The proposed regulations in Virginia to require 10 years of practice post degree for individuals graduating from programs not affiliated with CACREP (such as programs accredited by MPCAC) while only requiring 3 years of practice post-degree for individuals graduating from CACREP programs are overly restrictive and not based on any evidence.  MPCAC requirements are comparable to CACREP requirements and add an emphasis on making sure services provided are empirically based.  The mission of MPCAC is to “provide  science-based education and training in the practice of counseling and psychological services at the master’s degree level, using both counseling and psychological principles and theories as they apply to specific populations and settings” (http://mpcacaccreditation.org/).  There are 59 programs across 23 states accredited by MPCAC, with 9 additional programs currently under review.  Virginia is ranked 39^th in access to mental health care (https://mhanational.org/issues/2021/ranking-states#four).  The proposed regulations will deter students from MPCAC-accredited programs from moving to and practicing in Virginia.  This is not good for the state, is not based in research, and is a restriction of trade that will likely result in legal challenges.

As an educator of counselors in South Carolina who has had graduates move to VA this would deter competent providers from practicing in your state and reduces access to care. The goal should be competence and inclusivity, not decisions based solely on one accrediting body.