As the Chair of the Department of Psychology at Radford University, I am writing on behalf of our former, current, and future students to express my opinion about the necessity and urgency for the board to establish clear and consistent guidelines regarding the educational requirements for the LPC and to improve the transparency of the process whereby applicants are approved to sit for the LPC. 

Several points seem particularly important:

• Given the vast differences in opinion about whether or not graduates from Psychology Programs should be eligible for the LPC in Virginia, it is clear that the Board needs to make a clear, definitive, and operationally definable statement that will officially and conclusively end the debate once and for all in Virginia.
• Most people who opposed the petition felt adamantly that the training and orientation of counselors is fundamentally different from that of psychologists and that the LPC should be restricted to counselors. Most people who supported the petition felt that individuals should be judged on their coursework and their actual job performance, rather than on their philosophical orientation.
• Many people who opposed the petition did so because they thought it would be unethical to grant the LPC to graduates from Psychology Programs. Many people who supported the petition argued against this position citing evidence that CACREP approves some programs which are housed in Psychology Departments (including at least one in Virginia). Additionally, they cited other states around the country that recognize and grant the LPC to graduates from Psychology programs. In fact, several students who have been denied the LPC in Virginia have, or are in the process of, obtaining their LPC in other states. Finally, from 1977 until 2009, graduates from Radford University’s Clinical Psychology program were LPC eligible in Virginia. As one person who was subsequently licensed in DC posted, “Does ethicality really vary by state?” Thus, although people may oppose the petition on other grounds, the argument that the Board of Counseling “cannot ethically sanction those trained in the discipline of Professional Psychology” cannot be justified by any reasonable and objective assessment of the training and supervision actually provided to students in psychology programs.
• Many people who opposed the petition did so because they felt that it was an issue of protection of the public. However, the board should note the substantial number of individuals who have supervised graduates from Radford University’s program who have attested to the quality of its graduates. It should also note the significant number of CSBs who have voiced support for this petition, including the Virginia Association of Community Service Boards who documented a severe shortage of licensed behavioral health professionals. I think it is also noteworthy that even one former member of the NBCC and CACREP boards stated “I am confident that master’s level psychologists are well trained”. Thus, although he strongly opposed the petition on other grounds, he did not question the competence or training of master’s level psychologists.
• It appears that there are two programs in the Commonwealth that have been particularly impacted by the change in interpretation of the regulations, Radford University and Virginia State University. I would encourage the board to take an active role in working with these two programs to make a definitive conclusion as to whether or not their graduates will be license eligible. These programs will then have the duty to inform their students about whether or not they will be license-eligible. However, until the criteria for determining whether or not a program meets the educational requirements are made explicit, the programs are not in a position to do so.
• Numerous students from both Radford University and Virginia State University expressed support for the petition and voiced considerable frustration regarding the change in regulations. Several had their application for the LPC denied, others moved out of state or went on to further graduate training due to a concern that they would not be LPC eligible. 
• A considerable number of individuals expressed support for adopting a grandfather clause for those who were negatively impacted by the changes. If a student completed his/her degree prior to the change in the regulations, or if the regulations were imposed after the student had already begun his/her program, then it would seem only fair to grant such students the opportunity to be grandfathered in. Even if the board ultimately decides that the philosophical distinction between counselors and psychologists is so great as to exclude psychologists in the future, the change in regulations should not penalize individuals who entered a graduate program prior to the changes. 
• One of the major problems at the root of this debate stems from a lack of communication. Of particular note is the fact that after three students were rejected in 2009, the Psychology Program at Radford made many significant changes to the program to bring it into compliance with the Educational Requirements set by the board. If the board has explicit criteria with which they evaluate students’ application for the LPC, then surely they can inform the program of whether or not it currently meets those educational requirements. Although the board has consistently claimed that it “approves individuals, not programs”, it seems logical that the board would be willing to communicate with the programs whose graduates were turned down due to “insufficient emphasis on counselor preparation in the academic curriculum and program description”.  In fairness to our graduates, we ask that you not force one of them to be the “test case” to determine if the changes made by Radford University are sufficient. Rather, you inform the program so that we can advise students as to whether or not our program currently meets the educational requirements outlined in the regulations.

I believe that the board has the responsibility to make a determination on whether the philosophical distinction between counselors and psychologists is so great that it will exclude graduates from psychology programs from being eligible for the LPC. Additionally, it is also clear to me that the board has the responsibility to assure that the guidelines are so explicit that there will be no question to the programs, or to the students entering and graduating from the programs, as to whether their degree will include or exclude them from being LPC eligible in Virginia. Clearly the lack of clarity has caused considerable concern and debate, and thus I encourage the board to act quickly and put the confusion to rest. I offer three possible options for the board to consider.

One option would be to simply require that all students must graduate from a CACREP accredited program, period. If the program meets the standards set forth and enforced by CACREP, then the licensing board could remove section B of the regulations which suggests that graduates from other programs would potentially be eligible. That would end the confusion. Programs that are not CACREP accredited would then know that they either have to become CACREP accredited, or let students entering their program know, in no uncertain terms, that they will not be eligible for the LPC in Virginia under any circumstances.

A second option would be that no students who have graduated from any program housed in a Department of Psychology would be eligible for licensure, regardless of whether the program is CACREP accredited or not.  Period. Needless to say, this option would create problems for programs such as JMU, which is CACREP accredited, housed in a department of psychology, and has several psychologists as identifiable counselor training faculty.  

A third option would be to operationally define “counselor training faculty”, based on objective and measurable criteria rather than on subjective interpretations of this highly ambiguous term. As the regulations currently read, neither programs nor individual faculty members have any way of assessing whether or not the faculty or the program meets the regulatory guidelines. As another individual previously questioned, “Do the faculty have to have graduated from a Counseling Program in a Department of Education? Can the faculty have graduated form a Counseling Program in a Department of Psychology? Do the faculty have to have their LPC? Any or all of these would represent objective criteria that would remove the ambiguity of language which seems to be at the core of the problem. I urge you to remove the ambiguity from the language currently used in the regulations. This lack of clarity has led to considerable hardship for many graduates from such programs as evidenced by many of the postings to this petition. This lack of clarity also provided the impetus which led to the current petition. If graduates from a program are denied the opportunity to sit for the LPC in Virginia because their program did not have “a sequence of academic study with the expressed intent to prepare counselors as documented by the institution,” then the board must make explicit how this can be documented. Presumably, a sequence of academic study with the expressed intent to prepare counselors would be evidenced by the program description listed in the University’s Graduate Catalogue and the Program’s Mission statement posted on the Department’s website. If a program explicitly states that its intent is to prepare counselors and it has a sequence of academic study that directly maps onto the coursework dictated by the regulations, then presumably the program has met this criterion. If such evidence is not sufficient, what specific type of evidence would be necessary?

In conclusion, regardless of which option it ultimately chooses, I urge the board to act with speed, with clarity, and with due consideration for the students, faculty, and alumni of Virginia university graduate programs.  I also request that, regardless of how the criteria are settled and clarified, serious thought be given to the option of grandfathering in the many individuals who have been most hurt by changes in the LPC eligibility regulations..