Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Counseling
 
chapter
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]
Action Changes resulting from periodic review
Stage Proposed
Comment Period Ended on 4/1/2022
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3/29/22  12:23 am
Commenter: Melissa Ertl, PhD

Strong opposition
 

I strongly oppose this endorsement proposal. Not only is it unfair to require licensed counselors from non-CACREP programs to accrue 7 more years of clinical experience than their peers who graduated from CACREP programs in order to be licensed--but it is also an arbitrary and burdensome requirement that is not empirically-based and that would, without doubt, further the mental health disparities in the state of Virginia. There is no evidence that licensed counselors who graduated from programs accredited by CACREP are better prepared than their peers who graduated from other programs. At a time when licensed mental health counselors are in high need to support the mental health of the public, this proposal seeks to unnecessarily limit the number of licensed counselors who would qualify for licensure (and professional counseling work) in Virginia. 

CommentID: 120935