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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6/9/15  11:10 am
Commenter: Catherine A. Kunsch, Ph.D., Eastern University


I am an assistant professor in the Counseling Psychology Department at Eastern University in St. Davids, Pennsylvania.  In addition to regional accreditation, our masters programs in Clinical Counseling and School Counseling hold national accreditation by the Masters in Psychology and Counseling Accreditation Council (MPCAC).  This organization is committed to accrediting high quality counseling programs, with a rigorous review process based on professional standards commensurate with our state licensure board for professional counseling.

We join counseling professionals from across the country to urge you to stop the proposed counselor licensing regulations that would require graduation from a CACREP-accredited program for licensure in Virginia.  A careful look at the data will reveal that counselors who have graduated from CACREP programs are not more effective in their work with clients or in their service to their communities. There is also no evidence to support that counselors from CACREP-accredited programs are more ethical or more helpful to clients or the communities within which the counselors practice. There is a great need now for mental health services. A regulation limiting practice would not serve the people of Virginia well given that a majority of master’s level counselor training programs are not CACREP-accredited. A restriction such as this would negatively impact current students and alumni from non-CACREP affiliated VA programs; negatively impact the public by reducing access to qualified counselors; negatively impact relocation of qualified and competent counselors from non-CACREP programs; reduce overall services available to VA residents; and increase cost of graduate education. Even within the American Counseling Association (ACA), the largest national counseling association, there is significant opposition to the CACREP-only restrictions highlighted in the rationale for this regulatory change.

The people of Virginia need a strong Board that protects their rights to access quality mental health care. I urge you to stop this proposal and ensure that the people of Virginia will continue to rely on the strength of your licensing Board, and not on the agenda of an independent organization with no public oversight or accountability.  Please note, a similar attempt to monopolize licensure of counselors was undertaken (and subsequently overturned) in New Jersey.  We hope your state does avoids the mistakes made there and keeps open the licensing of counselors to those who meet your state standards, rather than the interests of only one organization.


Catherine A. Kunsch, Ph.D.

CommentID: 40147