Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Counseling
 
chapter
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]
Action Changes resulting from periodic review
Stage Proposed
Comment Period Ended on 4/1/2022
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3/23/22  8:42 am
Commenter: Larry Epp, Ed.D., a Past President, LCPCM

Differentiation of CACREP versus Non-CACREP Counselors Not Equitable or Evidence Based
 

At a time when the COVID-19 Pandemic has taught us that telehealth and license portability are critical to solving provider shortages, Virginia should be trying to create an easy to understand and streamlined licensure criteria to allow telehealth across state lines. When these conversations started, we did not have a national provider shortage, triggered by a secondary mental health pandemic, now that we do, our policies should be inclusive and allow the efficient portability of all counselors with three years of experience. The differentiation of CACREP versus non-CACREP counselors, and the punitive 10 year experience requirement for non-CACREP counselors, is not equitable and not justifiable based on the literature. This would exclude many of the graduates of Johns Hopkins from easily transferring their license to the Commonwealth, which has only had CACREP accreditation for 5 years, but is reputably one of the best programs in the US. Virginia should be modeling its regulations on the developing Counseling Compact and not diverging from this wise movement to eventually allow national telehealth portability. 

CommentID: 120842