The Alliance for Professional Counselors (APC), a national organization of counselors and counselor educators that supports interdisciplinary cooperation and licensure portability, strongly urges you to reject the current proposal for licensure by endorsement. The current proposal is an improvement over earlier proposals because it offers options for licensure in Virginia for all licensed counselors.

However, APC strongly objects to current proposal. We particularly object to the provision that licensed counselors who graduated from programs accredited by CACREP would qualify for Virginia licensure with 3 years post-licensure experience while licensed counselors who graduated from programs that are not affiliated with CACREP would need 10 years post-licensure experience. There is no evidence to support this proposed discrepancy.

Furthermore, this proposal would harm the public by unnecessarily limiting the number of licensed counselors who would qualify for licensure (and therefore professional counseling work) in Virginia. This proposal would also harm the majority of licensed counselors who graduated from programs that are not affiliated with CACREP by making it seem, despite lack of evidence, that they are less qualified. We call your attention to the two successive Virginia Economic Impact Analyses (2016, 2017) for further information. Furthermore, as Virginia has historically been a leader in the profession, this proposal could set a negative precedent.  

The American Counseling Association’s (ACA) 2016 Portability Plan is a significantly better option for portability than the current (or previous) proposals. The ACA Portability Plan would permit counselors licensed at the independent level in one state (who do not have any disciplinary actions against them) to qualify for independent licensure in any other state in which they are seeking residence. Duly licensed counselors would be treated equally across the nation under this plan. Compared with this – and earlier proposals - the ACA plan respects all counselors, the licenses they hold, and doesn't require a waiting period.

We fully respect that these decisions are within the purview of the Commonwealth of Virginia. However, APC asks your consideration because these proposed regulations are detrimental to the citizens and economy of Virginia. Furthermore, we urge you to consider the national implications of these decisions and take action to prevent the adoption of the current portability proposal in Virginia and all proposals to restrict Virginia counselor licensure to graduates of programs accredited by CACREP.

Thank you for your consideration.

Respectfully,

Peggy Brady-Amoon, PhD, LPC

President, Alliance for Professional Counselors

www.apccounseloralliance.org

&

Associate Professor

Department of Professional Psychology & Family Therapy

Seton Hall University

South Orange, NJ 07079