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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4/1/22  3:07 pm
Commenter: Society of Counseling Psychology, via Kimberly Howard

Strongly oppose
 

The Society of Counseling Psychology (SCP) is a national organization of counseling psychologists and counselor educators that supports interdisciplinary cooperation and licensure portability.  As a professional group, we are writing to express our strong opposition to a specific provision in the Virginia Board of Counseling’s proposal for licensure by endorsement that we objected to in 2019 – specifically that licensed counselors from non-CACREP programs would be required to show 7 more years of experience than their peers who graduated from CACREP programs. There is no documented evidence that counselors graduating from CACREP accredited programs are better prepared for practice or more effective in their practice than counselors who have graduated from other programs.

Furthermore, we strongly believe that proposal would harm the public as it would unnecessarily limit the number of licensed counselors who would qualify for licensure in Virginia and therefore the depth and breadth of the counseling workforce in the state.   (and therefore professional counseling work) in Virginia. This is particularly problematic as we have seen the need for mental health services on the rise.  The people of Virginia need greater, not reduced, access to mental health care.

We respectfully ask that you consider how the regulations would be detrimental to the well-being of the citizens Virginia as well as to the state’s economy. In our view, the Counseling Compact is a significantly better option for portability than the current (or previous) proposals.

CommentID: 121062