Acting Executive Director Hoyle -

     I have serious concerns about the proposed requirement for CACREP accreditation for educational programs to establish eligibility for the Licensed Professional Counselor credential in Virginia.  The current language of the proposed regulation includes a requirement "for all counseling programs leading to a license as a professional counselor to be clinically-focused and accredited by the Council for Accreditation of Counseling and Related Educational Programs (CACREP) or an approved affiliate, such as the Council on Rehabilitation Education (CORE)."

     As a faculty member who has served on both the CACREP and the CORE boards of directors, I am aware of the tenuous nature of affiliation agreements between such bodies.  If, for some unanticipated reason, CACREP and CORE discontinue their affiliation, graduates of CORE-accredited programs would then become ineligible for licensure as professional counselors in the Commonwealth of Virginia, although they have been appropriately trained and prepared for such practice.  Virginians who need mental health services, including those who experience other disabilities, would then lose access to qualified providers.  

     Instead of specifying one particular accrediting body, I recommend that the Commonwealth of Virginia's Board of Counseling require that applicants for the Licensed Professional Counselor credential graduate from an accredited Counseling graduate program, defined as a program accredited by an accrediting body that is specifically recognized by the Council for Higher Education Accreditation (CHEA) to accredit graudate programs to educate counselors.  That would allow the Board of Counseling to continue its long history of approving applicants who have graduated from CORE-accredited programs, as well as CACREP-accredited programs, regardless of whether or not the new CORE/CACREP affiliation continues into the future.  It would also be helpful for regulations to remain effective even if CACREP changes its name (which was discussed fairly recently as a possibility), so that the Commonwealth would not have to go through another regulatory change due to any name change of an external entity.

     I also have a question about how the definition of a "clinical" program will be operationalized.  If the "clinical" nature of a program will be defined by specific curricular requirements (such as specific instructional content areas that must be covered, and specific requirements for practicum and internship experiences), that would be great.  However, if people depend on the word "clinical" being listed in the name of a degree, or the title of an accreditation category, that becomes an arbitrary decision left to the determination of an external entity.  I specifically recommend that either 1) the term "clinical" be operationally defined as satisfying specific coursework and/or fieldwork requirements, or 2) the word "clinical" be removed from these requirements. 

     I would be happy to discuss these concerns with you or any other entities responsible for examining this proposed regulation before approval.  I can be reached by email at creid@vcu.edu, or by telephone at 804-827-0915.

Respectfully,

Christine A. Reid

Christine Reid, Ph.D. CRC

Professor, Rehabilitation Counseling

Virginia Commonwealth University

804-827-0915

creid@vcu.edu