Monthly Archives: April 2014

The Florida CACREP and Grandfathering Trap

The state of Florida requires that Licensed Mental Health Counselors have a master’s degree in mental health counseling from a CACREP accredited program (option 1(a) in their regulations) or that they present closely equivalent credentials (option 1(b) in their regulations). The board’s website goes to some pains to point out that even CACREP accredited degrees in community counseling are not good enough to satisfy the CACREP option 1(a).  The state requires some coursework – such as human sexuality and substance abuse – not offered in all degree programs.

Melanie, a Licensed Mental Health Counselor in New York for the past five years, found this out the hard way. She recently received a rejection letter:

I officially just received my license rejection notice from the state of Florida citing that I needed to take 3 additional graduate courses…  I graduated from my counseling program in 2003, so regardless if it was CACREP or not, educational programs tend to change and evolve over time.  When states decide to adopt a CACREP only policy or even just educational requirements WITHOUT putting a grandfathering clause into place for existing licensed counselors, none of us are protected unless you just don’t move.  Ever.  This appears to me to be either gross negligence on part of the lawmakers and corresponding advocacy/lobbying groups or just general discrimination.

Melanie is hopeful that she can appeal the decision. In the meantime she is falling into a common trap. Counselors face an array of obstacles in moving state-to-state:

  • The possibility of CACREP certification requirements invalidating their educational degrees.
  • Ever increasing coursework requirements that make it cost prohibitive to reach compliance.
  • The difficulty of finding a university willing to let you drop in for just a few classes.
  • The bewildering frustration that meaningful grandfathering opportunities rarely exist.

CACREP states that they are in favor of grandfathering CACREP-unaffiliated counselors into licensing eligibility for a period of seven years. However, support for grandfathering in their obscure position paper on their website is useless unless grandfathering is promoted in all the PR and lobbying efforts under way to promote CACREP at the state and national levels. This seems unlikely as long as CACREP-unaffiliated counselors are being wrongly portrayed as inferior in training.

The Florida example also illustrates the frustration of “alternative” licensing options to CACREP that are anything but.  The CACREP alternative section of the Florida regulations asks for:

The equivalent of at least 1,000 hours of university-sponsored supervised clinical practicum, internship, or field experience as required in the standards for CACREP accredited mental health counseling programs.

The problem here is that this “alternative” requirement to CACREP is TOO EXACTLY like CACREP (as we suspect are many of the section’s requirements).

For example, let’s take Maryland’s requirement for full licensure.  Maryland requires 3000 hours of face-to-face supervised counseling experience, up to 1000 hours of which may be accrued prior to graduation.  So let’s say that you completed an 800 hour internship as part of your graduate program.  You won’t qualify for the Florida license.  More to the point, the shortfall is all but unrepairable.  How the heck would a licensed counselor in another state seeking to move to Florida return to a graduate school just to complete additional supervised practicum?  How awkward would this be for a 10-year seasoned counselor even if it could be arranged?  Furthermore, it’s possible that were we to go read the cited internship regulations of CACREP there would be further requirements – perhaps such as no psychologists or social workers for supervisors?

Now in this particular example, it certainly IS better to have 1000 hours internship/practicum rather than 800 hours.  But it’s a trivial training difference for someone who has been in the field more than a few years.

Stepping away from Florida for just a moment, we also have a situation where CACREP-unaffiliated counselors can take the National Clinical Mental Health Counseling Examination (NCMHCE) from NBCC as part of their process to certify for TRICARE before the “grandfathering” period expires at the end of 2014.  We have many reports of counselors not being allowed to take this exam as part of their CACREP alternative credentials for TRICARE because… they don’t have coursework matching CACREP.

We must be on-guard against “alternative” credentials or “grandfathering” options that are de facto CACREP-only since there is no reasonable way for a CACREP-unaffiliated counselor to overcome the barriers.

State reciprocity of licensing is another goal that we should be aiming for. The argument is made that such reciprocity is one of the aims of national certification standards. However,the implementation of such national standards requires a long lead-in period and flexibility for equally desirable alternative training and certification methods.

Melanie goes on to state:

The last time I spoke to a representative at the Florida Board, I was told by the very nice man I spoke to that he hears these stories all the time from very seasoned counselors. It made me realize how much worse it would be if I had been practicing for 30 years and facing this. Nonetheless I believe we need to unite around this issue.

Melanie makes a good point about how difficult (or impossible) it would be for veteran counselors. Although Florida is not all about retirement, lots of retirees do move there. Does this mean counselors will no longer get to retire to Florida if they need to keep working a bit to make ends meet?

The elderly are the folks least likely to seek counseling. If they do, are they really all going to want counseling from 25-year-olds? CACREP-only language strongly favors new counselors. Older counselors are the professionals least likely to have CACREP certified graduate school backgrounds — and seasoned counselors are arguably the professionals with enough life experience to handle seniors more effectively.

Ohio Goes CACREP

UPDATE 5/4/14 — This blog article has significant updates and corrections posted here.

The ACAeNews is reporting that the state of Ohio will be requiring graduation from CACREP certified programs in clinical mental health, clinical rehabilitation, or clinical addiction counseling for licensure as of 2018.

The full text of the legislation is located here.

This licensing requirement is a problem for most of the reasons discussed throughout this website, including the lack of evidence for CACREP standards being superior, the expense for small graduate programs, and the loss of valuable core faculty from related professions.

If CACREP succeeds in adoption into licensing standards state-by-state, we will increasingly see an inability for about 70% of current counselors to move state-to-state.  We will become stranded on shrinking islands where we are able to practice.

Ohio’s adoption of CACREP for all licensing moving forwards gives lie to false reassurances that some counselors are telling themselves.  Many counselors yawn when they hear about an arcane graduate program standard given they graduated years ago.  Other counselors uninterested in military counseling grow bored at discussion of TRICARE certification standards.  But when state licensing starts being effected, its evident that our very ability to even practice is at risk.