I strongly OPPOSE the requirement for CACREP accreditation for education programs. For over 30 years, the Virginia licensing board evaluated candidates on the basis of their coursework, training, and ability to demonstrate their knowledge and competence on the objective licensing exam, rather than on a subjective philosophical distinction between “counselors” and “psychologists” or on a particular type of accreditation. At the completion of all required coursework and other requirements, every individual was required to take the licensing exam. An individual who passed became licensed as an LPC. Those who did not pass, did not. Thus, evaluation of who would be licensed as an LPC in Virginia and who would not was made based on an individual’s competence, as evidenced by the objective licensing exam.

 I am not sure of the exact timeline, but somewhere around 2009, that standard for evaluation changed. The licensing board made a dramatic shift in the interpretation of the regulations such that individuals who had been trained in a non-CACREP accredited program in clinical psychology were now turned down when they applied for approval for registration of supervision. Because these individuals were not allowed to complete this step, they subsequently were prohibited from the opportunity to take the licensing exam. In other words, the licensing board put up a barrier for these individuals which prohibited them from the opportunity to demonstrate their competence through passing the licensing exam. It is a travesty that some of these qualified individuals who were trained in Virginia ultimately had to move to another state in order to become licensed professional counselors.

 As best I understand it, this appears to be an issue of guild-protection, rather than competence-protection, or protection of the public. I firmly believe that the citizens of Virginia deserve the best mental health services that the Commonwealth has to offer and thus I am fully supportive of a licensing board that regulates mental health services. However, I am greatly concerned that the licensing board is now blocking highly trained and competent mental health professionals from obtaining that license due to a subjectively determined philosophical distinction that CACREP makes between “counselors” and “clinical psychologists”, rather than on relevant coursework, completion of all other requirements, and performance on the objective licensing exam.

For the purpose of clarity, at the bottom of my comments I have included the exact wording pasted from the Regulations Governing the Practice of Professional Counseling (18VAC115-20-49) and also from section § 54.1-3500 from the Code of Virginia. Currently, Letter A of the regulations does not state that an applicant must have graduated from a CACREP accredited program. Rather, it states that, by definition, such a program is automatically 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”. However, letter B states “The applicant shall have completed a graduate degree from a program that prepares individuals to practice counseling and counseling treatment intervention, as defined in §54.1-3500 of the Code of Virginia, which is offered by a college or university accredited by a regional accrediting agency and which meets the following criteria: 1)  There must be a sequence of academic study with the expressed intent to prepare counselors as documented by the institution; 2) There must be an identifiable counselor training faculty and an identifiable body of students who complete that sequence of academic study; and 3) The academic unit must have clear authority and primary responsibility for the core and specialty areas”.

Definitions provided for “counseling”, “practice of counseling,” and “professional counselor” in §54.1-3500 of the Code of Virginia are provided below. Specifically, "professional counselor" is defined as “a person trained in the application of principles, standards, and methods of the counseling profession, including counseling interventions designed to facilitate an individual's achievement of human development goals and remediating mental, emotional, or behavioral disorders and associated distresses that interfere with mental health and development”. One would be hard-pressed to argue that psychologists do not meet this definition, or that psychology program cannot a) adequately provide a sequence of academic study with the expressed intent to prepare counselors, b) be considered an identifiable counselor training faculty, and c) have clear authority and primary responsibility for the core and specialty areas. Thus, graduates from

Master’s level Clinical or Clinical-Counseling Psychology programs that are not CACREP accredited should not be denied the opportunity to apply for licensure and take the licensure exam on any of these grounds.

However, I am aware of highly trained and competent individuals who graduated from a master’s degree program in Clinical Psychology from an accredited university in Virginia, whose applications to proceed with licensure as a Licensed Professional Counselor were denied because the Credentials Committee determined that their course of study did not meet the requirements set forth in regulation 18VAC115-20-49. Three specific reasons have been cited: “there was insufficient emphasis on counselor preparation in the academic curriculum and program description, there was a clear intent to prepare students to become clinical psychologists rather than counselors, or the faculty roster does not have an identifiable counselor training faculty”. While I understand that the licensing board evaluates the credentials of individual applicants rather than university programs per se, the stated reasons that these individuals were denied suggest that the board takes issue with the discipline of clinical psychology itself, rather than with the actual training or coursework provided by the program or the competence of the individual applicants. The stated reasons for denial seem to imply that the training provided by doctoral level psychologists in a master’s level clinical psychology program is so different than that provided by doctoral level “counselors” that, by definition, such graduates are not even eligible to apply for licensure as an LPC in Virginia. But that is what CACREP clearly implies. Clearly, psychologists have a long history in training competent mental health professionals at both the masters and doctoral level in the Commonwealth. It would be ludicrous to argue that clinical psychologists are not trained in “counseling” as defined in § 54.1-3500 and listed below. It would also be ludicrous to argue that clinical psychologists have no role in training master’s level mental health professionals, or that the students they train are not competent to become master’s-level licensed mental health professionals and earn the LPC in Virginia.

Therefore, I urge the board to return to the position it held for over 30 years, whereby individuals applying for licensure would be judged on the basis of their coursework and competence, not on the philosophical orientation of the program from which they graduated or based on the narrow definition used by CACREP. I believe the current distinction between master’s level “counselors” and “clinical psychologists” would be analogous to the Board of Medicine deciding that it would no longer license individuals from a Virginia medical school who graduated with a D.O. rather than an M.D., which is something that the medical board does not do.

In summary, the Commonwealth of Virginia does not have room for guild issues regarding who can become an LPC and who cannot. This is evident by the numerous comments already posted.

Such CACREP-only restrictions are unneeded and do not enhance the protection of the public, which is ultimately what the Board of Counseling is designed to do. The comments clearly suggest that many mental health professionals and agencies oppose this petition and that the proposed regulations will hinder their ability to hire qualified mental health professionals and to fill vacancies in their region. Given that there is a serious shortage of mental health professionals in the Commonwealth and many regions are severely underserved, I strongly advocate that competent graduates from non-CACREP accredited programs in Clinical or Clinical-Counseling Psychology who have met all other requirements be deemed eligible to sit for the licensing exam in Virginia.

Let the coursework and licensing exam be the determinant of who is a competent mental health professional and who is not.

Respectfully,

Ann Elliott