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This 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. My opposal is based on the following:

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 unsound and unproven.
3. 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. New York state is an example of a state that resticts licensure including reciprocity to CACREP only graduates that has alienated potentional licensed LPCs from moving to practice in that state if they have not graduated from a CACREP school.
4. 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.
5. 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. I too 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. By doing so you are limiting the amount of LPCs that may potentially move to your area and have not graduated from a CACREP school and potentialy causing more harm to the clients that need them. I urge you to reconsider your position.