Virginia News
As of April 2nd, 2022
Thanks to everyone who posted public comments and who spoke out and contributed their voices in the fight for the inclusion of all counselors! We generated 181 comments, only a handful of which supported the proposal that suggested that counselors who seek licensure in VA and who graduated from programs accredited by CACREP should only need 3 years of post-licensure while those who graduated from other programs would need 10 years of post-licensure experience.
There was no public follow up from the VA Governor’s office.
Thank you for your commitment to counselor inclusion!
Alliance for Professional Counselors (APC; www.apccounseloralliance.org)
As of December 5th, 2019
Great news! The Virginia Board of Counseling withdrew their proposal to require CACREP accreditation for counselor licensing today! For more details on that action, see the Virginia Regulatory Town Hall page.
Thanks to everyone who wrote letters, posted public comments, spoke out at meetings, and otherwise contributed to this success for counseling, counseling psychology, and the public!
As of October, 2019
We thank all who responded to our most recent advocacy alert by posting public comments against the recent licensure by endorsement/portability proposal in Virginia! Together we generated 138 comments (not counting one that was obviously spam and another duplicate) of which 129 (93.5%) were opposed and 9 were in favor either of the proposal or CACREP in general (6.5%).
APC strongly objects to that proposal, which is still under consideration. 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. We noted there is NO evidence to support this proposed discrepancy.
Thank you very much!
Alliance for Professional Counselors (APC; www.apccounseloralliance.org)
As of September, 2019
Action Alert! Time sensitive! Public comment closes 9/18/19!
Once again we need YOUR help to maintain inclusive counselor licensure in Virginia – and beyond! The focus is on licensure portability, the eligibility of a counselor licensed in one state to qualify for licensure in another.
The Alliance for Professional Counselors fully supports portability for all counselors and the American Counseling Association’s (ACA) 2016 Portability Plan. 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.
See this link for a brief intro, actual text of the ACA plan and FAQs https://www.counseling.org/knowledge-center/aca-licensure-portability-model-faqs#
Last year, we generated hundreds of comments in opposition to earlier Virginia proposals that would have promoted CACREP, not broad licensure portability. We need your help to do that again!
The current proposal, while offering several options for all licensed counselors, falsely suggests that licensed counselors who graduated from programs accredited by CACREP (who would need 3 years post-licensure experience) are more qualified than those who graduated from other programs (who would need 10 years post-licensure experience).
According to the current proposal, licensed counselors from other jurisdictions would be qualified for licensure by endorsement in Virginia if they either 1) meet all requirements for initial licensure in Virginia including specific coursework, supervised experience, and residency, or 2) have 2 years post-licensure clinical practice in counseling in the last 5 years, which includes teaching graduate courses in counseling, or 3) hold NBCC’s Certified Clinical Mental Health Counselor (CCMHC) for which the NCC and therefore, effective 2024, graduation from programs accredited by CACREP, are prerequisites, or 4) have held an active license in the other jurisdiction for ten years, or 5) have held an active license in another jurisdiction for 3 years and have either graduated from a program accredited by CACREP or hold the NCC credential (which, as above, will be limited to graduates of programs accredited by CACREP effective 2024).
There is no documented evidence that licensed counselors who graduated from programs accredited by CACREP are better prepared than their peers who graduated from other programs! Why then, should the majority of licensed counselors who did not graduate from programs accredited by CACREP be required to show 7 more years of experience than their peers who graduated from programs accredited by CACREP?
The ACA Portability Plan (see above) is a significantly better option than this proposal!
Please submit comments strongly opposing the proposed regulations for licensure by endorsement (that is the ability of a counselor licensed in another jurisdiction to qualify for Virginia licensure) to the Virginia public comments forum on or before Tuesday, September 18, 2019 at 11:59 pm. http://www.townhall.virginia.gov/l/comments.cfm?stageid=8544
Your comments matter! They’ve made a difference in the past – and they can again!
In addition to public comments, letters from individuals, departments, universities, and professional organizations are also helpful! Please send letters on or before September 19, 2019 to:
Dr. David E. Brown, Virginia Department of Health Professions
Perimeter Center
9960 Mayland Drive, Suite 300
Henrico, Virginia 23233-1463
David.Brown@dhp.virginia.gov
Thank you very much!
Alliance for Professional Counselors (APC; www.apccounseloralliance.org)
As of October 20th, 2018
New Action Alert! Time sensitive! Public comment closes 10/22/18!
Once again we need YOUR help to maintain inclusive counselor licensure in Virginia – and beyond! This time the focus is on licensure portability, the eligibility of a counselor licensed in one state to qualify for licensure in another.
Although we support portability, we urge you to join with us in opposing the current Virginia proposal “To amend the requirements for licensure by endorsement to include the National Counselor Licensure for Endorsement Process (NCLEP) as a route for counselor licensure”. This proposal was submitted by Charles R. McAdams, III, a member of the CACREP Board of Directors https://www.cacrep.org/about-cacrep/board-of-directors/board-members/
Rather than a plan to broadly promote license portability, the NCLEP is another plan to promote CACREP!
The NCLEP route allows portability for fully licensed counselors with three years’ post-licensure experience who have either 1) graduated from a program accredited by CACREP, 2) hold the NCC credential (which will soon be available only to graduates of CACREP-accredited programs), or 3) meet the requirements for licensure in the state in which they seek licensure. NCLEP would only increase the portability of licenses held by CACREP graduates (as they would not need to meet additional state requirements). It would do nothing for the majority of licensed counselors who graduated from or are currently enrolled in programs that are not affiliated with CACREP – and in fact, could further limit their employment options and would set a dangerous precedent!
For more information about NCLEP, see this link: https://www.nbcc.org/Assets/Portability/Portability-Statement-Endorsement-Process.pdf
Note that the American Counseling Association (ACA) declined to endorse the NCLEP and adopted its own Portability Plan in 2016!
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 the NCLEP, the ACA plan respects all counselors, the licenses they hold, and doesn’t require a waiting period.
See this link for a brief intro and actual text of the ACA plan: www.counseling.org/knowledge-center/licensure-requirements/licensure-portability-model-fact-sheet and this for FAQs https://www.counseling.org/knowledge-center/aca-licensure-portability-model-faqs#
The ACA Portability Plan is a significantly better option than the NCLEP!
Please submit comments strongly opposing the proposal to adopt the NCLEP to the Virginia public comments forum on or before Monday, October 22, 2018 at 11:59 pm.
http://townhall.virginia.gov/L/ViewPetition.cfm?petitionid=281
Your comments matter! The Board is scheduled to consider them at their November 2 meeting.
In addition to public comments, letters from individuals, departments, universities, and professional organizations are also helpful! Please send letters on or before October 22, 2018 to:
Dr. David E. Brown, Virginia Department of Health Professions
Perimeter Center
9960 Mayland Drive, Suite 300
Henrico, Virginia 23233-1463
david.brown@dhp.virginia.gov
Kindly forward copies of your letters to Dr. Fred Bemak at George Mason University (fbemak@gmu.edu)
Thank you very much!
As of September 21st, 2018:
Together we generated 80 comments on the Virginia public comments forum! Those 80 comments are unanimous in their opposition to the recent regulation that restricts supervisors to licensed professional counselors (LPCs) and marriage and family therapists (LMFTs). Many commenters also opposed attempts to restrict licensure to graduates of programs accredited by CACREP. Both successes are a testimony to everyone who commented and encouraged others to do so! Thank you all for that.
Many, if not all, who posted public comments received an email from Elaine Yeatts, Senior Policy Analyst for the Virginia Department of Health Professions, advising that the regulation restricting residents’ supervisors to licensed professional counselors (LPCs) and marriage and family therapists (LMFTs) was adopted in accordance with established procedure, directing the reader to specific links that support that position. We appreciate that information.
APC replied to Ms. Yeatts, the Governor, Dr. Brown, and Dr. Carey noting that notwithstanding this additional information, the notation at this link indicates that regulations proposed in 2011 (that included the current supervisory restrictions) were “withdrawn” and “amended as part of the Regulatory Reform Initiative”. http://www.townhall.virginia.gov/l/ViewStage.cfm?stageid=5891
Nonetheless, our comments stand: We continue to advocate for reversing the new supervision restrictions and advocate against potential imposition of CACREP-only regulations. APC is committed to inclusivity in education, supervision, licensing, and employment.
As of September 5th, 2018:
We need YOUR help to maintain inclusive counselor licensure and preparation in Virginia – and beyond!
The current periodic review of the Virginia regulations for the practice of professional counseling closes September 5, 2018 at 11:59 pm. The purpose of this review is “to determine whether this regulation should be repealed, amended, or retained in its current form. Public comment is sought on the review of any issue relating to this regulation, including whether the regulation (i) is necessary for the protection of public health, safety, and welfare or for the economical performance of important governmental functions.”
We urge you to submit comments opposing the current regulations that restrict counseling residents’ supervisors to people who hold an active Licensed Professional Counselor (LPC) or Licensed Marriage and Family Therapist (LMFT) license and urge a return to more inclusive supervision requirements that includes licensed psychologists, psychiatrists, and social workers! After unanimous opposition to this then-proposed regulation in a 2012 public comment period, it appears this new restriction was added as part of a part of a Regulatory Reform Initiative, bypassing the normal usual levels of review for regulatory changes.
In addition, although not specifically part of this periodic review, we also urge you to submit comments opposing the Board of Counseling’s continued efforts to restrict Virginia counselor licensure to graduates of programs accredited by CACREP, despite official withdrawal of the proposal last Fall. These continued efforts are documented in their minutes and are confirmed by reports from prospective licensees.
The proposed restriction that would limit licensure to graduates of programs accredited by CACREP and restrictions of graduates’ supervisors to LPCs and LMFTs are clearly NOT “necessary for the protection of public health, safety, and welfare or for the economical performance of important governmental functions,” which are the goals of the periodic review.
CACREP-only restrictions would create a government-imposed monopoly of a private organization that is not accountable to the citizens of Virginia. It would also force George Mason University, an internationally respected counselor training program and the only counseling program in Virginia that is not, by choice, accredited by CACREP, to pursue that accreditation or close. Rejecting this proposal would not harm any program that chooses to pursue accreditation through CACREP; they can still do that. Rejecting this proposal would, however, maintain a path for licensure and service in Virginia for the national (and international) majority of students, alumni, and faculty in counseling programs that are not affiliated with CACREP.
We also urge you to urge decision-makers to strike the regulation that restricts graduates’ choice of supervisors to people with LPC and LMFT licenses. That current regulation specifically excludes the majority of qualified supervisors in hospitals and related clinical settings, most of whom are licensed as psychologists, psychiatrists, and social workers. If this regulation is not changed, the experience in other states has been that this will pose a significant employment barrier to new graduates seeking employment in agencies and regions of the state where these supervisors are not available (and who can only offer supervision through psychologists or social workers). This policy actually harms the employment prospects of new counselors and hampers the growth of the profession. In addition, it should be noted that this regulation, which has yet to go into effect, was adopted outside the normal processes after a public comment period in which all commenters opposed the then-proposed regulation.
Letters and comments from individuals, departments, universities, and professional organizations truly do matter! Please send your letters and submit your comments on or before September 5, 2018 to:
Honorable Ralph Northam
Governor of Virginia
P.O. Box 1475
Richmond, VA 23218
https://www.governor.virginia.gov/constituent-services/communicating-with-the-governors-office/
Dr. David E. Brown, Virginia Department of Health Professions
Perimeter Center
9960 Mayland Drive, Suite 300
Henrico, Virginia 23233-1463
David.Brown@dhp.virginia.gov
Dr. Daniel Carey, Secretary of Health and Human Resources
Office of the Secretary of Health and Human Resources
P.O. Box 1475
Richmond, VA 23218
HealthAndHumanResources@governor.virginia.gov
Elaine J. Yeatts
Senior Policy Analyst
Department of Health Professions
9960 Mayland Drive, Suite 300
Richmond, VA 23233
And
Via this link http://www.townhall.virginia.gov/L/comments.cfm?periodicreviewid=1671
Kindly forward copies of your letters to Dr. Fred Bemak at George Mason University (fbemak@gmu.edu)
Thank you very much!
As of November 3rd, 2017:
VIRGINIA PROPOSAL WITHDRAWN!
In an important decision for all counselors, the Virginia Board of Counseling WITHDREW, on November 3, 2017, a proposal that would have made graduation from a CACREP-accredited program a requirement for state licensure. APC vigorously opposed this proposal at every step of the regulatory process, and many APC members and allies posted powerful comments on the Virginia Town Hall website during its public comment period. The comments ran approximately 30 to 1 AGINST the proposed regulation. Congratulations and thanks to all who assisted in this effort!
More details on the the Virginia Board’s actions and APC’s response can be found under our “State Issues” tab.
The Board’s stated reason for withdrawing the proposal, according to the Virginia Town Hall web page, is “to allow more time for discussion and collaboration.” We hope this collaboration will involve members of the counseling community who favor retention of inclusive policies, to advance our common purpose of providing high quality, accessible counseling services to the public.
APC will continue to advocate for our mission of protecting practice rights and opportunities for all qualified counselors. We can take heart in knowing that our collective voices make a difference!
Thank you!
As of Sept 2017:
Proposed Virginia Regulatory Change Threatens All Counselors!!
Your Input is Needed!
The Virginia Board of Counseling has “re-proposed” a change to the regulations for LPC licensure that would restrict new licensees to (ONLY) those who hold a degree from a CACREP or CORE-accredited program. This change was originally proposed earlier this year. It was followed by a public comment period in which expressed opinions ran approximately 30 to 1 AGAINST the new restrictions. The comments were considered by the Board of Counseling, who then re-issued the proposal on September 8, 2017. You can read this proposal (and sign up for email notification of the next public comment period) at http://townhall.virginia.gov/l/viewstage.cfm?stageid=8032
Importantly, earlier this year, Virginia Governor Terry McAuliffe asked the Board to consider adding pathways to licensure for those who did not graduate from a CACREP or CORE program. The “re-proposal” purports to offer alternatives, however in fact it does nothing to ease the restrictiveness of the original proposal. The Board’s “alternatives” and the reasons that they do not represent viable alternatives are summarized below:
- The Board re-proposal states that individuals who did not graduate from a CACREP or CORE program may become eligible for licensing by pursuing the CCMHC credential (Certified Clinical Mental Health Counselor) through the NBCC (National Board of Certified Counselors). However, as of December, 2021, the NBCC will offer the CCMHC certification ONLY to graduates of CACREP programs. You can read about this change at http://www.nbcc.org/Assets/EducationalStandards.pdf
At the implementation date of the proposed regulations, pursuit of the CCMHC for graduates of programs outside of CACREP/CORE will already have been eliminated!
The Board’s document also cites a 7-year period for implementation as giving programs time to become accredited. However, CACREP accredits only a fraction of LPC training programs in the country, namely, those that award the degree in “counseling” or “counselor education.” Those such as “counseling psychology” or those with an interdisciplinary core faculty are not eligible, so no amount of time before implementation will allow those programs to become CACREP-accredited.
- The re-proposal also allows graduates of programs accredited by “any other accrediting body acceptable to the board” to become licensed. However, it explicitly disqualifies MPCAC (the Master’s in Psychology and Counseling Accreditation Program; see http://mpcacaccreditation.org/), which is the primary alternate accreditation for counseling programs.
Despite the fact that MPCAC-accredited programs primarily train graduates specifically for LPC licensure in many other states (CO, FL, GA, HI, IL, IN, KS, KY, MA, MD, MO, NJ, NM, NY, OH, OK, OR, PA, SC, TX, WA, WI), the Virginia Board claims that these programs “are primarily psychology-related and would not meet the current requirements of the Board for counseling education (p. 5).” The Board report further states that “CACREP is the only identified accrediting body for counseling education (p. 5).” Therefore, the re-proposal clearly offers no accreditation-based alternative for counselors who did not attend a CACREP/CORE program.
In short, the re-proposal would institute a requirement of graduation from a CACREP or CORE program for all newly-minted counselors. There is no viable provision for those trained in other programs, including other accredited programs. The re-proposal contains the same restrictions as the original.
The Board utilizes a very narrow definition of “counseling education,” which equates “counseling” training with CACREP training. We disagree and object to this interpretation. In fact, counseling training in MPCAC-accredited programs mirrors Virginia educational requirements almost perfectly. (Virginia requires one additional course, Substance Abuse Counseling, in addition to MPCAC requirements. This course is an elective in many MPCAC programs). The chart at the end of this statement shows the compatibility between MPCAC accreditation requirements and Virginia educational requirements.
APC asserts that the Board’s distinction between counseling training obtained in “psychology” and “counseling” departments is an artificial one. Theoretical and research foundations, philosophy, and methods employed in counseling all derive from and are shared with psychology.
Finally, the Board’s statement says that “Endorsement will take care of counselors licensed in other states” meaning that currently-licensed counselors in other states can become licensed in Virginia by meeting their endorsement requirements. These can be found at https://www.dhp.virginia.gov/Forms/counseling/LPC/LPC_Licensure_Process_Handbook.pdf
Licensure by endorsement in Virginia requires either “Educational and supervision experience requirements comparable to those required for persons applying for licensure in Virginia by examination” or other requirements including documentation of licensed clinical experience of at least 24 of the last 60 months.
Since “comparable” educational experience would imply a CACREP-program degree, under the proposed regulation, licensed counselors from other states whose graduate program was not CACREP-accredited would presumably have to meet the more arduous requirements for endorsement, including post-licensure experience. Extra hurdles will have been added for these licensed professionals.
The Virginia Board states that its proposal will work in the best interest of the public. APC believes that barriers to practice by counselors trained outside of the CACREP umbrella are not justified, and risk harm to the public by restricting access to and choice of counseling professionals.
More than half of counselors trained in the U.S. are NOT from CACREP programs. Absent any data that CACREP-trained counselors are better prepared to serve the public, the restrictive re-proposed regulatory change is inherently unfair to other well-trained counselors.
APC continues to work to oppose this regulatory change in Virginia. It will be important for all counselors and counseling students to express opinions in the next public comment period. Please watch for notices from us about this comment period! You can sign up to receive email updates from the Virginia Town Hall at http://townhall.virginia.gov/l/viewstage.cfm?stageid=8032
Update: On October 2 the Virginia Department of Planning and Budget issued its analysis, which is NOT supportive of the CACREP-only regulatory change. It is posted at the website noted above. This is not the last stage of the process – your input will continue to be very important in the upcoming public comment period!
Comparison of Virginia Educational Requirements for LPC Licensure
with MPCAC Accreditation Standards
| Virginia Coursework Requirements | 2017 MPCAC Accreditation Standards |
| Three semester or 4 quarter hours of graduate study in each of the following: | Competency areas as demonstrated in academic and applied experiences |
| 1. Professional counseling identity, function, ethics | A. Professional identity, and ethical and professional standards, including: Ethical/Legal Standards and Policy; Professional Values and Attitudes |
| 2. Theories of counseling and psychotherapy 3. Counseling and psychotherapy techniques 5. Group counseling and psychotherapy theories and techniques | B. Evidence-based theories and practice of counseling and psychotherapy: Knowledge (e.g., individual and group theories); Relationships (Relates effectively with individuals, groups, and communities); Intervention (e.g., career, group, family, and/or systems-level interventions) |
| 4. Human growth and development | I. Developmental basis of behavior |
| 6. Career counseling and development theories and techniques | G. Career development and/or the role of work in peoples’ lives |
| 7. Appraisal, evaluation and diagnostic procedures | E. Tests, measurements, and other assessments of behavior |
| 8. Abnormal behavior and psychopathology | D. Theories of psychopathology and relevant classification systems |
| 9. Multicultural counseling, theories, and techniques | C. Multiculturalism and diversity |
| 10. Research | F. Research methods and program evaluation |
| 11. Diagnosis and treatment of addictive disorders | |
| 12. Marriage and family systems theory | J. Social/organizational/community basis of behavior (Demonstrates knowledge of individuals in the context of their environment and how the environment (e.g., geographical, ideological, demographic, familial, institutional) affects functioning. Demonstrates understanding of the use of systems changes (whether by prevention or intervention) to enhance the functioning of individuals, families, groups, organizations, and/or institutions. |
| H. Biological basis of behavior | |
| K. Understanding and use of supervision during applied experiences | |
| 13. Supervised internship of 600 hours w/240 face-to-face hours of client contact | Supervised experiences, a minimum of 600 hours, at least 40% of which is direct contact hours |