As a resident of an underserved rural part of central Virgina, I strongly oppose the proposed action.

This proposal deprives many qualified and expertly trained professionals like myself from practicing in Virginia. While I may be able to attain licensure via "endorsement" within a year, the current licenisng process prevents me from utilizing my skills within my own town and state even though my course work, supervison, and internship meet or exceed current licensing requirements. Consequently, I drive to Maryland to practice which deprives the state of tax revenue and the local population of a needed mental health resource. 

This proposal suggests a false reliance on a marketed credentialing system that fails to show better patient outcomes, it limits access to needed mental health professionals. As noted by another respondent "Diversity and inclusion in mental health is of paramount importance. In a 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 needs". A few key considerations previously posted are of paramount concern:

• Given the state of mental health care in Virginia, more service providers – 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 accreditation.

• The proposed change would unnecessarily restrict trade of LPCs in Virginia and LPCs moving into Virginia. This includes LPCs from neighboring states that do not restrict licensure to a particular accrediting body.

• The proposed regulatory change also limits the hiring of mental health 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 Virginia.

• The role of the licensing board is to protect the citizens of Virginia 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.

This proposal is not in the best inerest of Virginia's citizens - I urge the Board to withdrawl the proposed regulatory action.