Agencies | Governor
Virginia Regulatory Town Hall
Department of Health Professions
Board of Counseling
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]
Action Requirement for CACREP accreditation for educational programs
Comment Period Ends 7/1/2015
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6/7/15  1:18 pm
Commenter: George N. Rathbone, Developmental Support Associates, LLC

CACREP alone will rule out seasoned counselors

My graduate training was at Columbia University in the early to mid 1980's when nobody had heard of CACREP, and that accreditation was not available to me at that time. Requiring attendance at a CACREP approved program will rule out virtually all of our most seasoned and highly skilled counselors, and it is a de facto form of age discrimination that bears no demonstrated relationship to job performance. As such, it will surely result in wasteful and unnecessary litigation if some kind of grandfathering process is not in place for mature counselors. 

At a time when our country was begging for mental health therapists for our veterans, the CACREP requirement by TRICARE prevented me from being able to help many military families, despite my considerable training and skills. This appears to be a territorial battle over money and power that will only undermine the state's and country's already weak community mental health systems.

In addition, many of the finest counselor training programs are still not CACREP accredited, even in Virginia. This means that many of our best trained recent graduates will also be blocked from certain practices by any CACREP credentialed requirement. It is very hard to understand, in an era where mental health and behavioral dysfunction are growing rapidly, why it makes sense to bar practice to or reimbursement to any trained group of mental health practitioners.

On a more personal note, my professional focus is on developmental disabilities and behavioral disorders. It appears that Virginia schools are "graduating" a geometrically increasing number of students who exhibit severe behavioral or mental health challenges that require intensive and long term intervention and support. In many cases these citizens end up on waiting lists for services, which means that our jails and emergency rooms are being substituted for treatment. I can think of few "solutions" that are more costly, inhumane and counterproductive. Why would anyone want to exclude qualified professionals from the effort needed to remedy this situation?

CommentID: 40097