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 Changes resulting from periodic review
Stage NOIRA
Comment Period Ended on 9/18/2019
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9/18/19  10:40 am
Commenter: Samantha Daniel, Ph.D, Private Practice

Strongly oppose
 

While I strongly support licensure portability laws, I strongly oppose this one that poses an unfair second class citizen status to counselors that have not attended the “right” program. There is absolutely no research evidence to suggest that skills differ among those in CACREP vs non-CACREP programs. Indeed many in non-CACREP are taught by clinicians with the highest skill level in mental health, those who are licensed psychologists. ACA’s rigid rules in accrediting programs based on faculty background have unfairly marginalized programs ran by doctoral level psychologists that have gone to APA accredited programs. It would be a huge disservice to VA to allow ACA’s lobbying and increasingly restricted approach to accrediting programs unfairly impose additional loops for those taught in programs headed by psychologists. And until ACA can prove CACREP students are better than non-CACREP this is unfair and could lead to litigation. Do the right thing and apply licensure mobility equally. 

CommentID: 76247