Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Counseling
 
chapter
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]
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11/18/24  10:17 am
Commenter: Council for Accreditation of Counseling and Related Educational Programa

Oppose this Petition
 

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.

CommentID: 228875