The Commonwealth of Virginia should correct the proposed policy to insure that all Maryland Counselors, whether graduating from a CACREP or non-CACREP program, should be able to transfer their license after three years of practice. Virtually every school in Maryland up to three years ago was not accredited by CACREP and this included a number of the nation's most respected graduate programs in counseling, such as Johns Hopkins, University of Maryland, Towson, Bowie State, UB, among many other respected universities. CACREP will not recognize the graduates of Counseling Psychology Programs, and this policy stance by the accrediting body marginalizes the graduates of these programs. Counseling Psychology has been a major contributor to the development of professional counseling, and excluding these programs and graduates is puzzling and injurious to the profession, given their immense intellectual contributions.

For over 20 years I have been involved in counselor education, at a university with a long history of graduating responsible and highly qualified practitioners. ACA has provided a reasonable proposal for national licensure portability that would allow counselors from NJ and other states to change their residences while not unreasonably limiting their employability. There is not one shred of evidence to support the need for graduates of non-CACREP programs to practice for 10 years rather than 3 before they are licensable. This cannot be other than a thinly veiled attempt to privilege CACREP programs over other programs that graduate highly qualified counselors, for reasons completely unrelated to the safety of the residents of Virginia. I strongly oppose this proposal.

The Commonwealth of Virginia should correct the proposed policy to insure that all Maryland Counselors, whether graduating from a CACREP or non-CACREP program, should be able to transfer their license after three years of practice. Virtually every school in Maryland up to three years ago was not accredited by CACREP and this included a number of the nation's most respected graduate programs in counseling, such as Johns Hopkins, University of Maryland, Towson, Bowie State, UB, among many other respected universities. CACREP will not recognize the graduates of Counseling Psychology Programs, and this policy stance by the accrediting body marginalizes the graduates of these programs. Counseling Psychology has been a major contributor to the development of professional counseling, and excluding these programs and graduates is puzzling and injurious to the profession, given their immense intellectual contributions.

This is a harmful and limiting policy for professionals and consumers. The Commonwealth of Virginia should correct the proposed policy to insure that all Maryland Counselors, whether graduating from a CACREP or non-CACREP program, should be able to transfer their license after three years of practice. Virtually every school in Maryland up to three years ago was not accredited by CACREP and this included a number of the nation's most respected graduate programs in counseling, such as Johns Hopkins, University of Maryland, Towson, Bowie State, University of Baltimore, among many other respected universities. Also, CACREP will not recognize the graduates of Counseling Psychology Programs, and this policy stance by the accrediting body marginalizes the graduates of these programs. Counseling Psychology has been a major contributor to the development of professional counseling, and excluding these programs and graduates is divisive, puzzling and injurious to the profession, given their immense intellectual contributions.

I am the owner and director of Congruent Counseling Services, a growing practice in Maryland.  If VA imposes such an unfair law, I will not open my planned office in Virginia.  There were no CACREP Accredited colleges in MD until after I graduated in 1998.  Punishing me, and other licensed counselors for not attuning a CACREP School, particular when Maryland licenser requirement exceeds that of CACREP programs, is unfair, unreasonable, and only political.  CACREP only seeks to establish itself as a political entity and has no greater value than other programs.  this is all political.  I am disgusted by this attempt to disenfranchise experienced licensed therapists.  

I oppose any requirement by Virginia to disadvantage licensed counselors who did not attend CACREP-accredited graduate programs. Discrepant requirements for CACREP and Non-CACREP counselors are unfair to Maryland Counselors who did not graduate from CACREP programs, which is the majority of counselors in Maryland. I, and others, are concerned that any CACREP restrictions would further marginalize graduates of Counseling Psychology programs, which CACREP does not recognize as Counseling programs. The Maryland Board of Professional Counselors recognizes Counseling Psychology as part of the profession of Counseling. We believe this is the correct stance to take, given Counseling Psychology's historic role in the development of our profession.

I oppose any provision or law that proposes to discriminate counselor license portability.The current proposal in Virginia which favors only CACREP graduate programs unfairly limits counselors who have been practicing for many years from obtaining a Virginia counselor license. Please do not pass this law. 

I am strongly opposed to any requirements that would disadvantage clinicians who graduated from non-CACREP schools.  Many reputable universities in Maryland, including Johns Hopkins University were previously not CACREP accredited.  I am among those graduates. 

Pro-CACREP sentiment tries to convince the public that counselors who did not graduate from CACREP programs are not as highly trained.  Individuals who don’t know any better might actually buy into this misinformation.  The reality is that CACREP is invested in this message as it brings significant amounts of money to their table.  Pro-CACREP legislation is simply a way for CACREP to keep getting business.  

The truth is that there are many highly trained clinicians who did NOT graduate from CACREP programs.  

I oppose any provision or law that proposes to discriminate counselor license portability. The current proposal in Virginia favors only CACREP graduate programs even though many accredited universities meet or exceed the standards of CACREP programs. Virginia needs excellent mental health services for its citizens and this proposal limits availability of highly educated, qualified, and experienced counselors.

I oppose any provision or law that proposes to discriminate counselor license portability. The current proposal in Virginia favors only CACREP graduate programs even though many accredited universities meet or exceed the standards of CACREP programs. Virginia needs excellent mental health services for its citizens and this proposal limits availability of highly educated, qualified, and experienced counselors.

It is patently unfair to make it difficult to find employment for thousands of clinicians. 

I strongly oppose this limitation on qualified, talented therapists..

I strongly oppose this proposal, which marginalizes highly qualified professionals and limits access to care for the many clients who need their support.

I am a retired Air Force Colonel with 26 years of active duty service. Following retirement I continue to serve as a mental health counselor licensed in Maryland and Virginia. I have received training at the Beck Institute, the Ellis Institute, the Gottman Institute, and the Baltimore-Washington Center for EFT. However, CACREP was not widely available, nor required, when I received my counseling degree. With the shortage of mental health counselors in the USA, I find it sad that competency is being judged based on the political pundants cry for a relatively new accreditation program that discriminates against highly skilled counselors. I understand the drive for improving the perception of the profession, but portability should not be the tool used to push it. Let the professional organizations work that out with NBCC. Virginia should stay out of the politics and maximize availability to mental health practitioners by supporting counselor portability for those licensed in other states. Let reasoned thought win the day. Thank you.

Virginia’s limited and biased regulatory decision reduces the numbers of licensed counselors who will provide diagnosis and treatment to the citizens of Virginia. The need for mental health counseling is extremely important with the current opioid epidemic and the stress the American people are experiencing. Please reconsider.

Thank you.  

I strongly favor the adoption of the fair and simple Portability Model of the American Counseling Association.  

I oppose this proposal as it limits access of qualified mental health professionals to those in need of services.

Given that there is quality education provided that is not CACREP affiliated, is reason enough not to pass this regulation.  Thousands of very good providers would be affected. A grandfathering approach is more appropriate if necessary.

This impacts several, highly qualified mental health clinicians from getting employment. Mental health treatment is already hard to find for several seeking these services. Limiting the amount of clinicians, who have the clinical skills, from being able to get employed in the state, would not only impact clinicians, but also people seeking these resources.

I oppose any requirements by Virginia that disadvantage licensed counselors for not attending CACREP accredited institutions.

I believe that Virginia should adopt the fair and simple Portability Model of the American Counseling Association:

A counselor who is licensed at the independent practice level in their home state and who has no disciplinary record shall be eligible for licensure at the independent practice level in any state or U.S. jurisdiction in which they are seeking residence. The state to which the licensed counselor is moving may require a jurisprudence examination based on the rules and procedures of that state.

Gretchen Williams, LCPC-S

This proposal is biased and discriminatory against programs of long standing which are not CACREP accredited but fulfill all other requirements of accreditation. By discriminating based on CACREP accreditation, Virginia would be creating a defacto requirement for CACREP accreditation for counseling programs and their graduates.

I strongly oppose this proposal. I am confident that Virginia would be greatly limiting their access to clinicians who are well-trained and eager to treat their most vulnerable by approving this regulation. 

To Whom It May Concern, 

I am a resident of Northern Virginia and an LCPC working in Maryland, where I completed my education and first began the licensure process before moving to Alexandria. When I moved to Virginia in 2008, I considered applying for Virginia licensure but was discouraged when I discovered that my accumulated supervision hours would not be honored by my home state. Having been licensed in good standing for many years, I could submit for license now, and would be eligible, but have hesitated because I continue to see examples of VA policies being driven more by lobbyists than by quality practices. In this case, providing preference to a single accrediting body rather than nationally established and accepted guidelines puts Virginia constituents at a disadvantage - there are unmet needs, particularly in Virginia's Public Behavioral Health System, and these needs could be met by qualified and capable counselors educated at non-CACREP accredited schools. 

As an Approved Clinical Supervisor in Maryland, I have personally supervised Licensed Graduate Professional Counselors pursuing independent licensure, including several from highly qualified graduates from Johns Hopkins University and University of Maryland whose counseling psychology programs are not CACREP accredited but continue to provide all the foundational skills and education required to start out in a career as a counseling professional. 

Virginia should adopt the fair and simple Portability Model of the American Counseling Association:

A counselor who is licensed at the independent practice level in their home state and who has no disciplinary record shall be eligible for licensure at the independent practice level in any state or U.S. jurisdiction in which they are seeking residence. The state to which the licensed counselor is moving may require a jurisprudence examination based on the rules and procedures of that state. 

Thank you for considering the perspectives of clinical professionals working in this field. 

Sincerely, 

Kris Wright, LCPC

I am in favor of Virginia adopting the Portability put forth by the ACA that includes counselors trained in any accredited institution not just CACREP ones.

James N. Tanner, LCPC

I strongly oppose this!

I strongly oppose this!

I strongly oppose this proposal. Virginia would be preventing well-trained clinicians from a multitude of opportunities, as well as limiting their own access to these clinicians.

The current proposal, while offering several options for all licensed counselors, falsely suggests that licensed counselors who graduated from programs accredited by CACREP (who would need 3 years post-licensure experience) are more qualified than those who graduated from other programs (who would need 10 years post-licensure experience).

According to the current proposal, licensed counselors from other jurisdictions would be qualified for licensure by endorsement in Virginia if they either 1) meet all requirements for initial licensure in Virginia including specific coursework, supervised experience, and residency, or 2)  have 2 years post-licensure clinical practice in counseling in the last 5 years, which includes teaching graduate courses in counseling,  or 3) hold NBCC’s Certified Clinical Mental Health Counselor (CCMHC) for which the NCC and therefore, effective 2024, graduation from programs accredited by CACREP, are prerequisites, or 4) have held an active license in the other jurisdiction for ten years, or 5) have held an active license in another jurisdiction for 3 years and have either graduated from a program accredited by CACREP or hold the NCC credential (which, as above, will be limited to graduates of programs accredited by CACREP effective 2024).

There is no documented evidence that licensed counselors who graduated from programs accredited by CACREP are better prepared than their peers who graduated from other programs! Why then should the majority of licensed counselors who did not graduate from programs accredited by CACREP be required to show 7 more years of experience than their peers who graduated from programs accredited by CACREP?

The ACA Portability Plan (see above) is a significantly better option than this proposal.

I strongly appose.

There is no documented evidence that licensed counselors who graduated from programs accredited by CACREP are better prepared than their peers who graduated from other programs! Why then should the majority of licensed counselors who did not graduate from programs accredited by CACREP be required to show 7 more years of experience than their peers who graduated from programs accredited by CACREP?

The ACA Portability Plan is a significantly better option than this proposal.

As as counseling psychology graduate student pursuing licensure in the state of Maryland, I am extremely interested in the possibility of being able to practice in the surrounding states, and the proposed regulations for licensure by endorsement in the state of Virginia are unnecessarily restrictive. Not only are these restrictions founded on exactly zero documented evidence, but the entirely false assumption that CACREP program graduates are more qualified than any other M.S. graduate is insulting and actively harmful to young counselors and the clients they will ultimately be tasked with helping. These "regulations" would provide unequal footing for equally qualified young counselors in the state of Virginia, unnecessarily restricting the pool of professionals available to the citizens seeking help in that state. There is no evidence to support these regulations, and the citizens of Virginia will pay the price for such a grave error in judgement.

 I strongly oppose this proposal. We need to move the portability of our licenses forward. 

This proposal discrimates against non-CACREP programs and it is unfair. The education and counseling skills acquired through non-CACREP programs is of the highest quality. We need to move forward with license portability and allow counselors to practice where they see fit regardless of the program they attended. 

I oppose any laws and/or any regulations would prevent or impede anyone the opportunity to provide substance and/or mental health services to any client. Virginia needs to rethink this matter. 

At least the DC MD VA should get an exemption from re licensing but the requirements to take the respective state seems prudent.

This proposal discriminates against non-CACREP programs and it is unfair. The education and counseling skills acquired through non-CACREP programs is of the highest quality. We need to move forward with license portability and allow counselors to practice where they see fit regardless of the program they attended. 

As a current MS student in my last year at Loyola University of Maryland, I am very disheartened to hear that there is even a consideration to provide special privileges to counselors who attended a school with a different accreditation. Students who have attended many years of schooling and spent a tremendous amount of time and heart into their work are being mistreated simply because they did not attend a CACREP approved school? This matter is clearly political and business driven, which has no place in our field of serving others on a humanistic level.  Please do not harm our fellow counselors who have worked so hard to get where they are with their only goal in mind to serve our communities. Let us do our job and serve others despite  "CACREP" seal. I know this can seem as a challenging issue considering the headquarters in in Richmond, VA. However,  my fellow counselors/ therapists/ practitioners and I humbly ask you to let us do our jobs, help others, and treat us all equally. Equality is vital in our profession, it is the core of our profession and our ethical standards. 

CACRP is not the only standard bearer in providing excellent counseling services to those in need. Virginia only hurts itself by adopting such a wrong-headed policy and discouraging skilled workers to move inside its borders.

This type of proposal is not inline with the values of the profession of professional counseling. The profession promotes equity and inclusion of a diversity of approaches. CACREP promoters are acting in ways inconsistent with these values. 

There is no documented evidence that licensed counselors who graduated from programs accredited by CACREP are better prepared than their peers who graduated from other programs! Why then should the majority of licensed counselors who did not graduate from programs accredited by CACREP be required to show 7 more years of experience than their peers who graduated from programs accredited by CACREP? 

The ACA Portability Plan (2016) is a significantly better option than this proposal!

I graduated from one of the very few CACREP-accredited Counseling Master's programs in the State of Maryland. While I deeply value the training, knowledge, and education I received, there is absolutely no data supporting the implied idea that a CACREP-accredited program is better than a non-CACREP-accredited program. It baffles me why so many legislative decisions on Counselor licensure, including the current one before you about Portability, are based on CACREP vs. non-CACREP, when there are zero studies providing any evidence that one more fully prepares students to be effective counselors than the other. 

It is implied by CACREP-accreditation getting preferential treatment in the current legislation on Portability. Not only is it implied that a CACREP-accredited program is better, it's implied it is immensely more complete by more than tripling the years in practice a Counselor/Therapist must be before they can have Portability if they graduated from a non-CACREP-accredited Counseling program.
Further, CACREP accreditation hasn't been available long enough to be established as a viable option. And it excludes the extensive training of Counseling Psychology programs which are usually Doctorates. 

The only winner in favoring those who had the opportunity to graduate from a CACREP-accredited program is the CACREP organization itself. Their powerfully persuasive PAC is trying to earn credibility by swaying legislators. By giving into this manipulation, thousands of highly trained and talented Counselors/Therapists and Counseling Psychologists will be Excluded with no real, valid, fact-based reasoning.

Again, I graduated from a CACREP-accredited Counseling Master's program, so there is no personal or professional benefit to me to ask you to oppose the currently proposed Counselor License Portability Legislation before you.

I ask you to adopt the Fair and Simple Portability Model of the American Counseling Association.

Thank you.

Kindly show us evidence to suggest that students who attended CACREP accredited institutions are better prepared to provide therapeutic services and we'll let this settle.  To date there is no substantiated evidence for this.  None.  Zero. 

Your broad based focus should be to promote mental health, to reduce stigmatization of those seeking counseling support, and to act as a catalyst for easier access to quality therapy from professionals who graduated from lauded institutions, like the University of Baltimore. 

This proposal will have a wide-reaching impact on not only the lives of professionals and the people who need to be able to easier access therapy services, but will also affect the development of future counseling studies and academic journals that support research on new therapeutic and counseling methods.

Please reconsider and do the right thing.

CACREP has attempted to create a second class of counselors out of the most experienced in Maryland. At the time I graduated (only about 10 years ago), there were virtually no CACREP accredited programs in Maryland. The only one in the Baltimore area was the pastoral counseling program at Loyola.  By discriminating against graduates from other institutions, you are ensuring that you won’t have experienced counselors. And even with a provision for “grandfathering” us more experienced counselors, the discriminatory language makes it clear to me, for one, that my expertise and experience is not welcome in Virginia. 

Terrible idea.  How can you justify limiting ones profession especially after they have put time, money and dedication into their counseling career.  This proposal not only short changes the counseling professional but also the clients who benefit from the services provided .  Please reconsider, it makes new counselors question whether they have made a good career choice and seasoned counselors question whether they want to remain in the counseling field.