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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3/30/22  1:04 pm
Commenter: Susan Woodhouse, Ph.D.

Strongly Oppose
 

This is a harmful idea that would needlessly limit the mental health services available to the people of Virginia and would result in the groundless restraint of trade. Licensed counselors contribute in important ways to public health and mental health, and CACREP seeks to restrict duly trained professional counselors from being able to serve the people of Virginia for 10 years, under the mistaken notion that those trained in accredited programs outside of the CACREP system need additional practice post-training (10 years as compared to 3 years for CACREP). This is patently false. There are other accrediting bodies that legitimately provide OUTSTANDING training for licensed professional counselors. There is absolutely no evidence that counselors educated in CACREP-accredited programs are better prepared than professional counselors that are educated in MPCAC-accredited programs. It is time for the public and lawmakers to be aware of the fact that CACREP is attempting to create a CACREP monopoly by falsely implying that there is only one legitimate way to accredit professional counseling program. This is simply not true. The public would be harmed by this baseless restraint in trade that would limit access to needed treatment by the public in Virginia. This would harm the citizens of Virginia. 

Other states have recently passed legislation to get rid of restrictive laws much like this current proposal. For example, see FLA SB 566 (Mental Health Professional Licensure). 

There is a national legislative initiative, which is supported by the professional organizations for Professional Counselors, to develop interstate compacts with a reasonable universal license portability standard of 3-years post-license practice. The Department of Defense has supported the idea of such interstate compacts. Moreover, the FTC issued a report in 2018--citing the Department of Defense--saying that the FTC also supports interstate compacts as a way to efficiently and effectively resolve this issue and avoid unnecessary restraint of trade.

There is nothing wrong with CACREP accreditation. However, CACREP is not the only strong accrediting body in our nation. Another important accrediting body is MPCAC--which stands for Master's in Psychology and Counseling Accreditation Council (http://mpcacaccreditation.org). Other professional organizations are likely to create strong accreditation standards as well. There is no reason to limit practice based on CACREP, because the public health is also well-served by these other accrediting bodies. 

CommentID: 121001