The Alliance for Professional Counselors (APC), a national organization of counselors and counselor educators that supports interdisciplinary cooperation and licensure portability, remains strongly opposed to a specific provision in the Virginia Board of Counseling’s proposal for licensure by endorsement that we objected to in 2019.

We particularly object to the provision that would permit licensed counselors who graduated from programs accredited by CACREP to qualify for licensure in Virginia with 3 years post-licensure experience while licensed counselors who graduated from programs that are not affiliated with CAREP would need 10 years post-licensure experience to qualify for licensure in Virginia. There is NO evidence to support this proposed discrepancy.

Furthermore, this proposal would harm the public by unnecessarily limiting the number of licensed counselors who would qualify for licensure (and therefore professional counseling work) in Virginia. This proposal would also harm the majority of licensed counselors who graduated from programs that are not affiliated with CACREP by making it seem, despite lack of evidence, that they are less qualified. We call your attention to the two successive Virginia Economic Impact Analyses (2016, 2017) for further information. Furthermore, as Virginia has historically been a leader in the profession, this proposal could set a negative precedent.

We fully respect that these decisions are within the purview of the Commonwealth of Virginia. However, APC asks your consideration because these proposed regulations are determinantal to the citizens and economy of Virginia – and have national implications. In our view, the Counseling Compact is a significantly better option for portability than the current (or previous) proposals.