I strongly urge you to stop the egregious efforts to limit and grant Virginia's Professional Counselor licensure to CACREP-only applicants. This proposed regulation, if approved, will falsely imply that CACREP graduates are more effective than other well-trained and well-qualified graduates of professional counselor training programs.  To date, there is no empirical evidence that CACREP graduates are better prepared or more effective than other excellently trained counseling master-level graduates.  

Furthermore, a licensing board making determinations for prospective applicants on a single accrediting body, has effectively relinquished their authority (CACREP)to an outside body that is not answerable to the public, and over which the board has no control. Please be mindful that there are other paths to accreditation of counseling programs. For example, the Masters in Psychology and Counseling Accreditation Council (MPCAC) accredits counseling programs and requires programs to meet professionally agreed upon standards that reflects (and in some domains exceeds) the rigor of CACREP standards. 

Also, consider the detrimental effect on Virginia's mental health consumer in that the proposed regulation would reduce choice and access by consumers to affordable mental health care. This would impact grossly underserved Virginia citizens and their communities the most.

I urge the Commonwealth of Virginia NOT to approve this change in regulation. Rather, I strongly believe that Virginians will be best served by a diverse body of LPCs, and not only those with degrees from programs affiliated with CACREP.

Sincerely,

Peggy Farrelly, Ph.D.