I OPPOSE the proposed CACREP-only regulation. It is not necessary to protect the health and safety of Virginians and will have numerous negative consequences to citizens of the Commonwealth, to Virginia Universities, Mental Health Agencies, and graduates from non-CACREP accredited programs. The end result of the proposed regulations will be a restriction of licensure for graduates from non-CACREP accredited programs. This will decrease the number of qualified mental health professionals in Virginia and further restrict services at a time when there is already a documented shortage of mental health providers. This may be particularly problematic in rural and traditionally underserved areas. This is not the time for guild issues where CACREP becomes the gatekeeper for Virginia. Virginia needs qualified mental health professionals from a variety of disciplines including Counselor Education and Psychology. Citizens of Virginia deserve greater access to qualified mental health professionals and research does not demonstrate that graduates from CACREP accredited programs are any more qualified than graduates from non-CACREP accredited programs. I understand that the Board of Counseling has found that “it has neither the resources nor the expertise to examine counseling programs across the country to determine their rigor or assess the quality of the education in those programs” (Town Hall Agency Background Document, page 5). But 46 other states have found a way to do so. Let me reiterate three points emphasized by the Virginia Department of Planning and Budget Economic Impact Analysis.  http://www.townhall.virginia.gov/l/GetFile.cfm?File=C:\TownHall\docroot\25\4259\7390\EIA_DHP_7390_vE.pdf

• "In Virginia, requiring CACREP education would not appear to improve the quality of counselors as there is no reported differential in complaints or efficacy of practice between counselors that have CACREP education and those that have non-CACREP education.” (page 4)
• “This proposed regulatory change could also adversely affect individuals seeking licensure as profession counselors by endorsement from the board…Since fewer than 20% of colleges and universities with counseling programs nation-wise appear to have CACREP approval, this proposed change has the potential to shrink the pool of professional counselors licensed in other states who would be eligible for licensure in Virginia" (p. 12-13)
• The primary conclusion of the Economic Impact Analysis is that “Costs will likely outweigh benefits for this proposed change” (page 2).

It is striking to me that one of the primary reasons for the proposed regulatory change appears to be motivated not by any assurance that it would somehow protect the public or ensure better mental health treatment, but rather because “the Board of Counseling has found that it has neither the resources nor the expertise to examine counseling programs across the country to determine their rigor or assess the quality of the education in those programs” (Town Hall Agency Background Document, page 5)”. Of note, the “Proposed Regulation Agency Background Document” states that “the primary advantage to the public is greater consistency in the educational programs of persons licensed as professional counselors in Virginia” and that “the primary advantage to the Commonwealth would be greater efficiency in reviewing applications for licensure, as it would eliminate the need to look at the current qualifications of an educational program and rely on accreditation by CACREP or CORE. It would facilitate approval of applicants to begin supervision and to be ultimately licensed with less delay in the process (page 4).

Thus, given the vast number of potentially negative consequences that will result from the proposed legislation, doesn’t it make more sense to provide the Board with additional resources and expertise to evaluate programs in Virginia and around the country, than to exclude a significant number of qualified mental health professionals from being license eligible in Virginia? Certainly, adding additional faculty from non-CACREP affiliated programs in Counselor Education AND Counseling Psychology programs to the licensing Board would be a helpful first step.

Respectfully submitted,

Tom Pierce, Radford University