Virginia Regulatory Town Hall
Department of Health Professions
Board of Counseling
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]
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7/18/22  9:46 pm
Commenter: Prof. Michael Moates, MA, LP, LCMHC, LBA

Comment Against Petition

Hello and thank you for taking the time to read my comment.

I have grave concerns about doing what the petitioner is asking. I believe that this will cause confusion to consumers and other entities by presuming that someone has a full license to practice.

The term resident in the medical field typically refers to a medical doctor who has reached a point of their career where they are refining their skills but have a full independent licensure to practice medicine.

The Board of Counseling currently has a good way of differentiating between when someone is in training and when someone has full licensure. There is no reason to change it especially in a way that can confuse consumers. Further, I do not agree with the other commenters that there should be a pre and post test title. Someone either has a full license to practice or they are in training. There should be no wiggle room.

The petitioner just graduate this year and it seems like he is trying to jump the gun. There is a requirement before getting the LPC title for a reason. Mr. Kaste is charging $185-230 well above the average for a therapist in training and the concern by me is that this would seek to add legitimacy (implying full credential) to a not yet fully licensed practitioner. See

Further under the authorizing statute § 54.1-3500. Definitions. it says that ""Professional counselor" means a person trained in the application of principles, standards, and methods of the counseling profession, including counseling interventions designed to facilitate an individual's achievement of human development goals and remediating mental, emotional, or behavioral disorders and associated distresses that interfere with mental health and development." You are not fully trained until you complete the educational, experiential, and examination requirements. Thus, it is my belief that this would not be in line with what the legislature intended.

Thank you.

Prof. Michael Moates, MA, LP, LBA, LCMHC

CommentID: 122753