I am writing in opposition to proposed regulatory change for Licensed Professional Counselors.  I own a private rehabilitation company and spend some of my time practicing as a clinician with Balance Behavioral Health in Midlothian Virginia.,  I am a graduate of the Virginia Commonwealth University Rehabilitation Counseling Program which is Core accredited.  I have some concerns about the language used in the proposed regulation:  "add a requirement for all counseling programs leading to a license as a professional counselor to be clinically-focused and accredited by the Council for Accreditation of Counseling and Related Educational Programs (CACREP) or an approved affiliate, such as the Council on Rehabilitation Education (CORE).”  My concern is that if at some time in the future CORE and CACREP drop their affiliation that there will be a large pool of qualified CORE program rehabilitation counselors that will lose their ability to seek licensure and as a result the clients they serve will be adversely impacted.   Instead of specifying one particular accrediting body, I recommend that applicants for the Licensed Professional Counselor credential be graduates from an accredited counseling graduate program that is recognized by the Council for Higher Education Accreditation (CHEA) to accredit programs to educate counselors.  That would allow the Board of Counseling to continue its long history of approving applicants who have graduated from CORE-accredited programs and CACREP-accredited programs, regardless of whether or not the new CORE/CACREP affiliation continues into the future.  

This is a valid concern because it is already playing out at the federal level.  Members of our profession, who attended CORE accredited graduate programs and are licensed, that have been practicing for years and have dedicated their lives to helping individuals with disabilities have been eliminated from hire or affiliation with the Veterans Administration and Tricare.  I ask that language  such as CACREP “and CORE” be considered. The exclusive language in the proposed change could impact the livelihood of VIrginia counselors intending to seek licensure as well as limit access to VIrginia citizens from qualified professionals with mental illness and/or physical/ cognitive disabilities.