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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7/24/22  9:28 pm
Commenter: J. A. Elliott, LPC

Strongly Against

I have serious concerns about this proposed change. I strongly believe that this will cause confusion to the general public and others by presuming that someone has a full license to practice. This confusion stems from the word Licensed being in the proposed title—which is misleading and could potentially break ethical codes to do no harm.


The Board of Counseling has a good way of differentiating between when someone is licensed and when someone is in their residency. There is not a good reason to change this distinction, especially in the way that the petitioner is asking. This proposed change can put people at risk of being exposed to harm due to the wording and the potential for misrepresentation by residents to clients. Further, this proposed change is confusing and potentially harmful to clients and the general public as well as the legitimacy of the profession and other entities/professions.


I agree with the concerns regarding the petitioner’s motivations brought up by Prof. Michael Moates, MA, LP, LCMHC, LBA. He stated, “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” Upon reviewing the provided link,, I second these concerns which further reinforces my aforementioned concern for the large potential for harm to clients and the misrepresentation of resident status by residents to clients.


Overall, I am strongly against this change and the potential harm it may cause to the profession, the field of mental health, and, most importantly, the general public—who are our potential clients/consumers.

CommentID: 122907