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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3/29/22  2:50 pm
Commenter: Dr William Sharp

Opposition to monopolies and lack of evidence-based implications
 

I strongly oppose the distinction between CACREP and non-CACREP schools implied in this legislation. I have seen no evidence that the 2 years most masters students spend in a CACREP counseling program would be able to be licensed as a professional counselor more than three times faster than someone graduating from a regionally accredited non-CACREP program (the 3 years versus 10 years stated in the legislation). The distinction would create a monopoly for CACREP schools and the loss of a number of small colleges and university programs which have produced competent clinicians as no one would choose those schools if they had to work at diminished wages for 10 years versus 3. Inclusive and supportive alternatives are circulating nationwide now and would be a better option, i.e. interstate compacts to support license portability which would benefit both the public and the provider. These are supported by both professional counseling associations-- ACA and AMHCA. This legistation would amount to monopolies and has no basis in research or evidence which mental health should strive to be.

CommentID: 120970