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.