The Alliance for Professional Counselors (APC), a national organization of counselors and counselor educators that supports interdisciplinary cooperation and licensure portability, is opposed to the lack of transparency and information in the current proposal to change the regulations for licensure by endorsement that does not provide any detail. What exactly would change? To what?

We are concerned given recent attempts to change the requirements for licensure by endorsement to unfairly privilege graduates of programs accredited by CACREP. To illustrate, APC and many other professional organizations and individuals strongly objected to the 2018 proposal to adopt NCLEP and the 2019 proposal to permit licensed counselors who graduated from programs accredited by CACREP to qualify for Virginia licensure in three years while licensed counselors who graduated from other programs would need ten years post-licensure experience. Fortunately, both proposals were withdrawn. Given this history, although we are not opposed to change, per se, we are opposed to the lack of transparency and any change that would unfairly privilege graduates of programs accredited by CACREP.

As we wrote in our 2019 comment:

Furthermore, this proposal would harm the public by unnecessarily limiting the number of licensed counselors who would qualify for licensure (and therefore professional counseling work) in Virginia. This proposal would also harm the majority of licensed counselors who graduated from programs that are not affiliated with CACREP by making it seem, despite lack of evidence, that they are less qualified. We call your attention to the two successive Virginia Economic Impact Analyses (2016, 2017) for further information. Furthermore, as Virginia has historically been a leader in the profession, this proposal could set a negative precedent. 

The American Counseling Association’s (ACA) 2016 Portability Plan is a significantly better option for portability than the current (or previous) proposals. The ACA Portability Plan would permit counselors licensed at the independent level in one state (who do not have any disciplinary actions against them) to qualify for independent licensure in any other state in which they are seeking residence. Duly licensed counselors would be treated equally across the nation under this plan. Compared with this – and earlier proposals - the ACA plan respects all counselors, the licenses they hold, and doesn't require a waiting period.

We fully respect that licensure decisions are within the purview of the Commonwealth of Virginia. APC asks for your consideration because any proposed regulation changes that are exclusive of all duly licensed or license-eligible counselors are detrimental to the citizens and economy of Virginia. Furthermore, we urge you to consider the national implications of any licensure by endorsement regulation change and all proposals to restrict Virginia counselor licensure to graduates of programs accredited by CACREP.

Thank you for your consideration.

Respectfully,

Peggy Brady-Amoon, PhD, LPC

President, Alliance for Professional Counselors

www.apccounseloralliance.org

Associate Professor

Department of Professional Psychology & Family Therapy

Seton Hall University

South Orange, NJ 07079

Margaret.brady-amoon@shu.edu

The ability for mental health counselors to transfer their licenses across state lines has important public health implications. The historic efforts of the Commonwealth to create different standards of practice than Maryland is problematic. We see this especially now during a public health emergency where differing standards creates confusion and difficulty in deploying mental health professionals to areas of need, whether in person or through telehealth. We cannot comment on the changes to Virginia licensure, because it is not clear what they are. We ask the Virginia Board to make clear what changes are being proposed and extend the comment period. This action would be consistent with fair and transparent government practice.