Agencies | Governor
Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Counseling
 
chapter
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]
Action Requirement for CACREP accreditation for educational programs
Stage NOIRA
Comment Period Ends 7/1/2015
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6/28/15  3:32 pm
Commenter: Sue Shekut, LPC

Opposed to CACREP Only Petition, Make Licensure Inclusive for All Accredited Counselors
 

I strongly oppose the proposed requirement for licensed professional counselors in Virginia to graduate from a CACREP only program for the following reasons:

1. The petition restricts counselors from non-CACREP counseling psychology programs from obtaining LPC licensure in Virginia. Counseling psychology programs utilize psychologists versus counselor educators to teach master’s level counseling classes. With few exceptions, CACREP programs use only PhDs in counselor education to train counselors. But the course content and theories are the same for both CACREP and non-CACREP programs.  And counseling psychology graduates have been licensed as professional counselors and members of the ACA since the beginning of counseling licensure.    

2. CACREP programs are not the only programs with 60 credit hours requirements.  In fact CACREP is still in the process of converting even CACREP-accredited 48-credit Community Counseling programs to their newer 60-credit CMHC standard and allows CORE programs to maintain their 48-credit hour standards. (http://www.cacrep.org/for-programs/) Many regionally accredited universities (and State Boards) now require 60 credit hours for a master’s level counseling program.

3. The petitioner claims that the petition is an attempt to clear up confusion by veterans over which counselors will accept their insurance. To avoid public confusion and ensure that veterans know which counselors accept their insurance, all that needs to be done is for counselors to determine if they are able to accept insurance and post a list of the insurance carriers they accept on their websites and brochures. This should not be the burden of the state.

Changing Virginia state law will actually increase public confusion. Thousands of competent seasoned non-CACREP counselors throughout Virginia will face increasing public confusion as to their competence. Requiring CACREP-only graduates may result in the public avoiding non-CACREP counselors in the future, even if they are grandfathered in today. A public which expects CACREP (despite no credible evidence of its superior quality) could start demanding CACREP and start discriminating against counselors without this accreditation in their past.  Grandfathering in counselors from non-CACREP schools while still requiring CACREP will only confuse the public. This could result in lack of employment for non-CACREP counselors, even in situations where they are licensed and eligible to help with Virginia’s burgeoning mental health community needs.  This could also adversely effect non-CACREP counselors acceptance by private insurance companies in the future. Potentially reducing the number of available counselors at a time when suicide and other mental health issues are at an all time high among Virginia veterans is a mistake.

4. In addition, requiring CACREP-only graduates reduces the number of counselors from other states that may want to relocate in Virginia. I graduated from a 60-credit hour counseling psychology program in Illinois with 63 credit hours and a 4.0 average. Some of my coursework exceeds CACREP requirements. I also completed a 1000-hour internship and scored high on the National Counselor Exam. Yet, if I want to move to Virginia, I would be denied licensure if this petition passes. It does not serve the residents of Virginia If this petition passes and then qualified, well-educated, and well-trained counselors cannot practice in the state. Instead of improving licensure portability, this petition further restricts it.

5. Although the petition states that requiring CACREP is needed because a few federal agencies currently require CACREP, that is no reason to change state law in Virginia. CACREP-only requirements place an unfair burden on Virginia counseling business owners and on counseling clients in Virginia who are looking for easy access to counselors in their communities. And many counselors are actively advocating with TRICARE to expand coverage to qualified non-CACREP counselors.

6. Despite public relations efforts to the contrary, CACREP is not an old and very established standard for mental health counseling. CACREP spent much of its early history accrediting school counseling (school psychology at one point) and has only recently accredited larger numbers of mental health counseling programs. The majorities of non-CACREP programs in this country are regionally accredited by CHEA and must maintain high quality standards. While I agree that CACREP counselors should be allowed state licensure, restricting counselor licensure solely to CACREP counselors does not help veterans and Virginians in need of mental health services.

7. When State Boards cede control of their standards to an outside entity, they lose control over serving the needs of their state constituents.  Many other State Licensing Boards examine counseling programs across the country assess the quality of the education in counseling programs.  They typically require regional CHEA accreditation (for quality) and then require coursework in a variety or required categories.  Sometimes they choose to look for "CACREP-equivalency."  The Virginia Board may look to discussions amongst the various State Boards at the AASCB association for guidance and a voice in helping craft national standards are enacted for standardization and license portability.  

8. CACREP is a six-person organization, which may change its name in the future, and has historically changed educational standards over time. Relying on one small organization to dictate Virginia’s counseling licensure standards does not serve the public good. The majority of state boards provide a list of required coursework, standards for practicum experience and the requirement of a national exam for counselor licensure. Both CACREP and regionally accredited non-CACREP programs must produce graduates that meet or exceed these standards. Maintaining coursework and experience standards ensures that licensed counselors in Virginia all meet the same expectations, without ceding control of those standards to an outside agency based on the agency name alone.

9. Furthermore, several professions have two or more recognized accrediting authorities.  With variety comes a greater opportunity for a diversity of training to ensure a flexible and responsive counseling workforce for the unique needs of individual clients. 

The people of Virginia need a strong Board that protects their rights to access quality mental health care. Please oppose this petition and work to make Virginia Counseling licensure inclusive for all counselors who meet the educational coursework completion standards, national testing and experience requirements for counseling. 

Sincerely,

Sue Shekut, MA, LPC, Graduate of Roosevelt University

 

CommentID: 40426