I am writing to strongly OPPOSE the CACREP-only proposal. Below I present a series of direct quotes from the recent Economic Impact Analysis report by the Virginia Department of Planning and Budget that evaluated this proposal. The data they provide in their analysis make it clear that the proposed regulations would not prove beneficial to any involved parties.

• The one sentence summary listed in the “Result of Analysis” section was as follows: “Costs will likely outweigh benefits for this proposed change” (page 2)
• “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)
• “Obtaining and maintaining CACREP accreditation appears to involved significant costs” p. 8
• “By increasing required costs to start counseling programs, this proposed change may limit the number of counseling programs that are instituted in the future below the number that might be instituted if current regulations remain in place (p.12)
• “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 nationwise 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)
• “Under existing regulation, there are multiple requirements to ensure the competence of applications for licensure by examination. The board currently requires that individual licensed as profession counselors receive an education adequate to prepare them for future practice by 1) specifying the coursework that they must complete at an accredited college or university, 2) requiring a fairly lengthy residency and 3) requiring passage of a licensure exam that measures the counseling knowledge of applicants. These requirements are located in 18 VAC 115-20, sections 49, 51, 52, and 70, are not proposed or repeal as part of this action, and will remain in force. If a candidate can pass the examination for licensure, has completed the Board required education without having earned a degree from a CACREP/affiliate-accredited program, and successfully complete a 3,400-hour supervised residency, then the candidate has presumably demonstrated significant knowledge and experience. Given this, the additional value of requiring CACREP/affiliate-specific accreditation appears to be limited. Further, there is no known evidence in Virginia that individuals who pass the examination, successfully complete the residency and graduate from a program that meets all of the specification already detailed in this regulation but do not graduate from a CACREP/affiliate accredited program, are any less effective as professional counselors than graduates of CACREP/affiliate accredited programs” (Economic Impact Analysis, p. 13)
• “Given the significant costs associated with requiring CACREP accreditation, the uneven and uncertain benefits of doing so and the lack of empirical evidence that this proposal is necessary to protect the health and safety of Virginians, the costs of this proposed change appear to outweigh its benefits” (p. 14)
• Projected impact on employment: “seven years after its effective date, the proposed amendment will likely limit the number of individuals qualified to see licensure by examination as professional counselors in Virginia to some unknown extent because it will likely make it more expensive to get the required education. Additionally, there will likely be fewer individuals who would be qualified to seek licensure by endorsement as they would need to have CACREP approved education or meet active practice requirements. This proposed change will also adversely affect the employment opportunities of doctoral level teach professionals who have counseling activities within their scope of practice but who are not trained of licensed as professional counselors. This group would include psychologists, psychiatrists, and social workers” (p. 15)