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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12/4/13  5:38 pm
Commenter: Joanna Bryant, MS

In support of Dr. Chase's petition
 

I graduated from Radford University in the year 2000 with a clinical psych degree.  It took me a number of years to finally get in a position where I could receive supervision that I could afford and when I did so I was informed this by the Board of Counseling:

"Based on the information contained in your application materials the credentials committee determined that your course of study did not meet the requirements set forth in regulation 18VAC115-20-49, specifically because:

1. There was insufficient emphasis on counselor preparation in the academic curriculum and program description

2. The faculty roster does not have an identifiable counselor training faculty."

I hear many individuals state that they oppose my being licensed for ethical reasons.  In my position I struggle to be philosophical about being marginalized in my career path due to what appears tantamount to hair splitting and semantics.  The entire business smacks of sophistry and politics in my perception.  I have seen some of my peers who went on to be licensed because they were able to get supervision in a timely manner.  Those individuals I know of this sort have represented people from my background in a professional and highly credible manner. 

There are many points in which I personally struggle.  During my matriculation through Radford, I took many of my core curriculum classes with counseling students.  Now the Board says in essence that my degree has been declined for lack of a better word because I do not have a degree that says "counseling" on it.   So I am being compelled to either take another degree where I will be required to repeat the same classes.  I could understand if they want supplemental classes if there are gaps in my training but why do I have to bear the expense of repeating numerous classes where I have had training that has been approved for licensure in other contexts? In my dozen years or so in the field I have worked side by side with licensed individuals doing the same work for less renumeration. My choices at this point are a bit grim.  I can choose to take another degree.   I can leave the field.  I can leave the state.  Or I can remain in my now marginalized position.  These are all highly uncomfortable prospects at my age and a bitter pill in light of my years of sevice to my community and to the Commonwealth.

Looking to the future, if the Board wants to continue pursuing this policy I think it would be the wisest course for them to be very up front if they are going to reject students from psychology programs etc, or from non-cacrep accredited programs so that the program knows in advance and can explicitly state it on their website that graduates will not be license eligible in VA.  I would also appreciate if they would give consideration to grandfathering those of us in who had no idea that this change was in the wind when we were choosing a graduate program that would help us meet our career path needs.  However I think that would be half measures to say the least.

I also have a few remarks pertaining to the arguement regarding there being a potential ethical concern with "improper training."    Several people who opposed the petition mentioned that there are 12 CACREP accredited programs in the state. But they failed to mention that CACREP also accredits programs in Departments of Psychology. This seems to call into question that assertion that the philosophical differences between psychologists and counselors are so vast that it would be unethical to grant the LPC to someone who graduated from a Counseling or Clinical Psychology program. Relatedly, someone also mentioned that the distinction between counselors and psychologists has now been determined clearly by 50 state legislatures who have independently voted to adopt separate professional licenses for Counselors and Psychologists. But they failed to mention that many states still grant the LPC to graduates from Psychology Programs at the Master’s level, as did Virginia up until 2009. Given that a) CACREP is willing to accredit programs in Psychology,  b) the VA regulations explicitly state that graduates from CACREP accredited programs  by definition meet the educational requirements, and c) that numerous other states continue to grant the LPC to graduates from Clinical and Counseling Psychology programs, the arguments that the “Board of Counseling cannot ethically sanction those trained in the discipline of Professional Psychology to practice as Professional Counselors” does not seem hold merit.

In closing, I want to invite the Board to consider that decisions of this nature can often have unseen ripples of effect that can last for years to come.  Some very qualified and valuable individuals will likely leave this field and the negative effects will not just be experienced by them but the clients and communities they would have served as well.  Please reconsider this policy.

Most sincerely,

Joanna Bryant

 

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