Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Counseling
 
chapter
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]
Action Changes resulting from periodic review
Stage Proposed
Comment Period Ended on 4/1/2022
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3/28/22  11:40 am
Commenter: Jennifer M. Taylor, Ph.D., Associate Professor and Training Director

In Opposition
 

I am writing to express my opposition to this endorsement proposal that would require licensed counselors from non-CACREP programs be required to show 7 more years of experience than their peers who graduated from CACREP programs. 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, particularly as there are other national accrediting bodies (e.g., MPCAC, which is a CHEA-recognized accrediting organization) that prepare students with rigorous training standards. Many MPCAC programs (ours included) meet and exceed CACREP's training requirements, with the sole exception that the Ph.D. degrees of our faculty are in Counseling Psychology rather than Counselor Education. 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 at a time when the people of Virginia need greater, not reduced, access to mental health care. 

CommentID: 120889