I strongly oppose the proposal to restrict initial LPC licensure in Virginia to graduates of CACREP-accredited graduate programs for the following reasons:

• There is no credible evidence that CACREP program graduates are more effective or ethical as practitioners

• Virginia already has vigorous licensure standards based on coursework and experience requirements that are similar to those throughout the country

• Costs to programs to attain and maintain CACREP accreditation are exorbitant, as noted in Virginia’s Economic Impact Statement on this topic

• An alternate accreditation, MPCAC, exists to serve those programs that CACREP does not; with the exception of one graduate course, its standards completely align with Virginia licensure requirements

• There is a shortage of qualified mental health providers in many areas; moves to restrict licensure will harm the public

• Prohibiting initial licensure to applicants trained outside of CACREP’s scope will impede commerce among sates; many states have few or no CACREP programs thus their graduates would be prohibited from initial practice in VA.  Military spouses moving to Virginia are uniquely vulnerable.

• The rationale for a CACREP-only restriction is flawed in these ways:

  • CACREP specifically excludes accreditation of programs in psychology; historically these programs have trained the majority of LPCs in the country, and emphasize grounding in research and evidence-based practice developed by psychologists

  • Restricting core faculty to doctorates in Counselor Education, as CACREP does, robs the profession of the contributions and intellectual diversity of sister professions, and robs consumers of access to professionals trained in these traditions

  • The argument that psychology and counseling are distinct professions is a false narrative; counseling psychology has played a prominent role in the development of the counseling profession; the theories and methods are indistinguishable

  • Finally, a CACREP-only restriction is not compatible with a license portability plans put forward by the American Counseling Association, which states:

    A counselor who is licensed at the independent practice level in their home state and  who has no disciplinary record shall be eligible for licensure at the independent practice  level in any state or U.S. jurisdiction in which they are seeking residence. See  https://ct.counseling.org/2017/06/aca-continues-push-forward-licensure-portability/

    and a joint proposal from the American Association of State Counseling Boards (AASCB), the Association for Counselor Education and Supervision (ACES),  American Mental Health Counselors Association (AMHCA), and National Board of Certified Counselors (NBCC), which says:

    The plan would promote acceptance of a license from another state when the individual “meets all academic, exam, and post-graduate supervised experience standards as adopted by the state counseling licensure board “ (OR holds a degree from a clinically focused counselor preparation program accredited by CACREP, OR  holds certification as  a National Certified Counselor).   See www.amhca.org/portability2017

     

    In short, a CACREP restriction on LPC licensure will reduce choices and accessibility to LPCS for the public, cause harm to counselors duly trained outside of CACREP’s scope, and threaten the viability of excellent, longstanding academic programs both within and outside of Virginia.  I strongly urge the governor to reject this proposal.