The proposed regulations in Virginia (to require 10 years of practice post degree for individuals graduating from programs not affiliated with CACREP while only requiring 3 years of practice post-degree for individuals graduating from CACREP programs) constitute restraint of trade, are not based on evidence, and make it more difficult for citizens of Virginia to access quality mental health care. Virginia is ranked 39^th in access to mental health care (https://mhanational.org/issues/2021/ranking-states#four), and the proposed legislation would worsen access to mental health care without providing any benefits to its citizens.

While it is appropriate to regulate who provides mental health services, such regulations should be based on evidence. Many mental health programs (59 programs across 23 states) in Psychology or Counseling are accredited by MPCAC (which is itself CHEA-accredited), which has similar—and in some ways more stringent--educational requirements as CACREP’s. MPCAC requirements emphasize ensuring services provided are empirically based, and emphasize thorough training in providing services to diverse populations.  The mission of MPCAC is to “provide  science-based education and training in the practice of counseling and psychological services at the master’s degree level, using both counseling and psychological principles and theories as they apply to specific populations and settings” (http://mpcacaccreditation.org/).   The proposed regulations will deter students from MPCAC-accredited programs from moving to and practicing in Virginia.  Such regulations are not based in research, only on one group of individuals trying to restrict competitors from providing mental health services. Moreover, it likely constitutes restriction of trade that could result in legal challenges.