As an aspiring counseling psychologist, I am currently pursuing my M.S. in counseling and look forward to utilizing my degree at a master's level.  I am writing to strongly oppose any regulatory change in Virginia that would limit LPC licensure to graduates of master’s programs accredited by the Council on Accreditation of Counseling and Related Educational Programs (CACREP). Based on my belief in multiple paths to licensure as an LPC, my stance is neither anti-CACREP nor is it anti-accreditation. The field of counseling and the public using mental health services benefit from graduates of diverse programs, multiple paths to licensure, and from inclusivity of graduates from all accredited counselor preparation programs – CACREP or otherwise. My perspective on the proposed regulatory change is shaped by the following considerations:

·                     Diversity and inclusion in mental health is of paramount importance. In a time of integrated care and rising mental health needs, mental health providers are called to work together for the good of the public’s health needs.

·                     Given the state of mental health care in Virginia, more service providers – rather than fewer service providers are needed. For example, according to the National Association for Mental Illness (NAMI), only 19% of Virginians with serious mental illness receive services from Virginia’s public mental health system. And, as of 2013, Virginia had 47 federally designated mental health care professional shortage areas (Signer, 2014). Addressing this shortage requires that Virginia protect and support valuable counselor training programs  – rather than close them due to the administrative and financial limitations of achieving CACREP accreditation.

·                     The proposed change would unnecessarily restrict trade of LPCs in Virginia and LPCs moving into Virginia. This includes LPCs from neighboring states that do not restrict licensure to a particular accrediting body.

·                     The proposed regulatory change also limits the hiring of mental health professionals outside of counselor educators as full-time faculty members in CACREP-accredited training programs, which in turn restricts quality supervisors, educators, and mental health providers from sharing their expertise in training and supervising new counselors in the state of Virginia.

·                     The role of the licensing board is to protect the citizens of Virginia through the regulation of licensure, and not accreditation. To cede the power of setting educational requirements that meet the needs of Virginians to a single, out-of-state accrediting agency does not protect the citizens of Virginia. Further, doing so may step beyond the charge of the counseling board.

·                     There is no empirical evidence to suggest that CACREP graduates are more effective or more ethical providers, and commonly cited evidence to the contrary is methodologically unsound.

·                     Counseling programs in Virginia that are not affiliated with CACREP are renowned. For example, in 2013, the counseling program at George Mason University – a program that is not affiliated with CACREP – was awarded the Outstanding Master’s Program award by the Southern Association for Counselor Education and Supervision.

·                     There are other paths to accreditation of counseling programs. For example, the Masters in Psychology and Counseling Accreditation Council (MPCAC) accredits counseling programs and requires that programs meet a standard that meets (and in some domains exceeds) the rigor of CACREP standards.

I strongly recommend that the Commonwealth of Virginia not approve this change. Instead, I strongly believe that Virginians will be best served by a diverse body of LPCs, and not only those with degrees from programs affiliated with CACREP. 

Respectfully,

Anna A. Brand