In my capacity as President of the Licensed Clinical Professional Counselors of Maryland (LCPCM), I want to express our state's strong opposition to a CACREP only standard in the Commonwealth. While we respect our neighboring state's right to self determination in its standards, we do want to express the highest degree of concern that this move would restrict the movement of counseling professionals between Virginia and Maryland, where we have many high quality programs that are not CACREP accredited and may never be, as they are Counseling Psychology programs.

Whatever five year waiting program exists to create a loop hole to allow non-CACREP, Maryland counselors to work in the Commonwealth is still a symbolic disparagement of their credentials without merit and a practical impediment to their working in your state.

The CACREP only movement is incredibly saddening to see, as it divides our profession, disenfranchises our Counseling Psychology programs and their graduates, and seems based in a black and white thinking that feels contrary to the creative spirit of the counseling process. We can think of many more humane and respectful ways to promote national accreditation in our profession rather than the one Virginia proposes.

I respectfully urge the Virginia Board of Counseling to seek a fairer resolution to this controversy that transcends the narrow CACREP only view and instead seeks a creative and inclusive final regulation that unites counselors in our common values rather than divides us in our regrettable pettiness.

Thank you kindly for sharing my views.

Larry Epp, Ed.D., LCPC

President, Licensed Clinical Professional Counselors of Maryland

Maryland's Chapter of AMHCA

I am writing in response to the proposed requirement for CACREP or CORE accreditation for educational programs in Virginia. I am writing in my capacity as a Professor and the Academic Program Coordinator of the Counseling and Development Program at George Mason University, as the former department head of the counseling programs at Ohio State University and Johns Hopkins University, as a Fellow of the American Counseling Association and as a former member and Vice Chair of the Maryland State Licensure Board of Professional Counselors and Therapists. From this framework I want to very strongly encourage that the Board rejects this proposal.  From my experience I am firmly convinced that this regulation that results in an accreditation body dictating state licensure laws regarding training is harmful for university training programs in Virginia and establishes a very dangerous national trend whereby states lose their autonomy to determine criteria for licensure.

Having held leadership positions in three states it is my strong belief that licensure boards and accreditation bodies should remain independent of each other.  Despite not having CACREP, George Mason University has received the 2013 Southern Association for Counselor Education and Supervision (SACES) Outstanding Master’s Degree Program award and continues to pride ourselves on training excellent counselors, many of whom are licensed and hold state leadership positions in Virginia. There are many other universities in similar positions to George Mason University. Thus we at George Mason strongly believe that requiring accreditation as part of state licensure policy is highly inappropriate and has serious negative ramifications for both Virginia and the field of counseling.  In fact states such as New Jersey rejected a similar proposal based on the same concerns being voiced in this letter.

In summary I am strongly opposed to this legislation and speak on behalf of many of my colleagues at George Mason University as well as colleagues from across the country who have written to the Governor (approximately 100 letters from colleagues at major universities across the United States have been sent in the past several months). We and others across the nation are highly concerned about the danger of state licensure boards joining accreditation agencies to formulate policy and regulations.

Sincerely yours,

Dr. Fred Bemak
Professor and Academic Program Coordinator
Director, Diversity Research and Action Consortium
George Mason University

Hello,  Please accept my objection to the CACREP only requirement proposed by the VA board.  While we currently practice in Maryland, we are looking into expanding in Virginia. If this ammendment passes, I will not exapnd to VA.  We currently provide therapy to over 600 adults, teens, children and families per week in Maryland.  90% of my staff are LCPC's that did not gradueate from a CACREP program.  The other 10% are Social workers.  I myself have a degree in Counseling Psychology, a program totally ignored by CACREP.  My practitioners provide exceptional care as is evidenced by our client feedback, our ongoing customer referrals, and our clients progress.  We also accept all commercial insurances.  Do not limit the number of exceptional providers who can serve VA residents.  If you do this, my company will not consider adding Virginia as a viable place to serve people in need.

Yours in Service, (or not)

Mark Donovan, LCPC, LCADC

I am a Licensed Clinical Professional Counselor in the state of Maryland and I graduated from a non-CACREP accredited program. I have a MS degree in Counseling Psychology and have practiced as a counselor for 7 years helping people to overcome depression, addictions, obesity, and myriad other conditions. I would like to formally submit my emphatic opposition to the CACREP only proposition for the state of Virginia. Although I do not practice in your state I am vehemetly opposed to any legislation that limits public access to mental health services and sunders the counseling profession. This is bad for counselors, bad for public health, and bad for Virginia.

While I haven't practiced in Virginia for a number of years, i was among the first one thousand counselors to be licensed in the Commonwealth in the 1980's (I have allowed my VA licence, #989, to become inactive since my practice has been only in Maryland for a number of years now).  I'm embarassed by the seeming short-sightedness of the Virginia board in considering - in fact, seeming to push for - the requirement that licensees be graduates of programs which are approved by "CACREP or an approved affiliate of CACREP." 

My graduate program predates CACREP; my Virginia and Maryland licenses predate CACREP.  I believe the Virginia board and the counseling profession are quite capable of evaluating the quality of an individual's preparation to serve as a counselor without becoming part of the political flood tide of the CACREP-Only forces!

I strongly support this regulatory action.  It ensures that graduates of counseling programs in Virginia will meet the training standards outlined by the government for jobs in federal agencies, allowing students to serve veterans.  It strengthens both the identity and reputation of the profession by aligning counselor training programs in Virginia with the only national, CHEA-recognized accrediting body for counselors.  Adopting this regulation will put counseling on par with social work, psychology, medicine, nursing, and numerous other professions which require training programs be accredited by a single accrediting body.  It protects future students of counseling in Virginia, who may be unaware of the importance of accreditation, from facing undue hardships (such as an inability to obtain a job in the federal government) by attending an unaccredited program in Virginia.  It also provides ample protections for students already enrolled in such programs through its use of a 7-year grandfathering period.  Furthermore, it still allows for non-CACREP counselors from other states to receive a license in Virginia through the licensure by endorsement process.  Finally, by adopting a single training standard, it reduces confusion among new applicants for licensure about what courses and credits are needed in order to become a counselor in Virginia.  It would be a significant step forward for the profession in Virginia.

• Making licensure CACREP-only disregards the expertise of experienced and well-qualified clinicians who either graduated prior to the existence of CACREP, or from programs that are highly respected, but not CACREP.

Distinguished colleagues,

This decision diminishes state autonomy and separation of regulatory powers.  Further, it brings an redundant administrative burden on higher education and helping professionals.

Professionally,

Mark Liston

I am writing in response to the proposed requirement for CACREP or CORE accreditation for educational programs in Virginia. I am writing from the perspective of an Assistant Professor in the Counseling and Development Program at George Mason University, a nationally certified counselor (soon to be licensed), and a graduate from a CACREP program at the Masters (Minnesota State University) and PhD (University of Iowa) level.  From this perspective I want to strongly encourage that the Board rejects this proposal.  From my experience, the proposed CACREP-only license regulations (e.g., graduation from a clinically-focused counselor preparation program accredited by CACREP or an approved affiliate of CACREP that includes a minimum of 60 semester credits of curricular experiences and a practicum of at least 100 hours and an internship of at least 600 hours) lack substantial evidence of effectiveness in terms of counselor training or performance. 

Having trained counselor in both CACREP and Non-CACREP programs, I am firmly convinced that a lot more goes into the preparation of culturally responsive counselors than the number or credit hours or practicum and internship experience hours required.  Simply put, pre-service counselors in CACREP programs come out as no more effective than students from Non-CACREP programs.  The differences, if any, between CACREP and Non-CACREP programs quickly fall apart upon examination.   I believe the strength of Virginia is our autonomy to determine criteria for licensure for those who wish to serve our fellow-citizens.  Furthermore, I believe each state should welcome the opportunity to dictate state licensure laws regarding training that meet the best interest of the citizens in which they represent.  Allowing an accreditation body to dictate state licensure laws is harmful for university training programs in Virginia and establishes a very dangerous national trend whereby states lose their autonomy to determine criteria for licensure. 

In summary I am strongly opposed to this legislation and I am highly concerned about the danger of state licensure boards joining accreditation agencies to formulate policy and regulations.

I am an elder Licensed Clinical Professional Counselor in the state of Maryland and I graduated from a non-CACREP accredited program, the University of Baltimore. I have a MS degree in Counseling Psychology and have been licensed in Maryland as a counselor since 1997.  I have helped people, including the military and veterans, to overcome depression, anxiety, PTSD, family conflict, behavioral problems and myriad other conditions. I have served seven Family Courts in the State of Maryland. I would like to formally submit my emphatic opposition to the CACREP only proposition for the state of Virginia. Although I do not practice in your state, I live close enough that I have considered Virginia as a place to volunteer my services after I retire. Should the long term impact of the non-CACREP accredited program continue to damage non-CACREP accredited counselors, my reputation and ability to practice independently will be destroyed.  My years of education and training and expertise in counseling will taken away from me. I am vehemently opposed to any legislation that limits public access to mental health services and destroy the livelihood of me and my peers. As a seasoned LCPC, I am firmly convinced that this regulation that results in an accreditation body dictating state licensure laws regarding training is harmful for university training programs in Virginia and other states.  establishes a very dangerous national trend whereby states lose their autonomy to determine criteria for licensure. My graduate program predates CACREP; my Maryland license predate CACREP.  I believe the Virginia board and the counseling profession are quite capable of evaluating the quality of an individual's preparation to serve as a counselor without becoming part of the political flood tide of the CACREP-Only forces. Whatever five year waiting program exists to create a loop hole to allow non-CACREP Maryland counselors to work in the Commonwealth is still a symbolic disparagement of our credentials without merit and a disastrous impediment to LCPCs working in your state. The Virginia Board's decision to allow non-CACREP-only counselors may well end in the severe cutting off of services to not just Virginia, but the nation; effecting 400,000 counselors and a huge population needing mental health services in their local communities. 

The CACREP only movement is incredibly dividing our profession, disenfranchises our Counseling Psychology programs and their graduates, and seems based in a system that is contrary to the creative spirit of the counseling process. There has to be many more humane and respectful ways to promote national accreditation in our profession rather than the one Virginia proposes.

Sincerely,

Patricia J. Simpson, M.S., LCPC

I am writing in response to the proposed requirement for CACREP or CORE accreditation for educational programs in Virginia. I am a graduate student in the George Mason University Counseling & Development program seeking a degree in School Counseling. I want to very strongly encourage that the Board rejects this proposal.  I am firmly convinced that this regulation that results in an accreditation body dictating state licensure laws regarding training is harmful for university training programs in Virginia and establishes a very dangerous national trend whereby states lose their autonomy to determine criteria for licensure. 

It is my strong belief that licensure boards and accreditation bodies should remain independent of each other.  Despite not having CACREP, George Mason University has received the 2013 Southern Association for Counselor Education and Supervision (SACES) Outstanding Master’s Degree Program award and continues to pride itself on training excellent counselors, many of whom are licensed and hold state leadership positions in Virginia.

There are many other universities in similar positions to George Mason University. I and many of my cohort believe that requiring accreditation as part of state licensure policy is highly inappropriate and has serious negative ramifications for both Virginia and the field of counseling.  In fact states such as New Jersey rejected a similar proposal based on the same concerns being voiced in this letter.

In summary I am strongly opposed to this legislation. I and others across the nation are highly concerned about the danger of state licensure boards joining accreditation agencies to formulate policy and regulations.

Sincerely yours,

Sean McCoart

Graduate Student, Counseling & Development Program

George Mason University

I am writing in response to the proposed requirement for CACREP or CORE accreditation for educational programs in Virginia. I am a graduate student in the George Mason University Counseling & Development program seeking a degree in School Counseling. I want to very strongly encourage that the Board rejects this proposal.  I am firmly convinced that this regulation that results in an accreditation body dictating state licensure laws regarding training is harmful for university training programs in Virginia and establishes a very dangerous national trend whereby states lose their autonomy to determine criteria for licensure. 

It is my strong belief that licensure boards and accreditation bodies should remain independent of each other.  Despite not having CACREP, George Mason University has received the 2013 Southern Association for Counselor Education and Supervision (SACES) Outstanding Master’s Degree Program award and continues to pride itself on training excellent counselors, many of whom are licensed and hold state leadership positions in Virginia.

There are many other universities in similar positions to George Mason University. I and many of my cohort believe that requiring accreditation as part of state licensure policy is highly inappropriate and has serious negative ramifications for both Virginia and the field of counseling.  In fact states such as New Jersey rejected a similar proposal based on the same concerns being voiced in this letter.

In summary I am strongly opposed to this legislation. I and others across the nation are highly concerned about the danger of state licensure boards joining accreditation agencies to formulate policy and regulations.

Sincerely yours,

Sean McCoart

Graduate Student, Counseling & Development Program

George Mason University

Hello,  Please accept my objection to the CACREP only requirement proposed by the VA board.  I currently practice in Maryland but would like to have the freedom to practice in Virginia as well. I graduated from a very prestigious university with a degree in Counseling but it was not CACREP accredited. I don't believe that the accreditation is the mark of highly skilled counselors, but rather a highly regulated school. If this passes, many highly talented and skilled counselors will not be able to serve people in need in Virginia. The field of counseling needs more clinicians, not less. The long and arduous path of licensure in Virginia (and all states) already prepares applicants to be fully-competent counselors while eliminating those who are not proficient enough for the field. Please strike down this proposal.

Hello VA etc.

In comparing humans to the animal world, there are 3 types of people I see in society : Those that when they see another animal licking their wounds they either let them have their healing time and keep moving forward, they stop and help them out, or the get hungry.  This last one is what I see happening in the cacrep only movement.  Its motive is not to mind our own or to help others, it's to feed off the wounded, the vulnerable adults who repeatedly request better treatment of our profession.

We shouldn't have to be having this conversation or beg for sanity here.  While a part of me wants an accreditation standard for the usually outlined reasons (of uniformity, ease, credibility or whatever), there is not one REASON (or a collection of them) at all that trumps the underlying and overt negative consequences to people without cacrep titles in their future (as already seen in public treatment).  The greater part of me cares about the greater part of reality and the humans involved.  

The grandfathering or other currently shown fallback solutions are a joke, not even close to preparing for or preventing undue harm.  Without the thousands of non-cacrep individuals who founded the counseling field, cacrep would not exist.   Then you/they don't mind if you enable/promote the slaughtering of professional stature that the non-cacrep people go through? 

If a state is geared toward helping people find work (or let's say survive and not be homeless in school debt), then the limiting of several credible excellent educational backgrounds to one quasi-effective standard is not the way to go.  It seems absolutely pathetic that we have to have this conversation.  Our profession is jumping the gun to think it's found the "perfect" standard of which to ruin the majority of the lives of our professional framework.  Cacrep and similar education doesn't train us to be therapists, it's pulled together 60 credits to compete with social workers, and our 60 is dead weight after 42 credits, it's nothing special as I saw going to a cacrep-like institution.  I'd rather not have a profession than to have one that prides itself on covert exploitative capatilization, divisive rhetoric, and one that has the potential to destroy lives, as it has mine to a large degree, regarding the financial struggle in dealing with paranoid board systems that need me to offer a cavity search since I did not go to Cacrep.  

I got a 90 percentile score on our NCE national test (in a pool of ALL POTENTIAL SCHOOLS), a 4.0 gpa in school, I have thousands of extra hours of learning / training due to my own explorations of the field and paying for legitimate hands on trianing that school doesn't provide from any of our current education, I have a BS in psychology of which my 40+ credits there were basically copied by CACREP, and for what?  To sit there and fill out paperwork for you that think there are provable uniform ways to cut people down in to a category of professional education standards, FOR COUNSELING?  Where is the DATA ?   Your proposal to cut it to one acts as if there is HARD PROOF that Cacrep would save the multitudes.  None exist. The states want us to practice evidence base counseling, yet this politicing stuff has no research behind it.  These contradictions seem to show disregard of your own regulations.

Oh yes, and does anyone care about the social ramifications of our jobless, struggling country?  Or why do degrees mean NOTHING like a plague in our society?  It's because of these movements argued herein.  Need I go through more work than a brain surgeon and get paid 10% of what they earn?  And now have it be even more difficult?

You need to think about how you can create a class of accreditations and school types, rather than 1 type of school.  Our profession has developed far too many professionals over far too many years to cut it down now to one type.  It's too late.  We're too far ahead, the ship is already docked in a station full of a lot more options than the CACREP and we are not able to handle turning around. It seems way too foolish and negligent to ignore this issue.  It's terribly difficult to watch people argue for CACREP Only.  Cacrep of a half dozen comforting options is about what's fair and decent, reasonable, safe etc.  Why would so many states not already do it?  Do you think VA or OH is so brilliant, you really thought of something that the other states didn't since the 1970s, the start of counseling as a profession?  Does anyone worry of what pride, what blasphemy, what shameless tarnishing neglect of people is going on here?

I also echo what was written by the help of leaders of the CCC movement at leave no counselorbehind.

Nick B, LAC/Addiction 3 states, 3 Licenses, Trainee in 4 methods of therapy

I'm pasting a few points from CCC

? The majority of non-CACREP programs in this country are also regionally
accredited by CHEA and must maintain high quality standards.  This sentence
implies that non-CACREP programs are usually not CHEA accredited and are
illegitimate.

?One of the goals of CACREP is to establish a uniform set of educational
requirements across the United States to facilitate portability of licensure
from state to state.?

? True, but other methods of state-to-state portability would include an
interstate agreement between the member Boards of AASCB, a simple choice to
recognize out-of-state licensed counselors, or even CACREP-equivalent
coursework and preparation.

?Three federal agencies have made graduation from a CACREP accredited
program a requirement for independent practice in counseling.?

? This is not a reason to make the same mistake elsewhere.  Such
requirements place a burden on counseling business owners and on clients who
are looking for easy access to counselors in their communities.

?With a large military presence in Virginia, there is a need to equate
graduation from a CACREP-accredited program with licensure to avoid public
confusion and give licensees access to federal agencies.?

? This is exactly what should NOT happen for the good of both counselors and
the public. Thousands of competent seasoned non-CACREP counselors throughout
Virginia face increasing public confusion as to their competence.  A public
which expects CACREP (despite no evidence of its superior quality) will
start demanding CACREP and start discriminating against counselors without
this accreditation in their past.  This will result in lack of employment
for non-CACREP counselors even in situations where they are licensed and
eligible to help with our burgeoning mental health community needs.  The
likelihood of public confusion of CACREP with license eligibility and with
competence is exactly why grandfathering provisions for non-CACREP
counselors fall short of acceptable.

?The Board of Counseling has found that it has neither the resources nor the
expertise to examine counseling programs across the country to assess the
quality of the education in that program.?

? Plenty of Boards across the country do just this.  They typically require
regional CHEA accreditation (for quality) and then require coursework in a
variety or required categories.  Sometimes they choose to look for
?CACREP-equivalency?.  When state Boards cede control of their standards to
an outside entity they lose control over serving the needs of their state
constituents.  Furthermore, several professions have two or more recognized
accrediting authorities.  With variety comes a greater opportunity for a
diversity of training to ensure a flexible and responsive (counseling)
workforce for the unique needs of individual clients.  The Virginia Board
might also avail itself of discussions amongst the various state Boards at
the AASCB association ? in which case it could at least have a strong voice
in whatever national standards are enacted for standardization and license
portability.

?Consistency and quality in educational preparation for professional
counselors will provide greater assurance to clients seeking their services
that they have been adequately prepared and appropriately licensed to
protect public health and safety.?

? CACREP advocates have created a mostly false narrative of a public
endangered by poor quality counselor preparation.  No doubt they can find
isolated examples of such.  There is no epidemic of poor quality counselor
preparation ? controls and standards are already in place to protect the
public without locking down the profession to one privately controlled
gatekeeper.

Requested Public Participation in the NOIRA: The agency is seeking comments
on this regulatory action, including but not limited to 1) ideas to be
considered in the development of this proposal, 2) the costs and benefits of
the alternatives stated in this background document or other alternatives
and 3) potential impacts of the regulation. The agency is also seeking
information on impacts on small businesses as defined in ? 2.2-4007.1 of the
Code of Virginia. Information may include 1) projected reporting,
recordkeeping and other administrative costs, 2) the probable effect of the
regulation on affected small businesses, and 3) the description of less
intrusive or costly alternatives for achieving the purpose of the
regulation.

Costs of the NOIRA proposal include the nearly $4500 in program application
fees, and $2600+ annual maintenance fees charged to each CACREP accredited
program (see their website] edited)
which are paid for in some fashion by state school budgets, counseling
students, and ultimately the public. Costs are also paid in terms of
flexibility of curriculum in a field with MANY theories of psychology, loss
of employment opportunities in CACREP programs for educators with slightly
different qualified backgrounds than Ph.D.s in counselor education, and
locking counseling psychology graduate students out of future licensure for
no discernable reason related to competency to the public good. The future
effects of CACREP on small businesses are murky and troubling. Many
counselors in private practice are sole proprietors or at small clinics
which would qualify as small businesses.  In the short-term under this
proposal, these non-CACREP counselors will continue to be licensed and new
graduates will be license-eligible until 2022.  However, the CACREP-only
push creates a false perception of CACREP quality that is likely to impact
these small businesses in the future.  The public may look for CACREP
graduates in the false belief that they are more qualified.  Government
programs (and private insurers?) may follow the bad TRICARE example and
start requiring CACREP for licensure.  Employers may start only hiring
CACREP graduates.  There is a potentially devastating longer term effect on
small clinics and sole proprietors at risk of being cut out of the market.
To the extent that non-CACREP counselors are cut out of the market, the
public may experience counselor shortages or have to settle for newer
counselors with less experience. Other Points: A careful look at the data
will reveal that counselors who have graduated from CACREP programs are not
more effective in their work with clients or in their service to their
communities. A regulation limiting practice will not serve the people of
Virginia well given that a majority of master?s level counselor training
programs in the USA are not CACREP-accredited. A regulation limiting
practice will not serve clients in Virginia given that the majority of
currently practicing counselors graduated from schools free of CACREP
accreditation. A restriction such as this would negatively impact current
students and alumni from non-CACREP affiliated VA programs; negatively
impact the public by reducing access to qualified counselors; negatively
impact relocation of qualified and competent counselors from non-CACREP
programs; reduce overall services available to VA residents; and increase
cost of graduate education. Even the American Counseling Association (ACA),
the largest national counseling association, opposes the CACREP-only
restrictions highlighted in the rationale for this regulatory change. The
people of Virginia need a strong Board that protects their rights to access
quality mental health care.

RE: Protesting CACREP ONLY

CACREP ONLY License qualifier is a BAD idea. CACREP should stick with school counseling accreditation only.

Allowing a FOR PROFIT GROUP such as CACREP to determine qualifications is a fallacy. Schools such as Harvard and many other quality schools choose not to participate in the CACREP accreditation process due to the high costs and the accreditation process.

CACREP should not be the gold standard since graduates from CACREP schools have shown no evidence based superior performance in studies.

The board of counseling should find a more inclusive way to qualify counselors to practice instead of turning to CACREP for guidance.

CACREP is new to the business of accrediting for mental health therapists.

Other accreditations should be accepted since they are older and more established. Other accreditation groups have served to qualify more mental health workers than CACREP. Research shows no benefit to CACREP qualified therapists.

CACREP offers no provisions for therapists who did not graduate from a CACREP school and yet have been highly successful in their given field of practice than a new CACREP grad. The public will be misled and not served if CACREP only is made the mandatory requirement for licensure.

State unemployment rates will rise if the non-CACREP graduates are not allowed to enter the field as a licensed worker.

There are more NON-CACREP counselors currently practicing that will suffer even though they have years of experience and have accomplished  many hours of CEU's.

If there is one standardized licensure exam that candidates must take in order to be licensed to practice it should not matter which program they completed, CACREP or NON_CACREP approved. Counseling psychology masters and masters in counseling are parallel programs in most universities and most states.

The fight for superiority in this profession among LMFT, LPC, LCSW is all ridiculous at this point when ALL these masters level care workers are interested in helping the people they are trained to serve.

ALL should be equally qualified to practice without one having the upper hand.

Federal agencies who have made CACREP a requirement have done harm to the public, the practicing therapists, and should not be a reason to follow  . A burden has been placed on the public and those who utilize the services.

I can personally speak to military members who now have limited mental health help as a result of CACREP only.

CACREP only is confusing the public which ultimately will not serve the public.

There must be a non-CACREP grandfathering provision allowed for the overwhelming number of non-CACREP licensed therapists who have been in successful practice since before CACREP began pushing their agenda.

State boards should not give control over licensure to CACREP. It is a disservice to their community.

There is no shortage now of highly qualified counselors and there is no benefit to CACREP.

The counseling field needs to have the opportunity for variety in the ways individuals practice in other states. State portability needs to be standardized somehow so that other professionals can easily move from state to state.

To Date, ALL States utilize a standard licensing test in order for masters level candidates to apply for practice. this method has been working quite well for years. WHY mess with something that is not broken in order to build a for profit business like CACREP?

Tricare is a good example of the failure of CACREP only accreditation.

Ann Brown M.A., LPC

I am writing in opposition to the CACREP only rule. CACREP only will disenfranchise numerous therapists and prevent many people in need of therapy from receiving services from seasoned and qualified therapists. There is a danger that if passed Virginia will be a precedent for other states creating even a wider gap between people in need of therapy and those who can provide it.

Please do not discriminate against those of us who graduated in the mid 90s and cost us our jobs! 

As a licensed professional counselor in Maryland, I was required at the time of obtaining my license to meet standards that exceeded CACREP.  Now CACREP wants you to believe that their standards are better, and that their educational programs exceed those such as Harvard and Johns Hopkins University (my alma mater), or counseling psychology programs. However, CACREP has not shown that programs accredited by them are better. The claim that their accreditation program is a higher standard has not been adequately examined, nor have the responses which can refute that claim been fully heard.  

Since the CACREP only standard was adopted by the U.S. Veterans Administration, veterans who seek mental health benefits cannot be seen by up to 70% of the licensed counselors in the country.  Is that what we want for non-veterans as well?

Hello,

I am a student at George Mason University that is currently enrolled in a masters program to become a LPC. I think it is unfortunate that Virginia wants to tell clients seven years from now that 70% of counselors nationwide are incompetent. For this reason I am against making Cacrep the only accreditation acceptable for licensure. The Virginia Board of Counseling should be supporting ALL counselors and not just some.

Samuel Seium
Graduate Student
Counseling and Development Program
George Mason University

I am writing in response to the proposed requirement for CACREP or CORE accreditation for educational programs in Virginia. I am writing in my capacity as a Professor of the Counseling and Development Program at George Mason University, as a Fellow of the American Counseling Association, as the 2013 State Council of Higher Education for Virginia (SCHEV) Outstanding Faculty Award recipient and the recipient of the 2013 Commonwealth of Virginia Commendation Award for my work in the counseling profession. From this framework I want to very strongly encourage that the Board rejects this proposal.  From my experience I am firmly convinced that this regulation that results in an accreditation body dictating state licensure laws regarding training is harmful for university training programs in Virginia and establishes a very dangerous national trend whereby states lose their autonomy to determine criteria for licensure. 

It is my strong belief that licensure boards and accreditation bodies should remain independent of each other.  Despite not having CACREP, George Mason University has received the 2013 Southern Association for Counselor Education and Supervision (SACES) Outstanding Master’s Degree Program award and continues to pride ourselves on training excellent counselors, many of whom are licensed and hold state leadership positions in Virginia. There are many other universities in similar positions to George Mason University. Thus we at George Mason strongly believe that requiring accreditation as part of state licensure policy is highly inappropriate and has serious negative ramifications for both Virginia and the field of counseling.  In fact states such as New Jersey rejected a similar proposal based on the same concerns being voiced in this letter.

In summary I am strongly opposed to this legislation and speak on behalf of many of my colleagues at George Mason University as well as colleagues from across the country who have written to the Governor (approximately 100 letters from colleagues at major universities across the United States have been sent in the past several months). We and others across the nation are highly concerned about the danger of state licensure boards joining accreditation agencies to formulate policy and regulations.

Rita Chi-Ying Chung, PhD
Professor

Counseling & Development Program

George Mason University 

I am writing in response to the proposed requirement for CACREP or CORE accreditation for educational programs in Virginia. I am writing in my capacity as a Professor of the Counseling and Development Program at George Mason University, as a Fellow of the American Counseling Association, as the 2013 State Council of Higher Education for Virginia (SCHEV) Outstanding Faculty recipient and the recipient of the 2013 Commonwealth of Virginia Commendation Award for my work in the counseling profession. From this framework I want to very strongly encourage that the Board rejects this proposal.  From my experience I am firmly convinced that this regulation that results in an accreditation body dictating state licensure laws regarding training is harmful for university training programs in Virginia and establishes a very dangerous national trend whereby states lose their autonomy to determine criteria for licensure. 

It is my strong belief that licensure boards and accreditation bodies should remain independent of each other.  Despite not having CACREP, George Mason University has received the 2013 Southern Association for Counselor Education and Supervision (SACES) Outstanding Master’s Degree Program award and continues to pride ourselves on training excellent counselors, many of whom are licensed and hold state leadership positions in Virginia. There are many other universities in similar positions to George Mason University. Thus we at George Mason strongly believe that requiring accreditation as part of state licensure policy is highly inappropriate and has serious negative ramifications for both Virginia and the field of counseling.  In fact states such as New Jersey rejected a similar proposal based on the same concerns being voiced in this letter.

In summary I am strongly opposed to this legislation and speak on behalf of many of my colleagues at George Mason University as well as colleagues from across the country who have written to the Governor (approximately 100 letters from colleagues at major universities across the United States have been sent in the past several months). We and others across the nation are highly concerned about the danger of state licensure boards joining accreditation agencies to formulate policy and regulations.

Rita Chi-Ying Chung, Ph.D.
Professor
Counseling & Development Program, George Mason University

CACREP is a good accrediting program, and it is the first one we instituted, but it is not the only one, and it is not any better than the other two currently available. It is simply different than the other two. Requiring CACREP accredited programs for counselors will do an injustice to the people of the state; both clients who are in need of competent, qualified professional counselors and counselors from other programs who are ready, willing and ready to competently serve client's needs.  All our competent professional counselors are needed to effectively serve the needs of the state, and all those prepared to provide these services have a right to practice.

CACREP is a good accrediting program. It is the first one instituted, but it is not the only one, and it is not any better than the other two currently available. It is simply older, and different than the other two.  Requiring CACREP accredited programs for counselors will do an injustice to the people of the state; both clients who are in need of competent, qualified professional counselors and counselors from other programs who are ready, willing and ready to competently serve client's needs. Many dedicated and highly qualified, competent counselors come from programs that are not CACREP accredited.  All competent professional counselors wanting to practice in the state are needed to serve the people's needs, and all those prepared to provide services have a right to practice.

I am the director of a counseling program in Pennsylvania, Arcadia University; our graduates practice in various states, including Virginia. Our program is accredited by MPCAC and recently won the Pennsylvania Counseling Association Outstanding Counselor Education Award. Our students are highly valued by the communities they serve, where they provide clients with essential evidence-based, trauma informed, and multiculturally sophisticated services.

I am joining counseling professionals from across the country to urge you to stop the proposed counselor licensing regulations that would require graduation from a CACREP-accredited program for licensure in Virginia. The majority of counselor training programs are not CACREP-accredited. This is a time of great need for mental health services, not a time to restrict licensure to a minority of graduates. This is also not a time to cede State licensing board authority to protect the public to an independent organization with no public oversight or accountability. A turf war between counselor educators and psychologists (the latter are restricted from teaching in CACREP programs) over counselor education and licensure does NOT serve the public good in any way.

If you look carefully at the data, you will notice that research does not indicate that counselors who have graduated from CACREP programs are more effective in their work with clients or in their service to their communities. There is also no evidence to support that counselors from CACREP-accredited programs are more ethical or more helpful to clients or the communities within which the counselors practice. Even the American Counseling Association (ACA), the largest national counseling association, opposes the CACREP-only restrictions highlighted in the rationale for this regulatory change.

The people of Virginia need a strong Board that continues to protect their rights to access readily available and quality mental health care. There are no other States where a licensing board has made such a decision, for many of the reasons stated above. A regulation limiting practice would not serve the people of Virginia well, as it would reduce the services available to Virginia residents; increase the cost of graduate education; and increase the difficulty for qualified counselors in relocating to Virginia—as many do, after graduating from rigorous MPCAC-accredited or unaffiliated programs. I urge you to stop this proposal and ensure that the people of Virginia will continue to rely on the strength of your licensing Board, and not on the unchecked agenda of an independent organization.

Respectfully,

Eleonora Bartoli, Ph.D.

Director, graduate program in Counseling

Arcadia University

There are no research studies or hard data that demonstrates the superiority of graduates of CACREP accredited program graduates in comparison to graduates from non-CACREP accredited programs.  There are many excellent counselor preparation programs that are not CACREP accredited.  Clearly standards and competencies are required for professional counseling practice, but to argue that CACREP is the sole arbiter of those standards is incredibly myopic.  Further, the restriction of counseling practice to CACREP program graduates only may be construed as restraint of trade.

I am very much opposed to the proposal to offer Virginia licensure only to counselor graduates from CACREP programs.  Please ask for verifiable evidence that only CACREP graduates are competent counseling professionals.

Dear Aid to the Secretary of Health and Human Resources, Ms. Judith Ahern,

I am the director of two doctoral programs in Marriage and Family Therapy at Eastern University in Pennsylvania. Our graduates practice in various states, including Virginia. Our graduates are highly valued by the communities they serve, where they provide clients with essential services related to their mental health needs.

I am joining counseling professionals from across the country to urge you to stop the proposed counselor licensing regulations that would require graduation from a CACREP-accredited program for licensure in Virginia. The majority of counselor training programs are not CACREP-accredited. Passing this legislation would limit the number of counselors available to those in need of quality mental health care. Please do not restrict licensure to a minority of graduates from programs across the country that seek to train highly competent practitioners.

If you look carefully at outcome studies regarding counseling and therapy, you’ll rapidly see that research does not show that counselors who have graduated from CACREP programs are more effective in their work with clients or in their service to their communities. No evidence to support the claims of CACREP has been found. Also please note that the American Counseling Association (ACA), the largest national counseling association, opposes the CACREP-only restrictions regulatory change would establish in Virginia.

It is a vital time for strong state Boards to continue to protect the people of their states and to remove these CACREP- exclusive clauses from their regulations. Please oppose this proposal so that the people of Virginia can continue to get the accessible mental health care they need.

Respectfully submitted,

Gwen White, Psy.D.

Director, Doctoral Programs in Marriage and Family Therapy

Eastern University

Professional counseling is a relatively new profession.As I understand it, there were virtually no CACREP  institutions in the beginning of this profession, particularly in the Northeast & Mid Atlantic Regions of the United States.  Those of us who wanted to become counselors saw the ever-growing master's degree of counseling and clinical psychology as a  wonderful opportunity. The programs offered  clinical course work designed to teach students how to become a counselor/psychotherapist. It was an alternative to becoming a licensed clinical social worker.  I researched both programs and I chose to be a counselor. Like many other counselors, I had no idea of the world of slander and threats of disenfranchisement that I would face. Many of us went to top-notch schools, where an accreditation was stated. I knew nothing about an organization called CACREP, untiL my school decided to offer the NCE within the school 5 months after graduating. We had to register with the NCC, naming who are licensed supervisors would be and complete our clinical hours.  It was 3600 clinical hours with 190 hours of supervision then. It's now 3000 clinical hours with 150 supervised hours. I learned that my curriculum was modeled after the CACREP MODEL. So, I took every area of study necessary to be CACREP compliant, completing well over 60 credits . I passed the NCE, completed my clinical hours with a licensed supervisor, while working in Community Mental Health Center. I was taught that the ACA was my organization, that I  ought to be a member, and abide by its Code of Ethics. I first became so disheartened to learn that Medicare and the VA didn't recognize my license. Afterward I have bore witness to several injustices., including CACREP grads only being permitted to work for the VA. I Believed I would be recognized if I took the NCMHCE. I APPLIED through the VA portal of NBCC. I passed NCMHCE but then learned, that because psychology was a word within my degree program, I would be locked out of the VA, Even though the NBCC AND THE VA had no problem taking my money for the examination. 

 So now I have a bit of an alphabet after my name, which seems to mean little. Is this America? We took the same course work, the same tests, (some have not taken the NCMHCE)- not required in all states. We all have had clinical practice under supervision.

When something doesn't make sense, it doesn't make sense. When an organization it's alive to promote Counselors. Shouldn't it be all of those who followed their rules and standards.?. If Virginia puts into place this CACREP ONLY statute to gain licensure in Virginia for counseling, it will be blatant discrimination and an absolute INJUSTICE.  Please please do the right thing!

Respectfully & Sincerely,

Carol Anne Robinson, MS, LPC, NCC, CCMHC

To take away a professional counselor's career is an injustice. These counselors have paid a high cost in tuition and longs hours of decication to their work in making a difference to our cities and our country.  What is the purpose of this attack?  Studies show that counselors performance level is just as good as any other counseling profession. Or practicing with or without the title of CACREP does not make us better counsellors. I understand they want to make a standard but why can't the present counsellors be grandfather in? Why do they have to throw us under the bus? We as counselors need to ban together for our profession and the universities that educated should stand behind their education as well. 

There is no evidence that CACREP programs produce a "better" or more effectual counselor than a non-CACREP program.  To make CACREP the "standard" is ridiculous.  I have clinically supervised people in TN who have moved to VA and have added their value to the people of the Commonwealth.  NONE were CACREP grads; ALL are excellent counselors.  It is interesting to see a state elevate an accreditation agency over its own power and reason.  If I were a Virginian, I'd be livid for that reason alone, whether I was a counselor or not.

This type of legislation is an injustice to the general public. By limiting the counseling profession to CACREP only graduates many individuals and families will be denied mental health and addiction services. Pschology program graduates make up a large proportion of the counseling profession. Their training, supervision and professional development is equal to or superior to cacrep programs. At a time when the demand for serices is at an all time high and on the rise it is unfortunate that an organization would work toward limiting access to treatment without merit. 

Anthony S. Parente, MA, LCPC, NCC, MAC, NCGC I

This type of legislation is an injustice to the general public. By limiting the counseling profession to CACREP only graduates many individuals and families will be denied mental health and addiction services. Psychology program graduates make up a large proportion of the counseling profession. Their training, supervision and professional development is equal to or superior to CACREP programs. At a time when the demand for services is at an all time high and on the rise it is unfortunate that an organization would work toward limiting access to treatment without merit.

Anthony S. Parente, MA, LCPC, NCC, MAC, NCGC I

Please do not allow this to happen in Virginia you will be over looking some great people and there practice.

As a Licensed Professional Counselor in Virginia (#0701005508) in good standing, who graduated from two Virginia professional counseling programs (Lynchburg College, James Madison University), I strongly support the proposal to require CACREP accreditation as a requirement for meeting the educational standards of licensure. The generous grandparenting provision gives all programs in VA time to move towards CACREP accreditation, in a State that has a proponderence of CACREP accredited programs.  I believe this decision strengthens the profession of counseling in Virginia.  CACREP Standards were created by professional counselors, for professional counselors.   

Bravo for taking this step forward!

Thom Field, PhD, NCC, LPC (VA)

I am strongly opposed to the CACREP only movement.  There are many competent and compassionate counselors who have graduated from Non-CACREP Colleges and Universities with skills that are helpful to many people, myself included.  My opinion is that the CACREP movement is designed to funnel prospective students into universitites who comply with the standards of CACREP for marketing purposes. CACREP certification does not elevate the level and ability of counselors, it segregates the field and unfairly punishes those from non-CACREP schools, who have an array of talent and abilities to offer and help others. 

Sincerely,

Vivian Morgan, MS, LCPC

Psychotherapist to Children, Adolescents, and Families

I am fully opposed to legislation entitling only CACREP graduates the right to practice counseling in Virginia. The idea of having only CACREP graduates as counselors and denying all others the equal right they have earned and are currently in practice, is true insanity and exclusively detrimental to the mental health of the people in the commonwealth of Virginia.

Ilene Richardson, LCPC

Licensed in Maryland, Residing in Onancock, Virginia. 

Please consider that many reputable universities choose not to be CACREP accredited, and there are legitimate reasons for making that decision.  

I am an LPC in MD, DC, VA and DE. I am strongly opposed to the CACREP requirement for several reasons. The primary reason is that CACREP's main claim on their website is that they want to ensure the quality of programs and prevent counselors that came through diploma mills. I personally find this claim highly insulting. I attended John's Hopkins and obtained my degree in Clinical Community Counseling. While the school program is accredited by CACREP, the CCC program is not. However, no one would consider Johns Hopkins a diploma mill. Harvard, Princeton, and Yale programs are likewise not accredited. This limitation of who can practice based on an accredtiting body would eliminate highly qualified, dedicated counselors from helping the residents of Virginia and the surrounding area.

Many highly qualified counselors would be disqualified from working, which would not only impact the counselor, but would lead to a potential shortage of counselors for people that need the service. Many counselors started attending master's programs or obtained their licenses before CACREP began accrediting counseling programs, and would therefore be punished for something beyond their control. Again, these are highly qualified individuals. Additionally, CACREP does not currently accredit psychology programs, meaning that anyone who graduated from a psychology program and obtained their advanced degree through that modality would be disqualifed unfairly. All licensed counselors need to attend the same subject matter classes, pass the same qualifications tests, and complete the same internship requirements. Additionally, there are other accrediting bodies.

This limitation would also lead to the unemployment of many counselors, as we would then be unable to obtain work within our fields.

Given these arguments, I cannot see how this limitation would serve the counselors or residents of Virginia, and I urge you to reconsider.

I am writing in response to the proposed requirement for CACREP or CORE accreditation for educational programs in Virginia. I am a graduate of a rigorous Counseling Psychology program which is not CACREP accreddited. As CACREP does not accredit counsling psychology and other mental health programs, the CACREP-only movement that is occuring will prohibit individuals who are skilled and trained in Psychology, counseling, and mental health from practicing as counselors. CACREP is an independent body, who should not be dictating state regulations. For this reason, I strongly encourage the Board to reject this proposal. Licensure boards and accreditation bodies should remain independent of each other.  

There are many universities who offer excellent counselor training programs and are not CACREP accreditted. Therefore I believe that requiring CACREP accreditation as part of state licensure policy would prove to be detrimental not only to Virginia, but to the field of counseling as a whole.

In summary I am strongly opposed to this legislation and speak on my own behalf as well as on behalf of my colleagues from across the country who are deeply concerned about the possibility state licensure boards looking to accreditation agencies to formulate policy and regulations.

Sincerely yours,

Shante Williams

opposed...concerned that good professional counselors will be excluded...concerned about conflicts of interests. 

Please do not impose this regulation concerning counseling practice.  I have been practicing for approximately ten years.  I am currently licensed in Maryland and Virginia.  The lack of CACREP certification of my graduate program has not in any way reduced, impaired or limited by ability to effectively address this issues of mental health and dually diagnosed clients in the communities I serve.

Thank you for your consideration of this request.

As someone who graduated from a master's program (Counseling Psychology) from Columbia University (which is not CACREP accredited), I do find it completely discriminatory that I would no longer be able to work in an entire state based on this change for "Public clarity". You would, in fact, be limiting the resources of the people you are seeing to protect and help. I see that there is an option for those wishing to move to the state, but I honestly wouldn't want to move to an area in which the atmosphere would be hostile towards my background and credentials. It seems like this policy is only going to hurt those in our field and do nothing to help the public of Virginia. 

It is well established that different states have different needs based on their populations.  Localized or regional accreditors are better able to reflect the needs of individual states when compared with an overarching centralized accreditor such as CACREP.  The leaders of accrediting bodies need to come from the local communities.  It is insanity to argue that one type of graduate program is better than another based on a central accreditor's viewpoint. 

Interaction between universities at a local or regional accreditation level runs smoother.  Bureaucratic organizations such as CACREP try to take over from local decision makers who know better their local populations.  CACREP cannot possibly set standards and be aware of the diversity issues involved at the local level (see CACREP’s 2009 and 2016 standards draft on the LGBT population and how CACREP's reports remain vague regarding this population).   CACREP seeks to dictate policy rather than listen.  We need competing local and regional accreditors to improve standards.  The last thing states should adopt is a centralized bureaucratic trashcan to dictate standards based on a one size fits all mentality.

As a former resident of Virginia, I am opposed to the one-size-fits-all, CACREP-only, pathway to licensure.  There are many worthwhile educational pathways and a supervised practice experience that should be evaluated regardless of whether the education was obtained in a CACREP program.