I strongly support the proposed revision to the Degree Program Requirements (section 18VAC115-20-49 of the Virginia Regulations Governing the Practice of Professional Counseling) as petitioned by Dr. Chase.

There appears to be several areas of debate about the appropriateness of clinical psychology Master's degree graduates seeking the opportunity to pursue licensure as professional counselors in Virginia and demonstrate their competency on the state licensure exam.  This question rests on several important factors: the educational and training requirements listed in the state's counseling licensure requirements, Virginia's need for counselors, and the possible loss of qualified mental health professionals, specifically clinical psychology graduates, to other states. 

In examining the curriculum of two accredited Virginia schools, one CACREP-accredited, Master's in Counseling program and one Master's in Clinical Psychology program, there is striking resemblance in the curriculum, training experience, and supervision.  In terms of curriculum, the two programs both required a core curriculum of Ethics, Lifespan development, Multicultural counseling, Psychopathology, Research, and Advanced counseling techniques, though the clinical program required multiple courses in assessment, research, and psychopathology.  And, while the counseling program required additional courses in Addictions, Group counseling, Career counseling, and Marriage/Family Systems, these were all electives in the clinical psychology program - in other words, clinical psychology students had the opportunity to take these courses and many would have in order to fulfill elective requirements.  And, both programs had required competency exams.  Lastly, in terms of practicum/internship, both programs required 240 hours of face-to-face client contact and similar overall practicum time.  Practicum sites were consistent across both programs, such as community mental health clinics.  And, supervision was similar across both programs as both utilized faculty and on-site practicum supervisors.  For example, the clinical program required the faculty supervisor to be a licensed clinical psychologist, while the counseling program required the faculty supervisor to hold a "doctoral degree from a counseling program or closely related field."  Additionally, both programs required the on-site practicum supervisor to have a "master's" in the respective field "or a related field."  Though there may be disagreement in the state about the counseling and psychology nonmenclature, I believe most would agree they are related fields.  A similar point of dissent is whether clinical psychology Master's programs have the required "identifiable counselor training faculty" as required by the state counseling requirements, but if counseling programs are permitted to use faculty with "a doctoral degree from a counseling program or closely related field" (as the accredited counseling program does), why then is the suitability of licensed clinical psychologists as "identifable counselor training faculty" in question?

To speak to the second issue, both the current times and near future represent a time of increased need for qualified professionals.  For example, the Institute of Medicine reported in 2012 that one in five older adults have mental health problems; this represents a higher need as "baby boomers" become elders in larger numbers than previous generations, thereby increasing mental health needs.  And, this need only represents one sector of citizens, excluding general populations and the high number of returning veterans (particularly to a state with the largest Navy base in the world and an area popular amongst discharged veterans). 

And, to speak to the third issue, professionals with a Master's in Clinical Psychology from Virginian programs may seek licensure in some other states.  For example, one state requires applicants to hold a "master's or doctoral degree in counseling from a program that is "registered," "accredited...by CACREP," "or determined by the Department to be the substantial equivalent of such a registered or accredited program" (as quoted from that state's Counseling Board regulations).  Again, while clinical and counseling programs are not identical, based on the overlap of required counseling courses that are also required and/or available to clinical psychology students as well as near identical practicum and supervision requirements and placements, the clinical psychology program does evidence itself "a susbstantial equivalent."  Then, with the receiprocal nature of licensure among states, Virginia's regulations do allow individuals with a professional counselor license in another state (and five years experience) to apply for licensure in this state.  So, why does Virginia not allow graduates from clinical Master's programs to seek licensure in counseling when they do allow these individuals to seek licensure after graduating from the Virginian program, leaving Virginia, successfully earning counseling licensure in another state that does afford clinical psychology students the opportunity to pursue licensure in counseling, worked in the other state for a period fo five years, and then returned to Virginia? 

With the equivalency between the educational programs in Virginia, the need for counselors in Virginia, and the acceptance of other state licensing boards to allow graduates of clinical psychology programs to seek licensure in counseling, I fully support Dr. Chase's petition.