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  4:58 pm
Commenter: Catherine D NUGENT

Oppose this Legislation. Support the Counseling Compact Instead
 

I oppose the proposed legislation because it is precedented on an unproved claim--that graduates of CACREP-accredited programs are somehow more qualified than graduates of non-CACREP programs. There is no evidence to support this claim. Instead of this faulty framework, please support the Interstate Compact. This Compact would allow licensed counselors to practice across state lines, provinding services in a state in the Compact. During the pandemic, when licensure regulations were relaxed and waivers or temporary licenses easily availble, I began counseling with a client in DC. She sought my services particularly because of special expertise and training I have. When the waivers were ended, I had to refer this client to someone licensed in DC. (I am licensed in MD.) This was 6 months ago, and so far, she has not been able to find a therapist to meet her needs. This anecdote illustrates the fact that arbitrary licensure laws and regulations can run counter to a client's needs and preferences, denying a client the right to have continuity of care and choice of an expert provider who may not live in their state. Thank you for your consideration.

 

CommentID: 120918