasi-effective standard is not the way to go.  It seems absolutely pathetic that we have to have this conversation.  Our profession is jumping the gun to think it's found the "perfect" standard of which to ruin the majority of the lives of our professional framework.  Cacrep and similar education doesn't train us to be therapists, it's pulled together 60 credits to compete with social workers, and our 60 is dead weight after 42 credits, it's nothing special as I saw going to a cacrep-like institution.  I'd rather not have a profession than to have one that prides itself on covert exploitative capatilization, divisive rhetoric, and one that has the potential to destroy lives, as it has mine to a large degree, regarding the financial struggle in dealing with paranoid board systems that need me to offer a cavity search since I did not go to Cacrep.  


I got a 90 percentile score on our NCE national test (in a pool of ALL POTENTIAL SCHOOLS), a 4.0 gpa in school, I have thousands of extra hours of learning / training due to my own explorations of the field and paying for legitimate hands on trianing that school doesn't provide from any of our current education, I have a BS in psychology of which my 40+ credits there were basically copied by CACREP, and for what?  To sit there and fill out paperwork for you that think there are provable uniform ways to cut people down in to a category of professional education standards, FOR COUNSELING?  Where is the DATA ?   Your proposal to cut it to one acts as if there is HARD PROOF that Cacrep would save the multitudes.  None exist. The states want us to practice evidence base counseling, yet this politicing stuff has no research behind it.  These contradictions seem to show disregard of your own regulations.

Oh yes, and does anyone care about the social ramifications of our jobless, struggling country?  Or why do degrees mean NOTHING like a plague in our society?  It's because of these movements argued herein.  Need I go through more work than a brain surgeon and get paid 10% of what they earn?  And now have it be even more difficult?


You need to think about how you can create a class of accreditations and school types, rather than 1 type of school.  Our profession has developed far too many professionals over far too many years to cut it down now to one type.  It's too late.  We're too far ahead, the ship is already docked in a station full of a lot more options than the CACREP and we are not able to handle turning around. It seems way too foolish and negligent to ignore this issue.  It's terribly difficult to watch people argue for CACREP Only.  Cacrep of a half dozen comforting options is about what's fair and decent, reasonable, safe etc.  Why would so many states not already do it?  Do you think VA or OH is so brilliant, you really thought of something that the other states didn't since the 1970s, the start of counseling as a profession?  Does anyone worry of what pride, what blasphemy, what shameless tarnishing neglect of people is going on here?


I also echo what was written by the help of leaders of the CCC movement at leave no counselorbehind.

Nick B, LAC/Addiction 3 states, 3 Licenses, Trainee in 4 methods of therapy

I'm pasting a few points from CCC

? The majority of non-CACREP programs in this country are also regionally
accredited by CHEA and must maintain high quality standards.  This sentence
implies that non-CACREP programs are usually not CHEA accredited and are

?One of the goals of CACREP is to establish a uniform set of educational
requirements across the United States to facilitate portability of licensure
from state to state.?

? True, but other methods of state-to-state portability would include an
interstate agreement between the member Boards of AASCB, a simple choice to
recognize out-of-state licensed counselors, or even CACREP-equivalent
coursework and preparation.

?Three federal agencies have made graduation from a CACREP accredited
program a requirement for independent practice in counseling.?

? This is not a reason to make the same mistake elsewhere.  Such
requirements place a burden on counseling business owners and on clients who
are looking for easy access to counselors in their communities.

?With a large military presence in Virginia, there is a need to equate
graduation from a CACREP-accredited program with licensure to avoid public
confusion and give licensees access to federal agencies.?

? This is exactly what should NOT happen for the good of both counselors and
the public. Thousands of competent seasoned non-CACREP counselors throughout
Virginia face increasing public confusion as to their competence.  A public
which expects CACREP (despite no evidence of its superior quality) will
start demanding CACREP and start discriminating against counselors without
this accreditation in their past.  This will result in lack of employment
for non-CACREP counselors even in situations where they are licensed and
eligible to help with our burgeoning mental health community needs.  The
likelihood of public confusion of CACREP with license eligibility and with
competence is exactly why grandfathering provisions for non-CACREP
counselors fall short of acceptable.

?The Board of Counseling has found that it has neither the resources nor the
expertise to examine counseling programs across the country to assess the
quality of the education in that program.?

? Plenty of Boards across the country do just this.  They typically require
regional CHEA accreditation (for quality) and then require coursework in a
variety or required categories.  Sometimes they choose to look for
?CACREP-equivalency?.  When state Boards cede control of their standards to
an outside entity they lose control over serving the needs of their state
constituents.  Furthermore, several professions have two or more recognized
accrediting authorities.  With variety comes a greater opportunity for a
diversity of training to ensure a flexible and responsive (counseling)
workforce for the unique needs of individual clients.  The Virginia Board
might also avail itself of discussions amongst the various state Boards at
the AASCB association ? in which case it could at least have a strong voice
in whatever national standards are enacted for standardization and license

?Consistency and quality in educational preparation for professional
counselors will provide greater assurance to clients seeking their services
that they have been adequately prepared and appropriately licensed to
protect public health and safety.?

? CACREP advocates have created a mostly false narrative of a public
endangered by poor quality counselor preparation.  No doubt they can find
isolated examples of such.  There is no epidemic of poor quality counselor
preparation ? controls and standards are already in place to protect the
public without locking down the profession to one privately controlled

Requested Public Participation in the NOIRA: The agency is seeking comments
on this regulatory action, including but not limited to 1) ideas to be
considered in the development of this proposal, 2) the costs and benefits of
the alternatives stated in this background document or other alternatives
and 3) potential impacts of the regulation. The agency is also seeking
information on impacts on small businesses as defined in ? 2.2-4007.1 of the
Code of Virginia. Information may include 1) projected reporting,
recordkeeping and other administrative costs, 2) the probable effect of the
regulation on affected small businesses, and 3) the description of less
intrusive or costly alternatives for achieving the purpose of the

Costs of the NOIRA proposal include the nearly $4500 in program application
fees, and $2600+ annual maintenance fees charged to each CACREP accredited
program (see their website] edited)
which are paid for in some fashion by state school budgets, counseling
students, and ultimately the public. Costs are also paid in terms of
flexibility of curriculum in a field with MANY theories of psychology, loss
of employment opportunities in CACREP programs for educators with slightly
different qualified backgrounds than Ph.D.s in counselor education, and
locking counseling psychology graduate students out of future licensure for
no discernable reason related to competency to the public good. The future
effects of CACREP on small businesses are murky and troubling. Many
counselors in private practice are sole proprietors or at small clinics
which would qualify as small businesses.  In the short-term under this
proposal, these non-CACREP counselors will continue to be licensed and new
graduates will be license-eligible until 2022.  However, the CACREP-only
push creates a false perception of CACREP quality that is likely to impact
these small businesses in the future.  The public may look for CACREP
graduates in the false belief that they are more qualified.  Government
programs (and private insurers?) may follow the bad TRICARE example and
start requiring CACREP for licensure.  Employers may start only hiring
CACREP graduates.  There is a potentially devastating longer term effect on
small clinics and sole proprietors at risk of being cut out of the market.
To the extent that non-CACREP counselors are cut out of the market, the
public may experience counselor shortages or have to settle for newer
counselors with less experience. Other Points: A careful look at the data
will reveal that counselors who have graduated from CACREP programs are not
more effective in their work with clients or in their service to their
communities. A regulation limiting practice will not serve the people of
Virginia well given that a majority of master?s level counselor training
programs in the USA are not CACREP-accredited. A regulation limiting
practice will not serve clients in Virginia given that the majority of
currently practicing counselors graduated from schools free of CACREP
accreditation. A restriction such as this would negatively impact current
students and alumni from non-CACREP affiliated VA programs; negatively
impact the public by reducing access to qualified counselors; negatively
impact relocation of qualified and competent counselors from non-CACREP
programs; reduce overall services available to VA residents; and increase
cost of graduate education. Even the American Counseling Association (ACA),
the largest national counseling association, opposes the CACREP-only
restrictions highlighted in the rationale for this regulatory change. The
people of Virginia need a strong Board that protects their rights to access
quality mental health care.



CommentID: 39978