I join counseling professionals from across the country to urge you to stop the proposed regulations that would permit licensed counselors who graduated from programs accredited by CACREP to qualify for licensure in Virginia with 3 years post-licensure experience, while requiring 10 years for licensed professionals who graduated from other accredited programs.  (CACREP is not the only accrediting body for counselor programs, and there is no documented evidence that their graduates are better prepared).

Not only is this legislation discriminative against qualified licensed counselors, it proposed at a time when there are public health and labor force crises in behavioral health care.  The legislature in Florida recently passed legislation to eliminate a similarly restrictive law involving the educational requirements of counselors (see FLA SB 566: Mental Health Professional Licensure).  Furthermore, there is a national legislative initiative underway (with the support of the ACA and AMHCA) to establish interstate compacts with the reasonable universal license portability standard of 3-years post-license practice.  The Dept of Defense offered support for such interstate compacts to protect the spouses of active duty personnel who are harmed by restrictive trade practices.  The FTC issued a 2018 report (which cited the DoD) that is also in favor of the interstate compact as the most efficient and effective way to resolve this issue. In sum, the proposed regulation amounts to restraint of trade and is discriminatory.

Ruth B. Palmer, Ph.D.                                                                    

Chair, Counseling Psychology Dept,

   And Director, Clinical Counseling Program

Eastern University