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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6/19/15  10:18 pm
Commenter: Timothy Flynn, University of Baltimore



Thank you for the opportunity to comment on this legislative proposal.  I am a graduate student and counselor in training at the University of Baltimore and I strongly oppose proposals to exclude counselors that do not graduate from CACREP accredited graduate programs from practicing in the State of Virginia. 

I am also writing to advocate as a veteran of our nations armed forces.  Unfortunately, this legislative proposal could not be enacted at a worse time as it would only prevent counselors not from CACREP programs from working with other veterans in need of mental health services in the future.  We should also remember that this is a time when the number of veterans returning home from multiple tours of duty in Iraq and Afghanistan is increasing.  This legislation would simply create needless challenges to those working to readjust to life outside of a combat zone or those navigating the frequently tumultuous transition back to civilian life.  As counselors, our goal should be to focus on assisting in these transitions, in vigorous collaboration with other mental health service providers, not focusing on further exclusions to appease one accrediting body.

Some additional facts to consider are:

  • Diversity and inclusion in mental health is of paramount importance. In a time of integrated care and rising mental health needs, mental health providers are called to work together for the good of the public’s health needs.  

  • Given the state of mental health care in Virginia, more service providers – rather than fewer service providers are needed. For example, according to the National Association for Mental Illness (NAMI), only 19% of Virginians with serious mental illness receive services from Virginia’s public mental health system. And, as of 2013, Virginia had 47 federally designated mental health care professional shortage areas (Signer, 2014). Addressing this shortage requires that Virginia protect and support valuable counselor training programs  – rather than close them due to the administrative and financial limitations of achieving CACREP accreditation. 

  • The proposed change would unnecessarily restrict trade of LPCs in Virginia and LPCs moving into Virginia. This includes LPCs from neighboring states that do not restrict licensure to a particular accrediting body.  

  • The proposed regulatory change also limits the hiring of mental health professionals outside of counselor educators as full-time faculty members in CACREP-accredited training programs, which in turn restricts quality supervisors, educators, and mental health providers from sharing their expertise in training and supervising new counselors in the state of Virginia. 

  • The role of the licensing board is to protect the citizens of Virginia through the regulation of licensure, and not accreditation. To cede the power of setting educational requirements that meet the needs of Virginians to a single, out-of-state accrediting agency does not protect the citizens of Virginia. Further, doing so may step beyond the charge of the counseling board. 

  • There is no empirical evidence to suggest that CACREP graduates are more effective or more ethical providers, and commonly cited evidence to the contrary is methodologically unsound.  

  • Counseling programs in Virginia that are not affiliated with CACREP are renowned. For example, in 2013, the counseling program at George Mason University – a program that is not affiliated with CACREP – was awarded the Outstanding Master’s Program award by the Southern Association for Counselor Education and Supervision.  

  • There are other paths to accreditation of counseling programs. For example, the Masters in Psychology and Counseling Accreditation Council (MPCAC) accredits counseling programs and requires that programs meet a standard that meets (and in some domains exceeds) the rigor of CACREP standards.  

Thank you for your time,

Timothy Flynn

CommentID: 40322