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 Proposed
Comment Period Ended on 7/14/2017
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5/16/17  8:52 am
Commenter: Larry Epp, Ed.D., LCPC, Past President, Maryland Chapter, LCPCM/AMHCA

Opposed: Regulation will Diminish Access to Mental Health Professionals in Virginia
 

This initiative is an implicit attempt by CACREP accredited universities to achieve market exclusivity in licensure. It will gradually eliminate or harm graduate programs that offer Masters degrees in Counseling Psychology, Creative Arts Therapy, Clinical Psychology, Sports Psychology, Forensic Psychology, among others, that qualify for licensure as a mental health counselor. In a CACREP-only state, these degree programs would not be recognized or approved by the state professional board; and the degree holder would be unable to practice as a mental health counselor.

I support an inclusive vision of mental health counseling, based on meeting course and clinical experience requirements, not degree title or accreditation. I am very concerned when an accreditation body attempts to create an educational monopoly, based on unproven claims of superiority, and does not allow alternative accreditation bodies to approve equivalent routes to mental health counselor licensure.

The Commonwealth of Virginia should be working toward parity of licensure between Maryland and Virginia to insure an ample supply of mental health professionals who can practice in Virginia; since such a policy would allow all Virginia residents access to highly qualified mental health professionals who could relocate from Maryland, if needed. Unfortunately, that is not the stance the Commonwealth is taking. They wish to make licensure more restrictive based on graduate program accreditation, an arbitrary standard, rather than the competency or experience of the practitioner. The narrowness of this approach is curious at a time when Virginia is in need of highly qualified mental health professionals to treat their residents.

CommentID: 59121