Monthly Archives: July 2015

Pitfalls of Grandfathering in the New ACA Governing Council Plan

[Those who have not seen the ACA Governing Council meeting minutes endorsing CACREP-Only can find them here.]

We received the following excellent question back-channel from a concerned counselor:

“I read your ACA post with alarm this morning…  Maybe you can clarify a question: What would this ruling mean for someone like me, who has been licensed with an LPC since 1999, from a non CACREP school?.  Would I automatically be grandfathered in, or will I have to make up for any possible deficiencies with my school program, by 2020?”

Good question.  What it will MOST LIKELY mean, is that you will be grandfathered-in and not have to do any further training (not have to make up “deficiencies”).

We remain very alarmed because such a probable outcome does not mean those grandfathered-in are safe.  We just won’t know until events are gradually done to us over the years.

ACA is claiming in the governing council motions that non-CACREP counselors will be treated equally.  I hope so.

In a few of our recent postings we have pointed out instances of prominent CACREP-only communications defaming or at least indirectly implying inferiority of non-CACREP counselors.  This is a message that state boards, Congress, and the general public are being bombarded with.

In order for those grandfathered to remain equal and have fully empowered future careers the following needs to happen:

  • State licensing boards need to adopt the recommended grandfathering provisions exactly, and not something harsher. (Don’t forget they are getting the messaging that we are inferior.)
  •  State licensing boards requiring some sort of alternative licensing procedure for non-CACREP counselors need to NOT adopt requirements so gosh darn exact to CACREP that those non-CACREP counselors going through the procedure would have to redo training for trivial reasons (like redo internships because they were not broken into two components instead of one for example).
  • Portability between states would need to be possible for non-CACREP counselors, as opposed to us being stuck in the state where we managed to get grandfathered before 2020 or whenever.
  • AMHCA and other parties need to immediately quit efforts to get TRICARE, the VA, Medicare, and who knows what other government programs and insurance panels to adopt CACREP-only paneling standards.  If the squeeze is being put on non-CACREP counselors at the state licensing level (ACA wants CACREP-only after 2020 in state licensing) then approval for a state license needs to be the final standard for participating in Federal and other programs.  Having a state license is not very helpful if the non-CACREP counselor then gets blocked from TRICARE, VA, and maybe Medicare or elsewhere.  It’s not true grandfathering if your license is second-rate.
  • The messaging of non-CACREP is inferior needs to stop.  It will be increasingly impossible to control the fallout.  Who can blame the general public, Congress, state licensing boards, private insurance panels, etc. if they adopt less-than-enlightened policies to exclude non-CACREP counselors if they truly believe such to be inferior?  This will shortly no longer be under the control of our professional associations as the messaging will result in independent actions in the world-at-large.
  • Medicare (when we finally get authorization for it) needs to NOT have any CACREP-only language in it.  Private insurance companies often mimic Medicare standards.  This is truly what could kill non-CACREP counselors.  Imagine being a non-CACREP counselor 5-10 years from now and being stuck in one state (although you need to move) and only being able to take 1 or 2 remaining insurance panels while all of your CACREP peers are able to take all insurance panels, TRICARE, and Medicare.
  • If the nightmare of private insurance companies and Medicare having CACREP-only regulations does materialize, then non-CACREP counselors better become really good at solo private practice because employers will be hiring CACREP counselors even if we still have state licenses.

We can’t swear all of this dooms day stuff will happen.  But it’s not rocket science to see how it reasonably could.  Especially with “our” professional associations actively working against us.

Let’s also not forget about the dozens and dozens of master’s programs in counseling psychology being actively hounded out of existence.  Such is not okay and does not serve the “profession” (whatever that means anymore) and certainly does not serve the mental health needs of the public.  NBCC’s offer to help “counseling psychologists” (their term for master’s level counseling psychology graduates after 2020) get licensing from scratch in all 50 states is an absurd atrocity that would be amusing if it was not so sad.

The AMHCA Threat to TRICARE and Medicare Counselor Participation

Below is some sample language from what the North Carolina AMHCA state chapter is sending to their members.  Presumably some other AMHCA chapters are doing this as well?  Please note that non-CACREP counselors are being referred to here as “non-clinically trained”. Also please note the very strong connection being made to the push for Medicare recognition. It is abundantly clear that some elements of AMHCA intend to cut non-CACREP counselors out of Medicare (most likely with some grandfathering). Historically many private insurance panels tend to follow Medicare guidelines, so that is very bad news indeed if it happens.

Also below is text taken from a letter sent to Congress from one CACREP-only partisan. This is the kind of attitude problem that we face from their most strident supporters. It may be news to many of the non-CACREP counselors reading this message that you are not trained in the “art and science of Professional Counseling”, and that you are not amongst the “best amd [sic] most qualified counselors”. It is also implied that you may not even be “qualified”.

It is CRITICAL that counselors with a broader vision of professional counseling continue to write Congress urging that the final version of the National Defense Authorization Act (NDAA) include the House version of the language in HR 1735 expanding TRICARE provider eligibility.

Senators and members of Congress are most receptive to letters from their own constituents. You can find your representatives here: http://www.contactingthecongress.org/ Please include particulars about your own state (lack of CACREP programs, etc.)

The Congressional NDAA conference committee members reconciling the House and Senate versions of the bill can be emailed by sending your letters to the following distribution list: tricarecounseling@concernedcounselors.org – this is not an ordinary email address, it directly redistributes your email to the committee members.

The ACA has been supportive of the more inclusive House language. AMHCA has broken with ACA on this issue. However, what ACA has not done is send a mass email campaign out to all of its members urging letters of support for the inclusive House version of the NDAA TRICARE language. ACA is perfectly capable of doing this and does so relatively often. We need to urge ACA to take this step quickly. AMHCA (with roughly 7,000 or so members) should not be able to field a stronger membership lobbying campaign than the 55,000 member-strong ACA.

 

AMHCA NC Chapter — Quotes:

[Italics added]

“IMPORTANT NOTICEThere is a bill in the Senate that could put our chances to get Medicare recognition back years, possibly not until 2027, if then.  It was proposed by ACA without consultation with any other professional association.  It would allow non-clinically trained [at LPC level] counselors to become TRICARE counselors. This would all but eliminate any chance of our getting Medicare recognition.  We have not gotten Medicare recognition because there several states who license LPCs with much lower standards than NC, and this would only worsen that. This has serious implications for us in …”  

“The House passed HR1735, which contains Section 712, which reverses the gains we made in the TRICARE ruling in 2014 and moves them to 2027. The Senate version does not contain the wording of Section 712.  The bill will go into conference soon, if not already.  We need to contact Senators… and … and our Representatives to let them know this will seriously damage the quality of mental health services for our military.”  

 

CACREP-Partisan Letter to Congress – Quotes:

[Italics and bolding added]

“There are many who are writing you today and in the past who have been trained in mental health programs that are not professional counseling by training and not CACREP accredited. Many of these programs while well intentioned do not provide through training in the art and science of Professional Counseling.

CACREP affords veterans and their families the opportunity to have qualified trained counseling professionals to provide the many mental health counseling services they need. Individuals trained in other related professions, while licensed as professional counselors, are not trained in the art and science of professional counseling…”

“I am a member of the American Counseling Association and I do not support their position of a 10 year grandfathering period. As a professional counselor educator in a CAQCREP accredited program, I am concerned that the 10 year period indicates that there is no desire to ensure that veterans get the best amd most qualified counselors.

“Professional counseling is a unique profession that has its own accreditation standards in CACREP and it is important that counselors have that training to provide the best possible services to our veterans and their families.”

ACA Commits to CACREP-Only

The ACA governing council has officially committed to CACREP and only CACREP all the way.  ACA is also going to send Virginia a letter of support for their proposed new CACREP-only licensing regulations.

The only good news here is support for grandfathering thru 2020 and (somehow) trying to keep those of us grandfathered as treated equally into the future.  Nonetheless this is a direct threat to dozens and dozens of fine master’s level counseling psychology graduate programs, and so is not really acceptable.

~~~
ACA Governing Council Meeting

July 20-21, 2015

Motions

It was moved by P. Francis and seconded by T. Mitchell to approve the recommendations of the Awards Committee regarding the ACA Fellows Award program. Motion passed.

It was moved by K. Butler and seconded by G. Lawson for the Governing Council to endorse the Multicultural and Social Justice Counseling Competencies. Motion passed.

It was moved by G. Lawson and seconded by P. Francis that to unify the professional identity of counselors, ACA endorses supports and advocates for graduation from a Counselor Education program accredited by CACREP/CORE as the pathway to licensure for independent practice.  Motion passed.

It was moved by S. Haberstroh and seconded by T. Mitchell that ACA, in all advocacy efforts related to licensure for independent practice, endorse licensed professional counselors (including comparable state counseling licenses), licensed on or before July 2020, as qualified independent practitioners with the same professional privileges and practice options as graduates from CACREP and CORE programs. Motion passes.

It was moved by G. Lawson and seconded by P. Francis that ACA shall, within its current legislative advocacy structure, endorse and will advocate for:

Standards that require graduation from a counselor preparation program accredited by CACREP or an approved affiliate of CACREP (e.g. CORE).

Students must demonstrate sufficient preparation in addressing clinical issues in order to be eligible for licensure for independent practice. In addition to concentration on Mental Health, psychological, and human development, this preparation shall include both coursework and practice in assessment, diagnosis, treatment planning, and clinical interventions for individuals with serious mental illnesses and/or serious emotional disturbances. Students must complete a practicum of at least 100 hours and an internship of at least 600 hours. Graduates from programs accredited by CACREP or an approved affiliate of CACREP (e.g. CORE) in Clinical Mental Health Counseling, Clinical Rehabilitation Counseling, Marriage Couple and Family Counseling, or Addictions Counseling are assumed to have met these clinical preparation requirements. Graduates of other CACREP or CORE tracks will need to demonstrate that they have met the clinical coursework requirements.

ACA will support and advocate for a liberal grandparenting period of seven (7) years after the adoption of this language in state regulations, whereby individuals who graduated from regionally accredited programs can still achieve licensure and regionally accredited program have sufficient time to pursue accreditation from CACREP or an approved affiliate of CACREP (e.g. CORE).

This advocacy will be included in the ACA Governmental Affairs Agenda as soon as is practicable.

Motion passed.