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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6/18/15  10:28 am
Commenter: Alyssa Dietz, University of Baltimore


As a faculty member in a program that trains licensed professional counselors

(LPCs), I am writing to strongly oppose any regulatory change in Virginia that would 

limit LPC licensure to graduates of master’s programs accredited by the Council on 

Accreditation of Counseling and Related Educational Programs (CACREP). Based on 

my belief in multiple paths to licensure as an LPC, my stance is neither anti-CACREP 

nor is it anti-accreditation. The field of counseling and the public using mental 

health services benefit from graduates of diverse programs, multiple paths to 

licensure, and from inclusivity of graduates from all accredited counselor 

preparation programs – CACREP or otherwise. My perspective on the proposed 

regulatory change is shaped by the following considerations: 

? Diversity and inclusion in mental health is of paramount importance. In a 

? Given the state of mental health care in Virginia, more service providers – 

? The proposed change would unnecessarily restrict trade of LPCs in 

? The proposed regulatory change also limits the hiring of mental health 

? The role of the licensing board is to protect the citizens of Virginia 

? There is no empirical evidence to suggest that CACREP graduates are 

time of integrated care and rising mental health needs, mental health 

providers are called to work together for the good of the public’s health 


rather than fewer service providers are needed. For example, according 

to the National Association for Mental Illness (NAMI), only 19% of 

Virginians with serious mental illness receive services from Virginia’s 

public mental health system. And, as of 2013, Virginia had 47 federally 

designated mental health care professional shortage areas (Signer, 2014). 

Addressing this shortage requires that Virginia protect and support 

valuable counselor training programs  – rather than close them due to the 

administrative and financial limitations of achieving CACREP 


Virginia and LPCs moving into Virginia. This includes LPCs from 

neighboring states that do not restrict licensure to a particular 

accrediting body. 

professionals outside of counselor educators as full-time faculty members 

in CACREP-accredited training programs, which in turn restricts quality 

supervisors, educators, and mental health providers from sharing their 

expertise in training and supervising new counselors in the state of 


through the regulation of licensure, and not accreditation. To cede the 

power of setting educational requirements that meet the needs of 

Virginians to a single, out-of-state accrediting agency does not protect the 

citizens of Virginia. Further, doing so may step beyond the charge of the 

counseling board.

more effective or more ethical providers, and commonly cited evidence to 

the contrary is methodologically unsound. 

? Counseling programs in Virginia that are not affiliated with CACREP are 

? There are other paths to accreditation of counseling programs. For 

renowned. For example, in 2013, the counseling program at George 

Mason University – a program that is not affiliated with CACREP – was 

awarded the Outstanding Master’s Program award by the Southern 

Association for Counselor Education and Supervision. 

example, the Masters in Psychology and Counseling Accreditation Council 

(MPCAC) accredits counseling programs and requires that programs 

meet a standard that meets (and in some domains exceeds) the rigor of 

CACREP standards. 

I strongly recommend that the Commonwealth of Virginia not approve this change. 

Instead, I strongly believe that Virginians will be best served by a diverse body of 

LPCs, and not only those with degrees from programs affiliated with CACREP.  


Alyssa Dietz

CommentID: 40258