The program at New York University that I direct educates Master’s level mental health counselors. I am writing in response to the NOIRA concerning licensure of mental health counselors in Virginia. Our program strongly opposes the proposed change to limit licensure to graduates of programs accredited by Council on Accreditation of Counseling and Related Educational Programs (CACREP). The program’s position is that multiple pathways to licensure that are inclusive of graduates of programs, whether from CACREP programs or those unaffiliated with CACREP, meets the needs of the citizens of Virginia, specifically those in need of mental health services. The following points support the program’s position:

1)    Virginia has a shortage of mental health counselors (Signer, 2014), and a substantial population in need of mental health services (National Association for Mental Illness). Adopting CACREP only licensure requirements will reduce the number of qualified mental health counselors to serve the population in need.

2)     Licensure is designed to provide for the needs of the consumer who seeks services. Licensure is not designed to protect professional turf. By adopting CACREP only requirements, the Virginia licensing board will be limiting consumer choice without enhancing quality. 

3)    There is no evidence that supports the supposition that CACREP graduates are more effective or ethical counselors that those from unaffiliated programs. Evidence cited to the contrary comes from research with serious methodological weaknesses.

4)    There is another mental health program accrediting body, the Masters in Psychology and Counseling Accreditation Council (MPCAC), through which programs can achieve accreditation. Its standards are also rigorous in promoting quality education. Virginia’s proposed restriction would prohibit graduates of these programs for becoming licensed.

5)    Virginia has programs of high quality that are not accredited by CACREP. For example, George Mason University’s program was designated the Outstanding Master’s Program in 2013 by the Southern Association for Counselor Education and Supervision. Under the proposed regulations graduates of this excellent program would be denied licensure in Virginia.

6)    The proposed change in regulations would unnecessarily exclude well-trained and qualified mental health counselors from serving Virginia’s population in need of services. 

We strongly encourage the Virginia licensing board not to adopt the proposed restrictive licensure regulations.