I strongly oppose this legislation. I am a licensed clinical psychologist who received his doctorate in a then-APA-approved Counseling Psychology program at Michigan State University in 1969 and has subsequently been licensed in Illinois, Pennsylvania, and as a clinical psychologist in Virginia since 1988. I also received a Diplomate in Counseling Psychology from the American Board of Professional Psychology in 1987, the highest distinction the profession bestows which is based on an examination of one’s ability to apply his/her knowledge and skills. I have also been a Registered Sport Psychologist of the Sports Medicine Division of the United States Olympic Committee since 1988. I taught in the doctoral psychology program at Virginia Commonwealth University for over 30 years and served as Department Chair for 8 years. The doctoral program provides master's degrees to students (non-CACREP-accredited) along the way to their PhD. I have been retired since 2013 and presently am a Professor Emeritus of Psychology at VCU.

I am presently completing a counseling textbook designed to help teach counseling to Master’s level counseling students in both APA and CACREP programs. As a result, I reviewed the criteria for both programs and found them comparable and adequate. However, neither APA nor CACREP-trained Master’s level students are significantly better trained than the other to allow a turf war to limit the access of students from either Program to serve the needs of clients in Virginia.

Unfortunately, I have had a too-long history of observing turf wars in psychology. In 1981, a colleague and I wrote an article for the American Psychologist. The article (Danish, S.J. & Smyer, M.A. (1981).  The unintended consequences of requiring a license to help.  American Psychologist, 36, 13-21) suggested that licensing was only partially related to competence.  Becoming a competent provider, as described in Miller’s Skills Pyramid, is a four-stage process.  It begins with the provider: (1) possessing the factual information and knowledge required (knows what to do); (2) knowing how to apply the knowledge in a given situation (knows how to do it); (3) demonstrating the knowledge and related technical skills in a practice setting (shows how); and (4) applying the knowledge, skills, and experience when performing in the real-world (does).  Training of students in both programs focuses on the first three stages; it is less clear whether master’s degree students in either program demonstrate the ability to apply the knowledge, skills and experience to perform effectively on a consistent basis with a diverse variety of clientele.

I have seen no research that indicates that either program demonstrates this level of competence more effectively or consistently than the other. Without such data why should the Commonwealth consider choosing one program over the other especially given the increasing demand for counseling services and with an addiction crisis sweeping Virginia and our nation?  Such an action appears to be a restraint of trade based on nothing more than a fight over turf.

As a member of Board of Directors of the Richmond Behavioral Health Authority (RBHA) for the past 8 years, I have seen first-hand the behavioral health problems and the difficulty treating all of citizens in need.  It would be unconscionable to eliminate one group of providers without research data to support such a decision. We need all the well-trained mental health counselors available to alleviate or at least reduce this problem.

Thank you for the opportunity to share my thoughts.  

Steven J. Danish,