Re: Opposition to Virginia Petition 419

To Whom It May Concern:

The Council for Accreditation of Counseling and Related Educational Programs (CACREP) opposes Virginia Petition 419 which would create a pathway for Licensed Marriage and Family Therapists (LMFTs) to obtain licensure as a Licensed Professional Counselor (LPC).

CACREP is the leading national accrediting body for Professional Counselor preparation programs. We accredit programs in the specialized practice areas of Addiction Counseling, Career Counseling, Mental Health Counseling, Clinical Rehabilitation Counseling, College Counseling and Student Affairs, Marriage, Couple and Family Counseling, Rehabilitation Counseling, and School Counseling. Additionally, CACREP accredits doctoral programs in Counselor Education and Supervision for the preparation of counselor educators and advanced practitioners.

CACREP opposes this petition for a few main reasons. First, Marriage and Family Therapy is a specialized area of practice with a unique focus that differs significantly from the broader scope of Professional Counseling. Unlike LPCs, LMFTs are not trained to provide the wide-ranging services expected of LPCs, nor do they meet the same educational requirements. The competencies required of LMFTs are a subset within the competencies for LPCs, underscoring the distinct scope of each profession. The petition indicates that the proposed change would create a similar pathway, but this is not the case. In the case of counselors having a pathway to the MFT license, this pathway is very narrow, allowing only counselors who have graduated specifically from a marriage and family counseling program to obtain the MFT license. The proposal in this petition would create a pathway for MFTs to significantly broaden their scope of practice, enabling them to practice with populations outside marriage and family counseling (such as addictions counseling) without the requisite training.

For these reasons, it is concerning from a public protection standpoint when individuals licensed as LMFTs practice outside their area of expertise or training (such as an LPC without the appropriate training). Permitting LMFTs to operate as LPCs would not only be unethical but also a potential risk to client safety, as it allows practice outside the licensed scope of competency.

For these reasons, CACREP definitively opposes Virginia Petition 419.

For any further questions, please contact CACREP’s CEO Sylvia Fernandez at sfernandez@cacrep.org.