Dr. Johnston Brendle, LPC, LMFT

Chairperson

Virginia Department of Health Professions

Virginia Board of Counseling

Perimeter Center 
9960 Mayland Drive, Suite 300
Henrico, Virginia 23233-1463

Dear Dr. Brendle:

The National Board for Certified Counselors (NBCC) is writing express our support for the proposed rule change for 18VAC115-20-45. Prerequisites for licensure by endorsement. At NBCC, we support and respect the important work that state regulatory boards do to protect the public and identify appropriate qualifications for competence and integrity of practice by counselors. Furthermore, we understand the need for increased access to qualified counselors and expanded mobility for counselors in the contemporary job market. We believe the proposed rule change helps to advance these aims.

NBCC provides national certification for the counseling profession, representing over 66,000 National Certified Counselors (NCCs) in the United States. NBCC also develops and administers the licensure examinations for professional counselors in all 50 states, Puerto Rico, and the District of Columbia. Professional counselors, counselor educators, regulators and counseling stakeholders are engaged throughout all facets of the development of the national models for counseling, the NCC and the Certified Clinical Mental Health Counselor (CCMHC). These stakeholders are engaged in the development of the assessments, ethics processes, identification of educational eligibility requirements and service and supervision elements. Engaging the profession in defining core eligibility requirements and processes for certification is critically important for ensuring a cohesive model informed by the profession’s voice. National certification provides a model and a pathway for the profession to respond to the evolving needs of the public while ensuring that the sustained core requirements include the elements necessary to protect the public and frame the profession.

It is our intention that certification and the national model be a help to our partners on the regulatory boards. Being able to refer to and utilize a national model developed and maintained by counselors for the profession is intended to help facilitate the work of the state boards. We were pleased to see that model and those intentions in action in the proposed rule change. Including the Certified Clinical Mental Health Counselor (CCMHC) credential and the National Certified Counselor (NCC) credential as pathways for the educational and experience requirements allows the Virginia Board to be assured that counselors seeking licensure by endorsement have obtained the education and experience necessary for competent practice, ensuring the ongoing protection of the public. We believe that utilizing the national credentials as a pathway to verify educational and

experience requirements will simplify administration, increasing efficiency and reducing costs for the Board.  NBCC also supports the inclusion of a CACREP accredited degree in the proposed endorsement rule. CACREP is the premier accrediting body for mental health counseling graduate programs and the inclusion of its standards here will help to further ensure that candidates for endorsement have the educational preparation necessary to provide quality counseling services to the citizens of Virginia. 

Furthermore, we enthusiastically support the inclusion of the broad range of clearly articulated options for documenting educational preparation and counseling experience set forth in the proposed rule change. The proposal your Board is offering will appropriately protect the citizens of Virginia, while also achieving critically important aims, including:

• • Significantly increasing public access to qualified care.
  • Establishing minimum standards for safe practice.
  • Reducing administrative burdens for both the state regulatory board and licensees.

The proposed rule change will support portability and continue the strong history of Virginia leading on meaningful, impactful regulatory processes for counselors. We believe that the proposed rule change facilitates portability for the vast majority of licensed counselors while establishing quality assurances for your citizens.

In closing, NBCC supports the proposed rule change and urges others to support the proposed changes to the licensure by endorsement process in Virginia. The proposed change will continue the long history of Virginia’s leadership for the counseling profession, promote counselor portability and facilitate the flow of qualified counselors into the state. The plan balances the priorities of public protection with the demand for increased access to behavioral health services.

Thank you for your consideration of our letter of support. If you have any questions or comments about this letter or about counselor certification, the NCC or the CCMHC, please contact Kylie Dotson-Blake, NBCC’s Interim President and CEO or Jacob Jackson, Manager, Government Affairs for NBCC, at dotson-blake@nbcc.org or jjackson@nbcc.org. 

Sincerely,

Kylie Dotson-Blake                                                    Jacob Jackson

Interim President & CEO                                           Manager, Government Affairs

National Board for Certified Counselors                   National Board for Certified Counselors