I am writing to strongly oppose CACREP-only language in the proposed regulations for LPC’s in the Intended Regulatory Action in Virginia.

My message is not anti-CACREP but pro-inclusion.  There are many fine programs across the country that for decades have been training licensed professional counselors to provide mental health services in accordance with state licensure regulations who choose not to pursue CACREP accreditation. This is due to CACREP’s restrictions on core faculty composition being only those holding counselor education degrees (yes, with some grandfathered exceptions) among other concerns.  George Mason University is one such example in your own state.

If you look at the CACREP accredited programs in clinical mental health counseling, you will see that they are regionally situated with most states across the country have few or no such programs.

I have been a licensed mental health counselor since licensure was available in my state of Massachusetts. I have been active in our state chapter of MaMHCA, served on our state licensure board for 9 years, and have held clinical and supervisory positions in both mental health and higher ed settings.  For the past 15 years, I have been a counselor educator and overseen field training for over 1500 students, and supervised our clinical supervision faculty. I think I understand a few things about counselor education.

In many of the discussions of inclusion vs. CACREP-only that have been occurring in various professional arenas in the past couple years, the debate often comes down to one of professional identity and historical turf wars between counselors versus counseling/clinical psychologists.  I believe this drawing of the lines in the sand is ill-conceived and destructive to the provision of competent mental health services across there country.

Let me use my own state of Massachusetts as an example. I served on the subcommittee who updated our most recent licensure regulations that were just posted this month.  This subcommittee chose to not include language re: CACREP standards (in full knowledge of recent events such as TRICARE). Massachusetts educational and field work standards have always met or exceeded CACREP standards. 

In Massachusetts, there are 19 programs that train students to become licensed mental health counselors (our title for LPCs).  Two of the programs are CACREP accredited, one has MCAC accreditation, one has MPAC, one has CORE.  Couselor educators from a majority of these programs have been meeting once a semester for close to 2 decades for MARIACES (Massachusetts/Rhode Island Association of Counselor Education and Supervision) meetings.  At MARIACES, we share a common bond as counselor educators and have consulted with each other on pedagogy, clinical expectations, licensure, dealing with impaired students, etc, etc.  Despite the differences in programs, we all know that we are training mental health counselors to the strict standards of our state licensing board.  We have no confusion about that professional identity and neither do our students.  We would never consider inferring that one of our colleagues or their programs were not engaged in counselor education.

I know that there are many other programs across the country like the 19 in Massachusetts, whether they be in departments of education, counseling, counseling psychology, or behavioral health that know their mission to prepare competent masters level mental health counselors and that their students embrace this counselor identity and its standards of practice.  The public is served by the breadth and depth of training that pro-inclusion of multi-disciplinary programs provide.

My perspective on the proposed regulatory change is shaped by the following rationale:

1. The role of the licensing board is to protect the citizens of Virginia through the regulation of licensure, and not accreditation. To cede the power of setting educational requirements that meet the needs of Virginians to a single, out-of-state accrediting agency does not protect the citizens of Virginia. Further, doing so may step beyond the charge of the counseling board.
2. There is no evidence to suggest that graduates of CACREP programs are more effective or more ethical providers, and commonly cited evidence to the contrary is methodologically unsound.
3. Counseling programs in Virginia that are not affiliated with CACREP are renowned. For example, in 2013, the counseling program at George Mason University – a program that is not affiliated with CACREP – was awarded the Outstanding Master’s Program award by the Southern Association for Counselor Education and Supervision.
4. The proposed regulatory change would unnecessarily restrict trade of LPCs in Virginia and LPCs considering a move to Virginia. This includes LPCs from neighboring states that do not have a similar restrictive policy.
5. 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 that programs meet a standard that meets (and in some domains exceeds) the rigor of CACREP standards.
6. Given the needs of the Commonwealth, more service providers – rather than fewer service providers are needed. For example, according to the National Association for Mental Illness (NAMI), only 19% of Virginians with serious mental illness receive services from Virginia’s public mental health system. And, as of 2013, Virginia had 47 federally designated mental health care professional shortage areas (Signer, 2014). Addressing this shortage requires that Virginia protect and support valuable counselor training programs  – rather than close them due to the administrative and financial limitations of achieving CACREP accreditation.

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,

Jill Ritchie, PhD, LMHC

Director of Field Training/Asst. Professor

Division of Counseling & Psychology

Graduate School of Arts and Social Sciences

Lesley University

Cambridge, MA