As a provider of mental health services in the Commonwealth for five years, I oppose the proposed change to licensure requirements that would restrict LPC licensure to graduates of master's programs accredited by CACREP. Although accreditation is a helpful and important standard within the sphere of education, I believe that limiting access to licensure for master's-level clinicians will be ultimately harmful to a public that is markedly underserved. There is currently no empirical evidence that graduates of CACREP-accredited programs are more competent or more ethical than their counterparts from non-CACREP programs. Additionally, my own experiences working in both community mental health and university counseling settings have shown me clearly that my CACREP-trained colleagues are not meaningfully different from colleagues who held LPC licensure but were trained in different programs (for example, the very well-respected counseling program at George Mason University). Additionally, the proposed changes would place unnecessary restrictions on transfer of LPC licensure by clinicians moving into Virginia from other states where licensure is not dependent on CACREP accreditation, and would restrict the pool of individuals eligible for hiring in training programs for counselors. The end result would be an exclusion of qualified, committed training staff in academic programs and an exclusion of qualified, committed clinicians in the field, all based upon an arbitrary standard set by an out-of-state accrediting agency. Therefore, I respectfully ask the Board of Counseling to reject the proposed changes, and to consider an inclusive approach which allows multiple paths to licensure. The Masters in Psychology and Counseling Accreditation Council (MPCAC) is one alternative to CACREP whose standards for training meet or exceed the standards for training imposed by CACREP. An approach to licensing which is more inclusive of diversity in training, rather than the more exclusive approach suggested by the proposed changes, will provide greater benefit to the citizens of this Commonwealth, including those whose needs are greatest.

Respectfully,

Michael M. Love, MS

Doctoral candidate in counseling psychology, Radford University

Psychology intern, Virginia Tech