I strongly support this change being made in the regulations.  The board allowed supervision across disciplines for many years without issue, and it never really made sense why the board made this change given the shortage of providers we have in Virginia.  

Acceptance for this change will increase access to supervisors that have clinical experience, even if in other disciplines, without detracting from the necessity for licensure to be held in the current mental health specialty. I support this update and believe it will benefit the current pool of approved supervisors and attract other experienced practitioners to our clinical specialty. 

October 22, 2024

Re: Proposed Changes to 18VAC115-20

To Whom It May Concern:

The Council for Accreditation of Counseling and Related Educational Programs (CACREP) opposes the proposed amendments to 18VAC115-20 that would allow professionals from other disciplines to count their experience toward counselor licensure.

CACREP is the leading national accrediting body for Professional Counselor preparation programs. We accredit programs in the specialized practice areas of Addiction Counseling, Career Counseling, Mental Health Counseling, Clinical Rehabilitation Counseling, College Counseling and Student Affairs, Marriage, Couple and Family Counseling, Rehabilitation Counseling, and School Counseling. Additionally, CACREP accredits doctoral programs in Counselor Education and Supervision for the preparation of counselor educators and advanced practitioners.

Firstly, CACREP believes the proposed regulation's language lacks clarity. The rule mentions “requirements for two years of post-licensure clinical experience,” but it is unclear whether this refers to C 1, which pertains to holding an unrestricted license as an LPC or LMFT. Additionally, the regulation states, “who is also a licensed psychologist, licensed clinical social worker, or psychiatrist.” If these credentials are held concurrently, there would be no need for an amendment. CACREP suspects that the rule is attempting to recognize these professionals from other disciplines as supervisors under their non-counseling licenses; however, the ambiguity as written raises several concerns.

Secondly, it is crucial that counselors are supervised by counselors, just as professionals in other fields should be supervised by members of their own profession. Virginia has a two-tier licensing system: the Resident-in-Counseling (restricted license) and the LPC (unrestricted independent practitioner). The purpose of 18VAC115-20-52 C 3 is to ensure that Residents-in-Counseling are supervised exclusively by LPCs or LMFTs. The final sentence in C 3 establishes a sunset provision, ending the approval of professionals from other disciplines as supervisors as of August 24, 2017. If the request pertains to C 1, it is effectively asking to either rescind this final sentence or reinstate the previous rule allowing supervision by professionals from other disciplines. However, permitting a licensee from another profession to supervise Residents-in-Counseling undermines the intent of supervision within the counseling profession, as the supervisor would not be part of the counseling profession. Furthermore, the Counseling Board lacks jurisdiction over supervisors licensed in other professions, meaning it cannot regulate or take disciplinary action against those supervisors if necessary. The C 3 requirement safeguards both Residents-in-Counseling and the public.

Thirdly, the purpose of 18VAC115-50-60 C 3 is to ensure that Residents-in-MFT are supervised solely by LPCs or LMFTs. The same arguments above should apply here also for Marriage and Family Therapy.

For these reasons, CACREP definitively opposes the proposed changes to 18VAC115-20.

For any further questions, please contact CACREP’s CEO Dr. Sylvia Fernandez at sfernandez@cacrep.org.

I want to voice my opposition to this change.  As a profession, counselors have been battling forming a clear identity where clients, communities and other professionals can distinguish them from Psychologist and Social Workers.  This identity is philosophically different than these two other helping professionals and practice of being a Professional Counselor is in practice different than the practice of being a Psychologist and a Clinical Social Worker.  Allowing these two helping professionals to gain a Professional Counseling License without going through the supervision process where they learn what it means to be a Professional Counselor will chip away at the identity that Counselors have been working to establish and maintain. 

I have a very specific education and time/focus of supervision that has allowed me to become a Licensed Counselor.  Allowing others who do not have the clear professional identity that is needed to be a Professional Counselor will have a negative impact on the profession overall.

In addition, as a Licensed Professional Counselor, I would never be allowed to use my counseling experience to gain a License as a Psychologist or Clinical Social Worker.  When these two helping professions allow me to gain their license in the same way they are requesting they gain my license, then I will support this idea.  Until then, I am strongly opposed to this plan.

I oppose the motion. Other professionals should be required to complete the same testing, education, and supervision as Counselors before obtaining the title.

As a future counselor, this bill harms my profession. Do not pass this unless I can become a LCSW or LCP with just years of work as a counselor. This attempt to encroach on the counseling profession shows a lack of respect for the supervision, education, and examination hours that are required to become a counselor. We have a role to fill, keep the professions separate. 

As a counseling student, I believe that the title of a counselor should be given only to those who had to undergo supervision and obtain the proper licensure. To know that there are people who can practice under my title that I aspire to have one day without going through the same education and supervision that I'm working so hard to obtain is personally discouraging and diminishes the specialization of the counseling profession.

Hello,

I am currently a student at Liberty University pursuing my master's in clinical mental health counseling and I would like to oppose this change. Licensed counselors are required to go through extensive training, education, supervision, and a licensure exam. If we allow psychologists and social workers to become licensed without going through all the required steps, this could cause these individuals to provide counseling that is not beneficial for those receiving the services. This can be confusing for clients if they are going to a psychologist or social worker and not receiving the care they need.

This also takes away from the individuals going through the training, education, supervision, and licensure exam. Licensed counselors put a lot of time, effort, money, etc., into becoming licensed counselors and are passionate about providing their clients with the best services. 

Please consider my request to oppose this change from allowing psychologists and social workers to become licensed counselors without going through the proper education, training, supervision, and licensure exam. 

Thanks,

Brittany

I strongly disagree! This would imply that counselors do not have a specific identity, training, and skill set. This would negatively affect counselor identity, and potentially clients as well. 

Additionally, if psychologists and social workers do the same work as counselors and can get licensed as counselors, counselors should also be able to become licensed psychologists and social workers.

Fully support!

We are still a young profession and are trying to identify WHO we are. This will only weaken the profession

Learning from other counselors is a key component of internalizing the way of healing our profession has established. This makes us unique compared to LMFT's, LCSW's, and psychologists. This identity is based in a wellness model (anti-medical model), an emphasis on development and prevention, client empowerment, and advocacy. We should protect the process that advances our professional identity, rather than diluting our training. We do collaborate with other professionals, but our training should be based in who we are. 

As a graduate student preparing to become a LPC in Virginia I have many requirements to get there. Where as, social workers, LMFT’s, psychologists, and others have very different requirements to become licensed. If this is allowed it would heavily hurt the identity and the integrity of Licensed Professional Counselors. Other programs should not be able to become licensed like me with much different standards and steps. This will only harm the counseling profession and further dilute the differences between each of these fields. 

Counseling is a separate profession. Individuals who have not had a supervised residency lack adequate expertise for counseling work. A counselor cannot get a license as a social worker or psychologist for the same reason, the professions are separate. Allowing untrained individuals to get licensed is not good for the profession or for clients.

Post-licensure clinical experience is vital to becoming an effective counselor. Replacing that with a substitute would create identity confusion and less competent counselors.

I am a future counselor and student at Liberty University. This should not be passed, as psychologists and social workers have not had the training and supervision that Licensed Professional Counselors are required to go through for licensure. They would make unequipped counselors, and they should not be doing mental health counseling or marriage and family therapy without undergoing the same education and supervision.

The approaches to care taken by LPCs, LCSWs, psychologists, etc. and so different from one another that I believe that supervision should be given by a licensee in the same field. 

I oppose this motion. Counseling is a specific profession with a unique philosophy and skill set that differs from psychology, social work, and psychiatry. It would be a disservice to future clients and the counseling profession for any counselor to forgo the specific counseling licensure requirement of supervised hours, replacing it with experience that is not equivalent. 

Experience cannot fully replace education; there is a reason why the degree requires extensive completion of both. Avoidance of the licensure exam solely based on having a certain amount of experience is bound to produce counselors who lack fundamental knowledge and expertise.  

Professional counselors' work is distinct from that of a psychologist, psychiatrist, or social worker, and it ought to be treated as such. Not treating it as such would be a disservice to clients who expect a well-practiced and experienced professional in the world of counseling, as well as an encroachment on LPCs' and LMFTs' individuality as their own unique discipline within the helping professions. 

I oppose the petition for previous experience in another helping profession to count towards getting a LPC/LMFT license. Licensed social workers and psychologists have a different focus and background when dealing with clients. Counselors have a more strengths-based and wellness focus when dealing with clients. Therefore, supervision is necessary in order to ensure that counselors are operating in a strengths-based focus. It would also skew the counselor identity, making it difficult to further differentiate between a counselor and other helping professions. 

Professional clinical mental health counseling (CMHC) is a fairly new profession that is still working to establish a strong identity and distinct boundaries. Psychologists and social workers have a much more solidified identity, and scope of practice. CMHC boasts one of the longest masters level programs, and it is because we specialize ONLY in professional counseling. CMHC is preventative, and holistic. It focuses on empowering the individual to make the needed changes to overcome life's difficulties, in congruence with their worldview, convictions, and culture. Although perhaps there is a slight overlap into social work and psychology, and psychological research is used by counselors to promote evidenced based practice in the counseling room; psychology is generally not preventative. Psychologists spend their masters and doctoral career conducting research in a mostly sterile environment with little client interaction. Social workers focus mainly on connecting clients with community resources and intervening for children in unacceptable living conditions. In contrast, CMHCs spend their ENTIRE masters career training for only one thing: to use evidence based practice techniques and methods to help clients overcome life's difficulties. Psychologists simply conducting research does not qualify them to adequately apply research studies and statistics to counseling practice. In fact, without the client exposure and training in counseling methods and techniques, the results could be extremely detrimental to the client. I do realize that before CMHCs existed, psychologists conducted the counseling. However, now we have professionals being thoroughly trained for counseling, and counseling ONLY. If a CMHC cannot be grandfathered into social work or psychology without any further training, education, or exams (which they would never allow us to do) then this should not even be considered the other way around. This would water down and be detrimental to CMHCs working hard to establish their own individual identity. For a CMHC to become a psychologist they must attend 4 more years of college on top of the 3 they already attend to achieve their masters/counseling license (as well as an additional 2 years of residency). It is simple, if psychologists would like the right to counsel, they need to specialize in CMHC, just like the counselors, so that clients are not harmed by individuals that are not adequately prepared. In my own experience, I was counseled for a short time by a psychologist who committed some of the very mistakes we learned within our first week of classes not to make and she was a PhD psychologist! It is a matter of "bedside manner," as we say in the medical field, and people skills which most psychologists, in my experience, do not possess. The scope of practice for social workers seems too vastly different to even be considered to counsel without formal training, so I will not use any more space to explain why I believe this to be so.