Agencies | Governor
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 Ends 7/1/2015
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6/29/15  6:12 pm
Commenter: Eileen Douglas, M.S., LPC, ATR-BC

Strongly Oppose

I am writing in opposition to the Board of Counseling’s Notice to proceed with rulemaking to revise regulations governing the practice of professional counseling.  The proposed rulemaking would change the Board’s existing degree program requirements for licensure to require graduation from a clinically-focused counselor preparation program accredited by the Commission on Accreditation of Counseling and Related Education Programs (CACREP) or a CACREP-approved affiliate accrediting organization.

As a licensed professional counselor and board certified art therapist in Virginia, I have dual academic training in the theories and techniques of counseling psychotherapy and also in the theory, methods and clinical practice of art therapy.  The Board has long recognized this training as meeting or exceeding the academic and experience requirements for the LPC license.  A significant number of art therapists have gained licensure in Virginia as professional counselors and, to my knowledge, no licensed art therapist has ever had an action brought by the Board for improper practice or unethical conduct.  The proposed amendment would disqualify many similar clinically trained and ethical professionals from licensure and eliminate both diversity and availability of counseling services going forward. 

The counseling profession has sought to explain this change to a CACREP-only degree standard for licensure as necessary to allow professional counselors to qualify to meet the needs of Virginia’s large military and veteran population.  I strongly disagree.  The National Intrepid Center of Excellence at Walter Reed National Military Medical Center, and notable military and VA health facilities across the nation, have recognized art therapy as an effective and needed treatment for returning military personnel suffering from traumatic brain injury and post-traumatic stress, as well as for their family members who have endured the emotional strain of multiple military deployments.

Virginia has a critical need for qualified mental health professionals to address not only the needs of its large military population, but the diverse needs of growing numbers of children, adolescents, adults and seniors with serious physical, mental and emotional conditions and disabilities.  It makes no sense to restrict licensure to only a segment of the state’s counseling profession and exclude many highly qualified and needed mental health professionals.

The Board of Counseling has always welcomed diversity in mental health counseling education.  I urge the Board to reject the petition for rulemaking and retain current counselor degree program licensing requirements.  


Eileen Douglas, M.S., LPC, ATR-BC

Counseling Doctoral Student, Oregon State University

CommentID: 40452