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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6/28/15  1:37 pm
Commenter: International Association of Rehabilitation Professionals

Opposition to proposed CACREP language

Dear Board of Health Professionals,

The International Association of Rehabilitation Professionals (IARP), a premier national association representing rehabilitation counselors throughout North America, is offering a position statement regarding proposed changes to required credentials for licensure as a Licensed Professional Counselor in Virginia.  As a national professional organization, we have concerns that the proposed language could directly result in the restriction or preclusion of highly qualified rehabilitation counselors from continuing to practice in their chose profession, and earning a living.   IARP believes the proposed changes will ultimately have the effect of restricting rehabilitation counselors from providing services to the citizens of Virginia with mental illness and/or physical disabilities.

Ensuring the highest quality rehabilitation counselor credentials is very important to the IARP professional association.  Credentialing serves to protect the citizens of Virginia.  IARP is in support of highly qualified licensed counseling professionals.  We believe these qualified professionals are found in both the ranks of Council for Accreditation of Counseling and Related Educational Programs (CACREP) and Council on Rehabilitation Education (CORE) accredited higher education programs.  Both accrediting bodies certify programs recognized by the Council for Higher Education Accreditation (CHEA.)  Any potential limiting of these recognized bodies would disenfranchise the citizens of Virginia.

The CACREP language “require graduation from a clinically-focused counselor preparation program accredited by CACREP or an approved affiliate of CACREP “ is troubling because it has the potential to be exclusive.  Currently, CORE is a recognized affiliate but if CORE falls out of favor with CACREP those persons who have graduated from exceptional rehabilitation counseling programs across the country will not be able to obtain licensure in Virginia.  This is a valid concern because it is already playing out at the federal level.  Members of our profession, who attended CORE accredited graduate programs and are licensed, that have been practicing for years and have dedicated their lives to helping individuals with disabilities, have been eliminated from hire or affiliation with the Veterans Administration and Tricare.  We suggest that language such as “and CORE” be considered.

The CACREP “only” mentality at the federal level impacts thousands of Veterans who have sacrificed for their country and are under served by the Veterans Administration are further limited in getting access to skilled Licensed Professional Counselors that have expertise in areas such as Traumatic Brain Injury which is one of the leading impacts on Veterans in current warfare.  We do not want this to become the plight of the Virginia citizens needing clinical counseling services.

Please carefully consider developing more inclusive language as shared above.  This will protect the citizens of Virginia from both the perspective of losing the ability to earn a living in some cases and, in others, access to important mental health services.  It also protects the citizens by requiring highly skilled Licensed Professional Counselors to serve the citizens of Virginia.   

Rick Robinson, MBA, Ph.D., CRC
International Association of Rehabilitation Professionals
1926 Waukegan Road, Suite 300
Glenview, IL  60025-1770
Phone: (888) 427-7722

CommentID: 40425