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]
Action Changes resulting from periodic review
Stage NOIRA
Comment Period Ended on 9/18/2019
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9/17/19  12:00 pm
Commenter: Susan Woodhouse, Lehigh University

Opposed to the discriminatory proposal
 

Portability of licensure is an important issue to address. This proposal, however, is discriminatory. This proposal gives preferential treatment to graduates of CACREP-accredited programs. There is simply no evidence that graduates of CACREP training programs are better trained or do better work than graduates of non-CACREP accredited programs. There are other accrediting bodies, other than CACREP, that are also very good and do a great job of ensuring excellent training. As of 2024 the NCC credential will be limited to graduates of CACREP accredited programs. This means that if this proposal were to be accepted, ultimately graduates of CACREP programs from other states would only need to have 3 years of experience whereas graduate of programs accredited by other bodies would need to have 10 years of experience. This simply does not make sense. CACREP does not have a monopoly on excellence in training. It would be better to have a more sensible licensure portability plan in order to ensure there are sufficient mental health support options available for Virginians.

CommentID: 76220