Disagree as exam content is different

The petition to allow licensed marriage and family therapists (LMFTs) to use the National MFT exam to satisfy the examination requirement for licensure as a licensed professional counselor (LPC) should be rejected. While both LMFTs and LPCs provide mental health services, the scope of practice and educational requirements for these professions differ significantly.

The educational requirements for LMFTs and LPCs are distinct. LPCs are required to complete a master's degree in counseling or a related field, which includes coursework in human growth and development, counseling theories and techniques, and assessment and testing (American Counseling Association, 2021). In contrast, LMFTs must complete a master's degree in marriage and family therapy or a related field, with coursework focusing on family systems, couples therapy, and child development (American Association for Marriage and Family Therapy, 2021). The differences in educational requirements reflect the unique focus of each profession.

The scope of practice for LMFTs and LPCs differs. LPCs provide individual, group, and family counseling, focusing on mental health, substance abuse, and personal growth (National Board for Certified Counselors, 2021). LMFTs, on the other hand, specialize in treating relationship and family issues, with a focus on systemic interventions (American Association for Marriage and Family Therapy, 2021). The National MFT exam is designed to assess knowledge and skills specific to the practice of marriage and family therapy, not the broader scope of professional counseling.

Allowing LMFTs to bypass the NCMHCE or NCE exams for LPC licensure could undermine the integrity of the LPC profession. These exams are designed to ensure that LPCs possess the necessary knowledge and skills to provide competent and ethical counseling services (National Board for Certified Counselors, 2021). Permitting LMFTs to become licensed as LPCs without demonstrating mastery of professional counseling content could potentially put the public at risk.

While LMFTs and LPCs both provide valuable mental health services, the educational requirements, scope of practice, and licensure exams for these professions are distinct. Permitting LMFTs to use the National MFT exam for LPC licensure would fail to ensure that these professionals possess the necessary knowledge and skills to practice as professional counselors, potentially compromising public safety.

References:
American Association for Marriage and Family Therapy. (2021). About marriage and family therapists. https://www.aamft.org/About_AAMFT/About_Marriage_and_Family_Therapists.aspx

American Counseling Association. (2021). Licensure requirements for professional counselors: A state-by-state report. https://www.counseling.org/knowledge-center/licensure-requirements

National Board for Certified Counselors. (2021). About NBCC. https://www.nbcc.org/about

The differences in MFT and LPC are theoretical and not necessarily in practical application.  California didn't even have an LPC license until a few years ago so the vast majority of LMFTs actually clinically operate more like LPCs.  The standards of practice to protect the public are the same.  I support any movement in bringing these two designations together vs the confusion and disharmony that exists in holding them as vastly different.  It is confusing to the public, isolating to the clinicians and costly to everyone.  I find the comments against this argument mean-spirited and disheartening (and even antiquated.)

LMFT's are not qualified to be counselors. It would be unsafe to not test them in the theories of counseling.

LMFT is a specialty training with a focus on relational and family systems. The scope of practice, theoretical orientation, differs from LPC which encompasses and has broader range of practice and training. The exam assesses for technical knowledge, as well as ethical and legal considerations. It should not be permissible for a LMFT to bypass this competency assessment particularly in the absence of training and education specific to the field with whom the exam is designed for. If the theories and training of both fields were deemed equivalent there would be one exam…there is not. I do not support this proposed exemption/petition.

The process and training for becoming a LMFT and LPC are very different and have unique focuses.  Yes, they overlap at times; however, the scope and focus remain different.  As a LPC, I choose to refer to LMFTs when working with certain cases that require complex family system work because I feel that is what they train for and is clinically appropriate/ethically sound.  I'm operating as a professional that the same consideration is also being paid as we are ethically bound to work within our scope of competency, meaning we have been educated, trained, and tested in certain domains that do not overlap.  As much as I know there is a great need for mental health supports currently, I do not support this proposed exemption.

California has had licensure 14 years way longer than "a few years."

Re: Opposition to Virginia Petition 418

To Whom It May Concern:

The Council for Accreditation of Counseling and Related Educational Programs (CACREP) opposes Virginia Petition 418 which would allow licensed marriage and family therapists (LMFTs) to bypass national counselor exams, needing only the LMFT examination for licensure as a Licensed Professional Counselor (LPC).

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.

Licensing exams serve as a critical assessment of an individual’s competence to enter a profession. For Professional Counselors, the National Counselor Examination (NCE) and the National Clinical Mental Health Counselor Examination (NCMHCE) evaluate both content knowledge, based on CACREP curricular standards, and practical skills, grounded in a job task analysis of practicing counselors. At least one of these exams is required by licensing boards in all 50 states. In contrast, the National Marriage and Family Therapy (MFT) exam assesses a more focused area of practice, specific to the field of marriage and family therapy, which does not encompass the broad scope of competencies required for Professional Counselors.

Allowing LMFTs to become LPCs without passing the relevant counselor exams would create a pathway that fails to fully assess competence for practice in this profession. This approach poses a risk to public safety by permitting individuals trained in a different field to practice as Professional Counselors without the necessary qualifications. Practicing outside one’s area of expertise is not only inadequate in addressing client needs but also unethical, as emphasized by the American Association for Marriage and Family Therapy (AAMFT) Code of Ethics, section 3.11.

For these reasons, CACREP opposes Virginia Petition 418.

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

I do not support removing the exam requirement for one discipline to become licensed in aonther discipline.  Marriage and Family Therapists are trained differently than Professional Counselors.  Each discipline is valuable.

LMFT's are counselors. CACREP accredits programs that train family therapists, they receive the same base education with extra coursework in systems work and 600 hours of supervised internship. LMFT counseling trainees often have internships in the same places as other counseling trainees, CSB's, addictions treatment, inpatient, and outpatient therapeutic agencies. 

Taking national exams is costly and can be prohibitive on a structural level. As counselors we need to be promoting workforce development, mental health access is at an all time low.

Why not decrease a structural burden for LMFT's by allowing the acceptance of the national exam they already have to take? It seems like decreasing a structural barrier to promote professional counseling access would be an ideal of the counseling profession.

I appreciate LMFTs and the work that they do. They have focused training and work that extends beyond other helping professionals' training in working with couples and families. Because of this, their training and their professional identity is not the same as professional counselor training and identity. I am very worried about diluting counselor identity, as we have been fighting for decades for a strong professional counselor identity. The NCE or NCMHCE exams are both grounded in counselor training and are more appropriate exams for the LPC than is the National MFT exam. I do not support this petition and hope that the Board does not pass it.

The LMFT exam is there to serve a purpose specific to the discipline. It was not intended to assess readiness for LPC.

As a student in a couples and family counseling program, I can appreciate the specialized training available that LMFT’s have had. That said, I also recognize that there are a broader set of skills available to general professional counselors that as a student I am seeking out. I plan to obtain licensure as an LPC, LMFT, and NCC. However, I also recognize that there are distinctions and it would be unethical to practice outside our scope of expertise. Therefore, while it is cumbersome to take multiple exams I am opposed to bypassing that safeguard for the public. I also am in favor of creating a pathway for LMFTs and LPCs to become dual licensed that does not require an additional full degree in a couples and family program.

I am opposed to this proposal. I understand that it is being made, in part, to balance the regulation that allows lpc's to become lmft's without taking the national mft exam. I'm equally opposed to that provision and would suggest that the path to equity is to require applicants to take the exam that is intended to assess skills and knowledge for the professional license being sought! We are two different professions who cover much the same scope of services, but from a research and technique base that relies on quite different base assumptions. Neither profession can claim outcome supremacy, but the client community deserves to know that the license being presented represents a professional trained in that particular speciality with a background of education, supervised experience and skills consistent with the license advertised. This change would cloud that understanding.

I oppose this petition. In Virginia, LPC’s have been permitted to become LMFT’s without taking the MFT licensing exam, a practice I would also oppose. Professional examinations are designed to measure competency in specific areas of study, including theory and practice outcomes. An MFT practitioner has been trained in systemic (relational) theory and practice; the exam measures competency of systemic theoretical approaches and their practice. Similarly, the Counselor exam reflects that discipline’s theory and training, focused on individuals. The disciplines overlap but retain areas unique to their professional arenas. Any profession requiring examination should hold their applicants responsible for a passing grade in their discipline. This petition seeks to correct an imbalance in the licensing exam requirements within the purview of the Board of Counseling; however, this exacerbates a blurring of the professional lines that already exist.

Allowing LMFTs to become LPCs without passing the relevant Counselor exams would create a pathway that fails to fully assess competence for practice in this profession. Practicing outside one’s area of expertise is not only inadequate in addressing client needs but also unethical, as emphasized by the American Association for Marriage and Family Therapy (AAMFT)