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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3/31/22  10:53 am
Commenter: Crystal Hank, Psy.D., LCP, The Citadel

Strongly Oppose
 

I strongly oppose making individuals who have a non-CACREP master degrees have to have 10 (instead of 3) years of experience post-licensure in order to be eligible for licensure in VA. I am from VA originally, and in my move to South Carolina, began teaching in the Masters in Clinical-Counseling Psychology at The Citadel (which is accredited by MPCAC). I can honestly say that this program is as rigorous as even my doctorate program was (because the courses are taught by licensed clinical psychologists). There is no reason to require more years post-licensure, because our students even before graduation have been put through a comprehensive exam, a practicum placement, and an internship experience. By the time they seek the additional hours of supervised experience for licensure in SC, they are MORE THAN well prepared to work in this field. Even having a doctorate degree myself, I find that they become amazing colleagues due to their extensive training and rigorous education, and our field placements are always eager to hire our students post graduation. There is absolutely NO evidence to suggest that MPCAC accredited programs are less than CACREP accredited programs in any way. Aren't we an evidence based field? Where is the supporting research to make such a limiting decision? Please consider this, and oppose this legislation.

Kind regards,

 Dr. Crystal Hank, Psy.D., LP

Professor of Practice, Diversity and Inclusion Coordinator for the CCP, and Field Placement Coordinator, The Citadel

P:540-969-8371

E: chank@citadel.edu

CommentID: 121038