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 Ended on 7/1/2015
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6/30/15  7:57 am
Commenter: Eleanor Fukushima IARP Virginia Chapter

Opposition Statement from IARP Virginia Chapter

Dear Board of Health Professionals,

The International Association of Rehabilitation Professionals Virginia Chapter (IARP VA) would like to comment concerning the proposed changes in credentialing for licensure as a Licensed Professional Counselor in Virginia.  As an organization we have concerns that proposed language could result in the restriction of qualified counselors from earning a living within our Commonwealth as well as restrict the services available to the citizens of the Commonwealth with mental health illness and/or physical disabilities in need of clinical counseling services.

Credentialing is very important to the IARP VA.  Credentialing serves to protect the citizens of the Commonwealth from harm.  IARP VA is in support of highly qualified licensed counseling professionals.  We believe these qualified professionals are found in both the ranks of Council for Accreditation of Counseling and Related Educational Programs (CACREP) and Council on Rehabilitation Education (CORE) accredited higher education programs.  Both accrediting bodies certify programs recognized by the Council for Higher Education Accreditation (CHEA.)  Any potential limiting of these recognized bodies would disenfranchise citizens of the Commonwealth or those who seek reciprocity in our Commonwealth from earning a living and contributing to our economy.

The CACREP language “require graduation from a clinically-focused counselor preparation program accredited by CACREP or an approved affiliate of CACREP “ is troubling because it has the potential to be exclusive.  Currently, CORE is a recognized affiliate but if CORE falls out of favor with CACREP those persons who have graduated from exceptional rehabilitation counseling programs across the country to include Virginia Commonwealth University will not be able to obtain licensure in Virginia.  This is a valid concern because it is already playing out at the federal level.  Members of our profession, who attended CORE accredited graduate programs and are licensed, that have been practicing for years and have dedicated their lives to helping individuals with disabilities have been eliminated from hire or affiliation with the Veterans Administration and Tricare.  We ask that language  such as CACREP “and CORE” be considered.

The CACREP “only” mentality at the federal level impacts thousands of Veterans who have sacrificed for their country and are under served by the Veterans Administration are further limited in getting access to skilled Licensed Professional Counselors that have expertise in areas such as Traumatic Brain Injury which is one of the leading impacts on Veterans in current warfare.  We do not want this to become the plight of the Virginia citizens needing clinical counseling services.

Please carefully consider developing more inclusive language as shared above.  This will protect the citizens of the Commonwealth from both the perspective of losing the ability to earn a living in some cases and, in others, access to important mental health services.  It also protects the citizens by requiring highly skilled Licensed Professional Counselors to serve our Commonwealth.

Thank you for your consideration of our concerns.



Eleanor Fukushima. M.Ed., CRC, CRP                                                                                                                                          President of IARP Virginia Chapter

Representing the Board of IARP Virginia               

CommentID: 40461