To Whom It May Concern: 

I am writing to strongly oppose the proposal for licensure by endorsement.. I am writing in my capacity as a faculty member and previous Academic Program Coordinator in the Counseling & Development Program at George Mason University as well as a 2018 recipient of the State Council of High Education of Virginia (SCHEV) Outstanding Faculty Award and a Fellow of the American Counseling Association. The proposed regulation includes a provision that counseling graduates from CACREP accredited programs would be qualified for Virginia licensure 3 years after graduation while non-CACREP counseling graduates would require 10 years of post-licensure practice in order to quality for licensure in Virginia. This proposed regulation is in direct contradiction to the report by the Mental Health America (MHA) 2018 The State of Mental Health Report that noted the serious overall shortage in America in the mental health workforce. Notably, Virginia was rated 42nd nationally in this report, comparatively poor with respect to other states, with a ratio of 730:1 clients to mental health providers. This figure combined with the fact that there is no research to support the determination of waiting 10 years for licensure in Virginia if one does not graduate from a CACREP program raises critical questions regarding the proposed regulation.

As noted by the Dean, Mark Ginsberg, at the College of Education & Human Development at George Mason University, in a recent letter to Kevin Doyle, former Chair and current member of the Virginia Board of Counseling, regarding the current proposal, "We [George Mason University] have been consistent in our view, which remains our perspective, that the intended restrictions of this proposed requirement (which has been proposed and not affirmed multiple times in Virginia) remain of concern and are NOT representative of a Virginia public policy we support. In our view, the proposal unnecessarily limits the availability of mental health professionals in the Commonwealth." Dean Ginsberg continued in his letter, "...Thus, the revised proposal is not a revision at all, rather it is a circular restatement of the original proposal, which was opposed virtually by all persons who submitted comments in response to an invitation for public comments." In fact, when we reviewed the public comments for the proposal out of 446 comments 412, or 92%, were against the proposed CACREP licensure regulations, leading to the withdraw of the proposed by the Virginia Board of Counseling.

Rex Stockton, the Chancellor's Professor in Indiana State University, and a Charter Member of CACREP and a longstanding member of the Indiana Counseling Licensure Board, noted in his public comments to the Virginia Board of Counseling during the public commentary period in 2017 to Governor McAuliffe and the Virginia Board of Counseling, "I urge you to veto the Virginia's Counseling Board Resolution requiring graduating from a Council for Accreditation of Counseling & Related Educational Programs (CACREP) accredited institution in order to obtain a license. I am a proud Charter Member of CACREP and have supported them throughout my career. However, I do not approve of their advocating the position that only CACREP accredited institution graduates are qualified for licensure. That is simply not true. There are many quality graduate programs that, for one reason or another, don't chose to affiliate with CACREP... All counseling boards have curriculum requirements that ensure that candidates come from a quality program. As a long-time member of the Indiana Board (although not speaking for the Board), I can assure you that there's no sentiment on our Board for requiring CACREP accreditation for our applicants. I every much hope you will veto the Virginia's Board's Counseling Resolution." 

I am highly concerned that the proposed regulations are a replication of the two previously proposed CACREP licensure regulations by the Virginia Board of Counseling and are in direct conflict with the documentation of increasing and under-served mental health needs in Virginia. Furthermore, there is no research or scientific base to support the position for a difference between CACREP and non-CACREP graduates. Based on these facts I strongly urge that this regulation is rejected.

Fred Bemak, Ed.D. Professor, George Mason University