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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4/1/22  9:04 pm
Commenter: Amber Pope, PhD, LPC, LMHC

Strongly oppose
 

At a time when there is an increased need for licensed MH professionals in VIrginia to serve our communities (I live in the Hampton Roads area and many of the LPCs here have wait lists, and it can take clients months to get in for outpatient treatment), the Board of Counseling should be working towards increased reciprocity for licensure with other states. Requiring a fully licensed counselor form another state without a CACREP degree to have 7 years more experience to get licensed by endorsement in VIrginia vs. a fully licensed counselor with a CACREP degree contradicts efforts in the state (such as those by the VIrginia Health Care Foundation described below) to increase the number of behavioral health providers within the next few years to meet the increased need for mental health services. The proposed legislation makes it exceedingly more difficult for fully licensed counselors from other states without CACREP degrees to get licensed, even though counselors getting licensed by endorsement have to demonstrate a 60 credit hour master’s degree with coursework that mirrors CACREP standards. 

According to a white paper from the Virginia Healthcare Foundation (accessible here: https://www.vhcf.org/data/capacity-of-virginias-licensed-behavioral-health- workforce/), Virginia faced a shortage of licensed behavioral health providers including LPCs prior to the COVID-19 pandemic. Virginia ranks 39th in the number of behavioral health providers per 100,000 residents, and 41st in behavioral health accessibility. Approximately 41% of Virginians currently live in an area designated as a Mental Health Professional Shortage Area (MHPSA) by the Health Resources and Services Administration (HRSA) as compared to 30% of citizens residing in MHPSAs in other states. Further, the number of licensed behavioral health providers in Virginia is estimated to decrease in the next 5 years due to a) attrition from the profession which has been compounded by the COVID-19 pandemic, and b) because ~32% of LPCs in Virginia are within 10 years of retirement age. Hence, an additional 200 individuals need to be licensed per year to maintain the current number of LPCs in Virginia so increasing access and pathways to licensure is necessary to maintain the behavioral health workforce capacity and increase accessibility to mental health services for  Virginian residents. 

 

CommentID: 121070