June 18, 2014

Ms.  Catherine Chappell

Executive Director

Virginia Board of Counseling

9960 Maryland Dr.

Suite 300

Richmond VA, 23233

RE: Chapter 20 Fast-Track Regulations

Dear Ms. Chapell,

We have reviewed the proposed changes to Chapter 20 and request the Board keep language that identifies CACREP-approved programs as meeting §54.1-3500 of the Code of Virginia definition of a graduate counseling degree program. As a respected institution with professionally recognized counselor preparation programs, we respectfully request that our feedback be considered before finalizing the proposed fast-track regulations.

Capella’s Programs

Capella University it accredited by the Higher Learning Commission and is a member of the North Central Association of Colleges and Schools (“NCA”). We offer graduate and undergraduate degrees and certificate programs in a variety of fields to students across the country. Our Master of Science (MS) in Mental Health Counseling program is accredited by the Council for Accreditation of Counseling and Related Educational Programs (CACREP). Our MS in Mental Health Counseling program has been serving Virginia residents for many years, and we have many successful alumni from our degree programs who have gone on to their mental health counseling residency in Virginia.

Maintain CACREP-approved Program Language in the Proposed Rules

Capella recommends the Virginia Board keep the language in 18VAC115-20-49(A) that states, “Programs that are approved by CACREP or CORE are recognized as meeting the definition of graduate degree programs that prepare individuals to practice counseling and counseling treatment intervention as defined in §54.1-3500 of the Code of Virginia” as well as any related definitions of CACREP programs. CACREP accreditation assures quality and rigor in a counselor preparation program. A program’s quality and rigor help produce high quality counselors who better serve the public. CACREP accredited mental health counseling program are clearly programs designed to prepare individuals to practice counseling and should continue to be recognized as such in your rules.

In addition to protecting the public, many states that are geographically close to Virginia use CACREP as a way to “pre-evaluate” a counseling program so the Board is able to use its scarce resources more effectively. Keeping CACREP-approved program language in the rules is consistent with other state credentialing boards in surrounding states such as West Virginia (http://www.wvbec.org/images/27-01_07-01-07.pdf), Tennessee (http://www.state.tn.us/sos/rules/0450/0450-01.20140407.pdf), Ohio (http://cswmft.ohio.gov/pdfs/4757.pdf), and New Jersey (http://www.njconsumeraffairs.gov/chapters/Chapter%2034%20Subchapters%2010_30%20%20Professional%20Counsellors.pdf ).

Conclusion

Capella requests that the Board amend the proposed fast-track regulations to keep the language in 18VAC115-20-49(A) identifying CACREP-approved programs as meeting §54.1-3500 of the Code of Virginia definition of a graduate counseling degree program.

Regards,

Sam Sands

Licensure Consultant, Capella University