As a member of the community that trains licensed professional counselors (LPC), I am writing in response to a Notice of Intended Regulatory Action in Virginia. Based on my belief in multiple paths to licensure as an LPC, I strongly oppose any regulatory change in Virginia that would limit LPC licensure to graduates of master’s programs accredited by the Council on Accreditation of Counseling and Related Educational Programs (CACREP). My stance is neither anti-CACREP nor is it anti-accreditation. Rather, the field benefits from graduates of diverse programs, benefits from multiple paths to licensure, and benefits from inclusivity of graduates from programs accredited by CACREP as well programs that are not affiliated with CACREP, such as ours at Avila University.  Please consider the ramifications of restricting trade to individuals who are equally qualified for these positions.  I have a CACREP-accredited Masters degree and believe in many of their training ideas, however passing this action would in fact limit my ability to train students in our program who want to return to their home in VA simply because our program does not have additional salary lines to hire more CACREP-trained faculty and would be faced with the choice of dropping our training program altogether, or firing and rehiring faculty to be  in compliance. All this, based on no empirical data to suggest that CACREP-trained providers are any more effective, ethical, or innovative care than providers trained in other programs who have been licensed all around the country doing the EXACT same work without a CACREP degree. 

Our non-CACREP 60 hour graduate degree in counseling requires that counselors-in-training have course work in biological bases of behavior. With the continual evidence providing that this area has significant relevance for mental health, this action would force other like-minded counseling programs to either drop these requirements to confirm to their plan or make it an optional course.  Let the marketplace of ideas in our field survive so we can continually innovating in how we provide mental health treatment to your citizens.  Please carefully review all evidence you have on both sides of this question and I am sure you will find reason to be concerned.

Dom Scalise, PhD 

Avila University