November 18, 2024

Re: Opposition to Virginia Petition 423

To Whom It May Concern:

The Council for Accreditation of Counseling and Related Educational Programs (CACREP) opposes Virginia Petition 423 which would establish a pathway for Licensed Substance Abuse Treatment Providers (LSATPs) to become Licensed Professional Counselors (LPCs).

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 the proposed pathway allowing LSATPs to qualify as LPCs, as these roles represent distinctly different scopes of practice. The LSATP license is specialized and limited to substance abuse treatment, while LPCs are qualified to diagnose and treat a wide range of mental health issues beyond substance abuse, including career counseling, marriage and family counseling, and specific mental health diagnoses. Unlike LPCs, LSATPs do not receive the same level of educational training or skills development, as defined by the CACREP curriculum requirements that support the broader LPC scope. Graduates of CACREP-accredited Addictions Counseling programs meet degree requirements for LSATP licensure, and regulation 18VAC115-60-90(C) permits LPCs to bypass an examination when transitioning to LSATP licensure, as their competency has already been assessed through the National Counselor Examination (NCE) or the National Clinical Mental Health Counseling Examination (NCMHCE) required for LPCs.

For these reasons, CACREP opposes Virginia Petition 423.

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

The proposed policy raises significant concerns as it would equate LSATPs (Licensed Substance Abuse Treatment Providers) with LPCs (Licensed Professional Counselors), despite their fundamentally different professional scopes. While LSATPs focus exclusively on substance abuse treatment (and have solely received training in such), LPCs are trained to address a comprehensive range of mental health needs, including career counseling, substance abuse, family and marriage therapy, and diverse psychological conditions.

The educational differences are critical: LPCs undergo rigorous training aligned with CACREP curriculum standards, which ensure a broader and more comprehensive professional preparation that LSPATs do not receive. Consequently, conflating these two distinct licensure tracks would potentially compromise the quality and depth of mental health services.

I am an associate professor of counselor education at an R1 institution in Virginia. I have carefully reviewed the requirements for Licensed Substance Abuse Treatment Practitioners (LSATPs) and they are nearly identical to the standards set forth by CACREP for Licensed Professional Counselors (LPCs). Of all the proposed pathways in mental health that I have seen presented in recent years (some of which are equally insulting and terrifying), this seems straightforward and stringent, particularly given the standards set forth by the Virginia Board of Counseling.

Why would this not be an option for LSATPs? I suspect it is because the CACREP has a monopoly on graduate programs and the counseling profession in general. While I strongly support accreditation standards, we are in the midst of a public mental health crisis. I believe the CACREP has outdated standards and is in desperate need diverse and alternative pathways to help those, like LSATPs, earn LPC credentials. 

In our CACREP-accredited graduate program, our students take one class on substance use. They graduate able to either work provisionally in a school setting (two years before fully licensed) or provisionally as a resident counselor under the supervision of an LPC-S (3400 hours) and they see students and clients battling addictions. One could easily argue this is not nearly enough, but we don't because CACREP states it is fine and the graduate program checked a box. In fact, all of the areas the the CACREP mentioned in their comment are typically one class in graduate school. While there are specialization tracks, they are not necessary to become an LPC. 

The VA Board of Counseling could easily require a simple respecialization pathway, too. We need more licensed counselors in Virginia, not less.