As a faculty member in an Applied Psychology department that trains both Master's and Doctoral students for the counseling psychology profession, I am writing to oppose any regulatory change in Virginia that would restrict professional counseling licensure to graduates of master’s programs accredited by the Council on Accreditation of Counseling and Related Educational Programs (CACREP).

While my position is not anti-CACREP, the counseling profession benefits from graduates of quality training programs, which includes graduates from programs accredited by CACREP as well as programs that are not affiliated with CACREP. My perspective on the proposed regulatory change is shaped by the following rationale:

1. The role of the licensing board is to protect the citizens of Virginia through the regulation of licensure, not accreditation. Licensure and accreditation are not the same. To cede the power of setting educational requirements required for licensure to one entity does not protect or advance the citizens of Virginia. Further, doing so may exceed the authority of the licensing board.

2. The citizens of Virginia, due to their constitutional rights, move across state borders in pursuit of quality graduate education. Requiring CACREP affiliation for VA licensure limits VA residents from engaging in commerce and travel as they see fit. Thus, the proposed regulatory change would unnecessarily restrict trade of LPCs in Virginia, non-CACREP graduates seeking to return home to VA from out-of-state, and out-of-state LPCs contemplating relocation to Virginia. Essentially,VA would be sending well-trained counseling professionals packing out of VA to North Carolina, DC, Maryland, as well as to other regions of the U.S.

3. 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.

4. VA has a high population of racial, ethnic, gender, and sexual diversity. There are qualified underrepresented graduates of color, linguistic, and sexual minorities from non-CACREP programs. Although they are VA citizens, they would be unable to practice in VA if this regulatory change is approved. There are patients who would like to work with practitioners who speak their native language without the intrusive presence of an interpreter. Other practitioners would like to have the choice of a practitioner whose cultural backgrounds resonate with their own. This regulatory change seems inconsistent with the promotion of choice, diversity, psychological health, and even capitalism.

I urge the Commonwealth of Virginia NOT to approve this change in regulation. Virginians would be best served by LPCs who hail from programs affiliated with CACREP and those that are not.

Sincerely,

Professor Tracy Robinson-Wood