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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7/21/22  3:41 pm
Commenter: Anonymous

For the Title Change

I’m for the change in title. The scope of practice, responsibilities and ethical mandates per VA Board of Counseling, and ACA, do not change. Simply the title changes. The current resident handbook still mandates that residents post their provisional license in a conspicuous location, inform clients that they can not practice independently or directly bill for services. Residents in Counseling would still have to complete the NMHCE, 3,500 hours of experience and be under the supervision of an independently licensed, board approved supervisor during that time frame.

I do understand the concerns of confusing the general public on the change. However, it does not change the board regulations on scope of practice for residents. Plus, I would argue that the general population finds the current title confusing already. As residents, it is their (and their supervisor’s) ethical responsibility to provide psychoeducation on the limits of practice and trainee status in all of their public facing materials and all written communication.

Currently, in the state, a Certified Substance Abuse Counselor (CSAC) is a regulated bachelor’s degree level profession. How does this title differ in terms of public confusion? How does this title resonate with the public’s understanding? Of course, the CSAC is needed due to the substance use crisis, but let us look at the full picture in the state. Especially with the Counseling Compact gaining national traction. Clients want uniformity. Client’s want clarity. This can be a step in that direction. If you are concerned, consider the following ACA Ethical Codes:

C.4.a. Accurate Representation

F.1.c. Informed Consent and Client Rights

F.5.c. Professional Disclosure

CommentID: 122853