The petition to create a pathway for licensed marriage and family therapists (LMFTs) to obtain licensure as licensed professional counselors (LPCs) should be rejected. While there are some similarities between the two professions, the differences in education, training, and scope of practice are significant enough to warrant maintaining separate licensure requirements.

Differences in Educational Requirements

Although both LMFTs and LPCs complete graduate-level education, the focus of their coursework differs. LMFTs' education emphasizes family systems, couple dynamics, and systemic interventions (American Association for Marriage and Family Therapy, 2021). In contrast, LPCs' education focuses on individual counseling, mental health disorders, and a broader range of counseling theories and techniques (American Counseling Association, 2021). These differences in educational focus highlight the distinct knowledge and skills required for each profession.

Variations in Scope of Practice

While there is some overlap in the scope of practice between LMFTs and LPCs, there are also notable differences. LMFTs specialize in treating relationship and family issues, with a focus on systemic interventions (American Association for Marriage and Family Therapy, 2021). LPCs, on the other hand, provide a wider range of counseling services, including individual, group, and family counseling, as well as addressing mental health disorders and substance abuse issues (National Board for Certified Counselors, 2021). The distinct scopes of practice underscore the need for profession-specific licensure requirements.

Maintaining the Integrity of Each Profession

Creating a pathway for LMFTs to obtain LPC licensure without requiring them to meet the same educational and examination standards as LPCs could undermine the integrity of the LPC profession. LPCs have worked diligently to establish rigorous licensure requirements that ensure practitioners possess the necessary knowledge and skills to provide competent and ethical counseling services (American Counseling Association, 2021). Allowing LMFTs to bypass these requirements could dilute the quality and consistency of care provided by LPCs.

Protecting the Public

Maintaining separate licensure requirements for LMFTs and LPCs is essential for protecting the public. Licensure laws exist to ensure that mental health professionals have the appropriate education, training, and competence to provide safe and effective services (National Board for Certified Counselors, 2021). By requiring LMFTs to meet the same standards as LPCs to obtain LPC licensure, the Board of Counseling can ensure that all licensed professionals have demonstrated the necessary qualifications to practice within their respective scopes.

While there are some similarities between LMFTs and LPCs, the differences in education, training, and scope of practice warrant maintaining separate licensure requirements. Creating a pathway for LMFTs to obtain LPC licensure without meeting the same rigorous standards could undermine the integrity of the LPC profession and potentially put the public at risk. The Board of Counseling should reject this petition to uphold the distinct qualifications of each profession and ensure the provision of safe, competent, and ethical mental health services.

References:

American Association for Marriage and Family Therapy. (2021). About marriage and family therapists. https://www.aamft.org/About_AAMFT/About_Marriage_and_Family_Therapists.aspx

American Counseling Association. (2021). Licensure requirements for professional counselors: A state-by-state report. https://www.counseling.org/knowledge-center/licensure-requirements

National Board for Certified Counselors. (2021). About NBCC. https://www.nbcc.org/about

LMFT is a specialty training with a focus on relational and family systems. The scope of practice, theoretical orientation, differs from LPC which encompasses and has a broader range of practice and training. In the interest of professional integrity and public safety, this petition is not endorsed.

Agreement with the comments already made.

Re: Opposition to Virginia Petition 419

To Whom It May Concern:

The Council for Accreditation of Counseling and Related Educational Programs (CACREP) opposes Virginia Petition 419 which would create a pathway for Licensed Marriage and Family Therapists (LMFTs) to obtain licensure as a Licensed Professional Counselor (LPC).

CACREP is the leading national accrediting body for Professional Counselor preparation programs. We accredit programs in the specialized practice areas of Addiction Counseling, Career Counseling, Mental Health Counseling, Clinical Rehabilitation Counseling, College Counseling and Student Affairs, Marriage, Couple and Family Counseling, Rehabilitation Counseling, and School Counseling. Additionally, CACREP accredits doctoral programs in Counselor Education and Supervision for the preparation of counselor educators and advanced practitioners.

CACREP opposes this petition for a few main reasons. First, Marriage and Family Therapy is a specialized area of practice with a unique focus that differs significantly from the broader scope of Professional Counseling. Unlike LPCs, LMFTs are not trained to provide the wide-ranging services expected of LPCs, nor do they meet the same educational requirements. The competencies required of LMFTs are a subset within the competencies for LPCs, underscoring the distinct scope of each profession. The petition indicates that the proposed change would create a similar pathway, but this is not the case. In the case of counselors having a pathway to the MFT license, this pathway is very narrow, allowing only counselors who have graduated specifically from a marriage and family counseling program to obtain the MFT license. The proposal in this petition would create a pathway for MFTs to significantly broaden their scope of practice, enabling them to practice with populations outside marriage and family counseling (such as addictions counseling) without the requisite training.

For these reasons, it is concerning from a public protection standpoint when individuals licensed as LMFTs practice outside their area of expertise or training (such as an LPC without the appropriate training). Permitting LMFTs to operate as LPCs would not only be unethical but also a potential risk to client safety, as it allows practice outside the licensed scope of competency.

For these reasons, CACREP definitively opposes Virginia Petition 419.

For any further questions, please contact CACREP’s CEO Sylvia Fernandez at sfernandez@cacrep.org.

LPC and MFT are distinct disciplines and should not be lumped together. Education requirments and scope of work are different. There is much value in maintaining disctinction in the disciplines.

In CACREP programs, family counseling trainees obtain the same base educational requirements, with the addition of systems trainings supporting their expertise in systems/family work. They recieve 60 credit hour degrees with 600 hour internships with supervision - often in the same types of agencies that mental health students are placed. COAMFTE programs require between 60-72 credit hours for a degree with supervised internships. 

Adding another exam is costly and provides additional barriers to licensure that are unnecessary. We need to promote workforce development as a field - and paying attention to structural barriers prohibiting access to licensure is an important philosophical ideal of the counseling profession. 

One qualifying exam should be enough. We are in a position to slightly lessen the financial and systemic burden of master's level professionals who have earned a 60 credit hour degree and practiced years under supervision to earn a license. That feels like an ideal the field would support. 

In agreement with Moates' comments and CACREP comments. These are two distinct disciplines and the specific licenses (LMFT and LPC) represent those distinctions.

I oppose this petition. LPCs are trained to focus on the individual; LMFTs focus on relational systems and the interactive effects between individuals and systems. The current rules of the Board permit LPCs to become LMFTs without relevant examination. Though this petition may seek to address an imbalance, approval would further blur the lines of clinical specialization and eradicate the purpose of creating separate examinations: to assess competency in a specific field of behavioral health. 

It may seem odd that the President of the Virginia Association for Marriage and Family Therapy would oppose this petition requesting a pathway for LMFT's to become licensed as LPC's similar to the pathway for LPC's to become licensed as LMFT's.  "Two wrongs do not make a right." Both disciplines are unique and distinct.  Because LPC's have a pathway to licensure as LMFT's does not mean LMFT's should have a similar pathway to licensure as LPC's.  Both are wrong, although this seems to imply that counseling is a "superior" discipline to marriage and family therapy when it is not. Without rewriting the definitions contained in 54.1-3500, it is obvious that there is considerable overlap between the professions of counseling and marriage and family therapy, as well as clear differences between the two professions recognized in the Code of Virginia and by the Virginia Board of Counseling.  In reviewing the Regulations for LPC's and LMFT's, I also found considerable differences in the education requirements, with emphases in different areas for each discipline.  The Board created separate licenses for each discipline because of these noted differences.  LPC's take more of an individual, linear approach to mental health issues, where problems are located within the individual, and A leads to B; while LMFT's take more of a systemic, circular approach to mental health issues where A leads to B leads to A, while considering and focusing on context, relationship, interaction and what happens between rather than within people.  The practice of LMFT's and LPC's are different because of these different orientations to mental health issues.  This does not mean that LPC's don't consider context and relationship, and LMFT's don't consider individual pathology; but these orientations establish different tendencies in practice. Again, when I examined the Degree Program Requirements for both LPC's and LMFT's in their respective Regulations, I found that the graduate programs in each discipline have to have a distinct sequence of academic study to prepare the Resident for licensure as an LPC or LMFT; and there must be an identifiable training faculty with credentials and specialization in each discipline.  The Board created different licenses because of the recognition and sensitivity to professional identity.  We are colleagues under the professional umbrella of mental health professionals yet are uniquely different as counselors and marriage and family therapists. Reviewing graduate catalogs for degrees in counseling and marriage and family therapists, I again find clear differences. Now, the general public may not recognize the differences between the two disciplines when seeking a mental health professional, but their experiences in sessions will be different. It is for these reasons that I oppose the petition.