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  5:20 pm
Commenter: Susan Morgan Stork, AASECT Certified Sex Therapist in MD, NM, DE

Oppose this Legislation + Support the Counseling Compact Instead - we are in crisis in Mental Health
 
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.
 
I say this as a graduate of a CACREP school. 

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, providing services in a state in the Compact.

During the pandemic, when licensure regulations were relaxed + waivers or temporary licenses easily available, I began counseling a client in the DMV. 

She sought my services particularly because of the special expertise and training I have in Sex Therapy. When the waivers ended, I had to refer this client to someone licensed in Washington DC--  (I am licensed in MD, NM + DE.)

This was 10+ months ago, and so far, this client has not been able to find a therapist to meet their specialty needs.

This anecdote illustrates the fact that arbitrary licensure laws + regulations can be barriers to a client's needs and preferences, denying a client the right to have "continuity of care" and the choice of specialty provider who may not live in their state of licensure. 

Thank you for your deep consideration + attention to these mental health matters that impact EVERYONE in a time of a Mental Health Crisis. 

CommentID: 120922