To ensure safe and competent patient care as outlined in the mission statement of the Department of Health Professions the Board should return to previous interpretations of regulations which emphasized academic training based on course content and demonstrated competence on internship and supervised practice rather than professional identification. Like many CACREP approved programs housed in Psychology Departments, the Board has historically considered graduates from accredited Clinical and/or Counseling Psychology Master's programs as meeting the academic requirements to initiate LPC credentialing. A distinction between counseling and psychology and clinical seems arbitrary given many CACREP approved programs, including some in this state, are in Clinical Mental Health Counseling. Virginia and Virginians are ill served when the Board limits those with demonstated competence to practice and serve individuals with mental, emotional, or behavioral disorders because of a putative distiction between the practice of counseling as defined in the code by those trained in counseling versus those trained in counseling or clinical psychology. An individual suffing from mental illness wants a skilled clinician irrespective of a degree in counseling or in psychology.   

   By not allowing competent clinicians who meet the course and practice requirements to become licensed professional counselors fewer clinicians are available to serve those in need, and equally important state agencies lose a revenue steam from their employees becasuse they can not bill for their services. This has resulted in long-term employees with demonstrated competence to lose their position within public mental health facilities and places an additional  financial burden on the agency. 

   It is unclear that the Board's recent rejection of applicants historically approved for the LPC from accredited Master's psychology programs from Virginia state schools was the result of a disproportionate rate of professional violations by such individuals, a result of increased public harm, or that the policy change increased the public welfare. If the Board can not provide the public, the Department of Health Professions, and the state legislature documentation as to unique and disproportionate harm by those who with Master's in psychology who meet the coursework and experience requirements then they should revert back to their past interpretation of code and allow such graduates to obtain the LPC.

   The Board should first and foremost ensure the competent practice of those counseling individuals suffering from mental illness through documenting coursework and clinical training. Emphasizing professional identity over documented training limits the public, and state agencies mandated to provide services to those suffing from mental illness. Counseling by a competent counselor from a counseling program or clinical/counseling psychology program is a distinction without a difference and does not best serve Virginia. Please reinstitute the prior regulatory interpretation of the regulations and allow graduates from accredited Master's programs in clinical/counseling Psychology in Virginia to become credentialed as an LPC.

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