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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6/30/15  2:24 pm
Commenter: Kristen Anderson, LPC

Strongly Oppose

As a licensed professional counselor currently providing mental health treatment in the state of Virginia I strongly oppose limiting access to licensure based on graduation from a CACREP accredited school. There is little to no proof that those who graduate from CACREP accredited schools perform better or provide better treatment to those they serve. Schools with reputations for excellence would be excluded from this list, such as: Columbia, Seton Hall, Johns Hopkins, George Mason, and many more. Regulatory changes of this type would only serve to limit access to licensure for otherwise extremely qualified applicants. It could also serve to unintentionally, and unfairly, discredit individuals who are currently practicing and hold degrees from non-CACREP accredited institutions. Although this legislation grandfather's in individuals who are already licensed, it sets a dangerous precedent that could lead to further regulations in the state and among insurance companies that further restrict the provision of care based on CACREP accreditation. Restricting care provision to CACREP only clinicians would likely result in eliminating access to some of the most experienced and knowledgeable counselors who attended school at a time when CACREP did not widely accredit.

The unfortunate result of this short-sighted regulation change would be a restriction in access to mental health treatment across the state of Virginia. Virginia has already seen it's share of heartbreak related to untreated mental illness. It is critical that further impediments are not put in the way of mental health treatment.

The state licensing board in Virginia has an extremely rigorous set of standards for licensure, the most rigorous in our region. This process already does an excellent job of assuring quality. An arbitrary standard that has not been proven to accurately measure the quality of a person's education does NOT need to be included in these standards.

CommentID: 40474