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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6/4/15  10:05 am
Commenter: Nancy Brisebois-Good, LCPC, NCC

Opposition to this proposal

I am writing to express my objection to the CACREP-only requirement proposed by the VA board.  I am a counselor who has been practicing for the past 6 years. I graduated from Johns Hopkins University with a degree in counseling that trained us to become outstanding clinicians. However, this program was not CACREP accredited THEN. I am writing “THEN” because when I was a student there, all our syllabus/curricula were marked as reflecting CACREP regulations. When I was a grad student, JHU was in the process of getting their accreditation (they have it now) but they had not formally obtained it yet. I am specifically writing this “detail” because it proves that someone who didn’t graduate from a CACREP accredited program could still have graduated from a very well regarded program which even followed CACREP requirements.

My cohort (2010) just happened to graduate “too soon” to have this now or future supposedly “elite” qualifier - but does this make us less competent counselors? I don’t think so. However, based on the CACREP-only proposition currently under consideration, it would.  This is unfair and does not make any sense. It would mean that someone who studied in a program following all the CACREP regulations would not receive this “elite qualifier” simply because that person did not graduate "at the right time" to receive it.

As of now, CACREP grandfathered A YEAR back. So this means that the student who graduated a year and one month before would not receive this supposedly elite qualifier because that person, just like my cohort and the cohort before me, would have graduated “too early.” I hope that you see my point that this CACREP qualifier does not make sense and doesn’t indicate whether someone is a competent clinician or not.

In my cohort's case, our entire program (from day one) was based on and followed CACREP regulations, but we just weren’t “lucky” enough to make the cut.  Therefore, if this requirement passes, we will find ourselves having to “prove” that we are as good as CACREP graduates when looking for a job or being accepted by insurance.

Furthermore, I cannot comprehend that we, non-CACREP counselors, have to fight in order to keep our right to practice and be as well-regarded as CACREP accredited counselors in a society where the need for mental health is so great. Just having to come here and write a comment in order to be able to not lose our right to practice is completely unfair.  Non-accredited CACREP counselors are not second class citizens of the counseling field. If this requirement passes, however, we will be looked upon as such when it couldn’t be further from the truth.

As a colleague said in another comment, “the long and arduous path of licensure in Virginia (and all states) already prepares applicants to be fully-competent counselors while eliminating those who are not proficient enough for the field.”

Therefore, I am asking to please take down this proposal that would do unprecedented and unnecessary hurt to competent and devoted professionals who are asking nothing else but being able to continue working in their beloved field where they can help others in need. Having less mental health professionals is certainely not the solution in today's society where the need is greater than ever.

Thank you.



CommentID: 40054