As someone deeply involved in the training of licensed professional counselors (LPC), I am writing in response to a Notice of Intended Regulatory Action in Virginia.  I 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). There are are a number of legitimate, accredited, and truly excellent training non-CACREP programs in Virginia that are currently training not only competent, but outstanding counselors.

I am not against CACREP and I am not against accreditation. Nevetheless, the field of counseling and the public at large benefits from the existence of diverse programs and benefits from multiple paths to licensure.

Virginia needs a strong mental health provision system with more providers--not fewer providers. In 2013, Virginia had 47 federally designated mental health care professional shortage areas (Signer, 2014). There is a tremendous public health need for these shortages to be addressed. Supporting excellent existing programs that are already training outstanding graduates who become LPCs would best protect the people of Virginia.

There are renown counseling programs in Virginia that are not affiliated with CACREP. George Mason University, for example, is not affliated with CACREP--yet in 2013 was awarded the Outstanding Master’s Program award by the Southern Association for Counselor Education and Supervision.

You may not be aware that there are other accrediting bodies, besides CACREP,  that are legitimately able to ensure top-quality masters-level training program. You may not be aware, for example, of the Masters in Psychology and Counseling Accreditation Council (MPCAC). You can get more information about MPCAC at  the following website: http://www.mpcacaccreditation.org/. The mission of MPCAC is to accredit programs in psychology and counseling that promote training in the science-based and multicuturally-competent professional practice at the master's level. The standards promoted by MPCAC are very similar to--and in some aspects, exceed--the standards promoted by CACREP. These are BOTH organizations that promote responsible standards for master's-level counselors.

The licensing board's mission is to protect the citizens of Virginia through the regulation of licensure. I urge you not to give up the setting of educational requirements that will meet the needs of diverse Virginia citizens to a single, out-of-state accrediting body.

There is absolutely no evidence to suggest that those who graduate from CACREP programs are more effective or ethical counselors. Any assertion to the contrary is unscientific and based on methodologically unsound approaches.

Adopting a CACREP-only stance would restrict trade for LPCs in Virginia and limit the amount of high quality care availabie to Virginia citizens. This would result in a brain-drain, with high quality trainees moving to other states without the senseless restriction. LPCs considering a move to Virginia would go elsewhere.

Like many others, I urge the Commonwealth of Virginia NOT to approve this change in regulation. It is clear to me that Virginians would be best served by a diverse body of LPCs. CACREP is not the only route to high quality care for the people of Virginia.

Sincerely yours,

Susan S. Woodhouse, Ph.D.