Category Archives: Press Releases

New Final TRICARE Regulations came out July, 17, 2014

News from Courtenay J. Culp, LCPC, Executive Director of LCPCM

July, 27, 2014

New Final TRICARE Regulations came out July, 17, 2014

Delineating the Requirements for LCPC Independent Practice under TRICARE

The US Department of Defense published in a final rule July 17, 2014 to implement the new TRICARE Certified Mental Health Counselor (TCMHC) provider type as a qualified mental health provider authorized to independently diagnose and treat TRICARE beneficiaries and receive payment for services.

The final rule goes into effect on August 18, 2014. The TRICARE rule includes at least three major wins which the Licensed Clinical Professional Counselors of Maryland (LCPCM) and our advocacy partners made. They include:

1)      An extended “transition period” (grand-parenting period) to January 1, 2017, providing extended time to prepare and take the NCMHC Exam.

2)      Expansion of the pool of qualified supervisors to include licensed psychologists, licensed social workers and psychiatrists so more LCPCs will be eligible.

3)      Keeping the current supervised TRICARE providers, now called Supervisor Mental Health Counselor (SMHC) intact with the ability to practice with physician referral indefinitely.

We are disappointed that TRICARE is requiring the NCMHC Exam instead of the NCE. However, at least there is a 2 ½ year extension to prepare and take the exam should you want to become an independent TRICARE provider.

Additionally, we are disappointed that TRICARE kept the CACREP-only policy for approval of graduate programs, but we intend to continue to lobby vigorously to have this aspect of the rule amended.

LCPC of Maryland and Massachusetts MHCA leaders are now working with TRICARE to make the TRICARE application easier to complete.

Again, if you want to be an independent provider for TRICARE, you will have to have passed the NCMHC Exam by January 1, 2017.

To read the Final Rules, go to https://federalregister.gov/a/2014-16702

TRICARE Position Statement

Coalition of Concerned Counselors (CCC) &
Licensed Clinical Professional Counselors of Maryland (LCPCM)
http://www.concernedcounselors.org
inquiries@concernedcounselors.org

 

Position Paper

July 15, 2014

Military families and veterans do not have access to the majority of the nation’s most experienced and highly trained licensed mental health counselors

 

The Problem:

1. Many military families and veterans who are currently in treatment with highly qualified licensed mental health counselors will have to terminate therapy before completion of their treatment due to new and limiting TRICARE regulations.

TRICARE, in an effort to expand mental health services for military families, unintentionally created regulations that only permit a small fraction of state licensed mental health counselors to provide much needed care.

2. TRICARE must create an alternate pathway to eligibility for licensed counselors that is equivalent to the current pathway in terms of standards, but results in the expansion services to veterans and military families, by including    the most talented and experienced licensed counselors to serve.

3. The Veteran’s Administration created a job classification for licensed counselors that excludes the nation’s most experienced and highly educated licensed counselors. The Veteran’s Administration must create an alternative employment pathway for licensed mental health counselors, to expand our veteran’s access to the most highly trained and experienced licensed counselors in the nation.

 

The Solution:

The federal government should implement standards for the participation and employment of mental health counselors in its agencies and programs. The stringently high standards that follow ensure the uniformity and quality of the counselor’s training and education, while broadening the pool of mental health providers in our communities. The current standards implemented at the Veteran’s Administration and at TRICARE insure uniformity at the expense of quality and experience. The following standards are equivalent or higher to the eligibility requirements of the VA and TRICARE:

  1. State licensure as a professional counselor or clinical mental health counselor
  2. State authorization to diagnose and treat mental and emotional disorders and conditions.
  3. A master’s degree from a regionally accredited graduate program that prepares students to meet the state licensure requirements for professional counseling or clinical mental health counseling.
  4. Documentation of 60 graduate course hours to include at a minimum the current eight common core curricular areas recommended by the Council of Accreditation of Counseling and Related Educational Programs (CACREP) for professionals who practice clinical mental health and professional counseling.
  5. A supervised clinical practicum and/or internship that meets the standards for state licensure.
  6. Two years of supervised post-graduate experience in clinical mental health counseling.
  7. Passed the National Certified Counselor Exam and/or the National Clinical Mental Health Counselor Exam in accordance with state licensure requirements.

The Background:

Unlike psychologists and clinical social workers, licensed clinical mental health counselors graduate from a variety of accredited masters and doctoral level programs leading to degrees in counseling, clinical community counseling, clinical mental health counseling, counseling education, counseling psychology, school psychology, pastoral counseling, among others. These graduates are eligible to apply for a license to practice clinical mental health counseling, but all licensees must meet the same requirements established legislatively by their respective states. To ensure the consistency and quality of the educational training of their mental health counselor licensees from the various accredited graduate programs, each state mandates the specific graduate program of study, including the number of graduate credits, specific coursework, training, internships, supervision, post-masters experience and national examination. Applicants must successfully complete the same specific criteria to be licensed to practice. This is what unifies and identifies our profession. Our field is different in this regard from the other comparable clinical professions whose national associations accredit graduate programs and determine the uniform standards for those programs. It cannot be assumed that, because professional counselors have a different method for standardizing the profession and thereby ensuring public safety, that the quality of service provided by the profession is superior or inferior to other methods.

A study by the Institute of Medicine recommended uniform graduate program accreditation to align the profession with the other mental health professions. The Council of Accreditation for Counseling and Related Educational Programs (CACREP) is a national accreditation body that can offer uniformity in programs from state to state. It must be emphasized, however, that the Institute of Medicine did not report any difference in the effectiveness of treatment or quality of services provided by licensed mental health counselors compared to services provided by social workers and psychologists who currently serve as eligible providers in federal government agencies and programs.

The new TRICARE and the Veterans Administration (VA) criteria for participation and employment now require the counselor to have graduated from a graduate program accredited by the Council of Accreditation for Counseling and Related Educational Programs (CACREP), disregarding the fact that CACREP accredits a very small number of clinical mental health counseling programs. This requirement alone excludes the vast majority of licensed counselors, some of whom attended the finest of our nation’s universities and colleges well before CACREP began to accredit clinical mental health counseling programs. It also discounts the well-established laws and regulations in each state carefully designed to protect its citizens. This is happening at the same time that services to veterans and military families are sorely needed.

Summary and Conclusion

The unintentional consequences of new regulations for licensed mental health counselors participation and hiring in the federal government has disrupted treatment of veterans and military families, has excluded access to the most experienced and qualified mental health counselors in the country, and has inadvertently reduced the pool of qualified mental health providers.

The solution is to establish an additional pathway to eligibility that provides military families and veterans access to the most experienced and qualified mental health counselors in the nation. The requirements presented in this paper provide uniformity and quality for the mental health counseling profession while incorporating the majority of established state licensure laws and CACREP standards.

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We invite counselors and the public to take a closer look at the issues at http://www.concernedcounselors.org .

 

About The Coalition of Concerned Counselors (CCC): CCC is a growing confederation of individual counselors, client rights advocacy organizations, counseling associations, and professional graduate programs created in order to educate counselors and the public on the growing threat of CACREP-only restrictions on counseling practice.

 

About Licensed Clinical Professional Counselors of Maryland (LCPCM): LCPCM is a 501c6 advocacy organization for the rights of clients and the development and equity of professional counselors.

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Are All the 2014 NBCC Foundation Scholars from CACREP Schools?

Some weeks ago we were wondering if the NBCC Foundation scholarships had a CACREP requirement.  When we asked a NBCC customer service representative, we could not get a clear answer.

If NBCC scholarships were restricted in this way, it would raise a question of fairness, since one group of counselors would be receiving preferential treatment over another. NBCC, like ACA, is a counseling organization that includes members of many counseling backgrounds, both CACREP and CACREP-unaffiliated, who loyally contribute dues each year unaware of any differential treatment of students from their alma maters.

The NBCC Perspective column (pages 64-65) of this month’s June 2014 Counseling Today seems to answer our question.

EVERY SINGLE 2014 WINNER IS FROM A CACREP SCHOOL

When we searched the NBCC website for specific criteria, we found that its preferential treatment of CACREP students was not as subtle as we thought, but clearly articulated in the requirements for their scholarships. Here are the requirements for the minority scholarship, as an illustration:

Be enrolled in good standing in a master’s-level counseling program accredited by the Council for Accreditation of Counseling & Related Educational Programs (CACREP). Applicants must carry at least six credit hours during the current semester and have already completed at least 18 credit hours.

• Possess substantial experience with ethnically, culturally and racially diverse communities.

• Commit to providing counseling services to underserved or minority populations for at least two years after graduation.

• Commit to applying for the National Certified Counselor (NCC) credential prior to graduation.

Obviously, NBCC is practicing preferential treatment toward one group of counseling students – those from CACREP schools — which is inconsistent with their mission as a neutral certification organization.

It is unfair and discriminatory for counseling students from CACREP-unaffiliated schools to be cast as political pawns, used to emphasize a perspective that is not unanimously held by our profession–that CACREP is the singular accrediting body. NBCC’s policy penalizes these students for their choice of graduate program, irrespective of whether they have other qualities such as minority status, economic disadvantage, or superior academic achievement that should recommend them for a NBCC scholarship.

This raises a series of interesting questions for us:

Since graduation from a CACREP-accredited program is currently not a requirement to sit for NBCC examinations, nor is it currently a requirement to become a mental health counselor in any state, why is NBCC using it as a primary criterion to select scholarship recipients? Is promoting CACREP accreditation more important than supporting counseling students who may be disadvantaged or members of minority groups?

Question: Why is NBCC offering scholarships only to CACREP students?

NBCC examinations are marketed to CACREP and CACREP-unaffiliated counselors alike for attaining national certification after their graduate training. In fact, CACREP-unaffiliated counselors wishing to continue as TRICARE providers are directed to take NBCC’s National Clinical Mental Health Counseling Examination (NCMHCE), which leads to national certification as a mental health counselor.  All counselors take these exams, but only CACREP students are allowed to compete for scholarships offered by the organization.

Counseling students in both CACREP and CACREP unaffiliated schools regularly apply to become Nationally Certified Counselors, which involves a significant application fee and yearly dues to NBCC.  On one hand, NBCC supports students unaffiliated with CACREP by providing this pathway to the NCC.  Yet, it is concerning that NBCC accepts their dues (without regard to the accreditation of their school) but then channels its scholarship support to only those who are attending a CACREP school. Use of their fees for a political purpose that acts against their own interests violates an inherent trust that accompanies their affiliation with NBCC.

NBCC should be a neutral party, but it is clearly taking sides in a complex political issue within our profession.

NBCC’s partisanship also discounts the value of CACREP-unaffiliated schools, many of which are among the nation’s leading graduate programs, including a number at Ivy League and nationally ranked schools. Their students should be equally entitled to scholarship support from NBCC.

If NBCC is the impartial regulator of certification exams across our profession, and readily accepts dues from students and graduates of both CACREP and CACREP-unaffiliated programs, they must be politically neutral and stand above organizational politics. The Counseling profession deserves higher standards from those who purport to maintain our standards.

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We invite counselors and the public to take a closer look at the issues, sign-up to take action and receive newsletters and alerts, and to read the many documents in our document library outlining the lack of organizational leadership in appropriately addressing this crisis.  You can also find FAQs, the latest blog entries, proposed solutions, and more at http://www.concernedcounselors.org .

About The Coalition of Concerned Counselors (CCC): CCC is a growing confederation of individual counselors, client rights advocacy organizations, counseling associations, and professional graduate programs created in order to educate counselors and the public on the growing threat of CACREP restrictions on counseling practice.

About Licensed Clinical Professional Counselors of Maryland (LCPCM): LCPCM is a 501c6 advocacy organization for the rights of clients and the development and equity of professional counselors.

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Most LPCs are Unaware of the Possible Loss of Federal Insurance Provider Status, Licensure Portability, and Livelihood Due to CACREP Restrictions

FOR IMMEDIATE RELEASE: 05/01/14

Most LPCs are Unaware of the Possible Loss of Federal Insurance Provider Status, Licensure Portability, and Livelihood Due to CACREP Restrictions.

www.concernedcounselors.org will fill in the knowledge gaps and provide a focal point for advocacy efforts.

ORGANIZATIONS:
Coalition of Concerned Counselors (CCC) & Licensed Clinical Professional Counselors of Maryland (LCPCM)

CONTACTS:
www.concernedcounselors.org
inquiries@concernedcounselors.org

Michael Reeder LCPC – National Advocacy Chair, LCPCM
410-871-TALK
Larry Epp LCPC – President, LCPCM
240-683-6580 X205
Betty Bracht LCPC – Board Member at Large, LCPCM
301-871-1699

As many as 70% of all currently working counselors are quietly in danger of being dropped from TRICARE, potentially excluded from MEDICARE (when the legislation is finally passed), and gradually losing the ability to transfer their license to another state.  Recent actions by the Ohio and Florida licensing boards have even restricted the ability of counselors from CACREP-unaffiliated graduate programs to obtain state licensure or transfer their licenses state to state.  (CACREP is one of several organizations which certify masters programs for counselors nationally.)

In order to provide badly needed education and a focal point for advocacy efforts, The Licensed Clinical Professional Counselors of Maryland (LCPCM) is proud to announce the launch of the Coalition of Concerned Counselors website at http://www.concernedcounselors.org .

Larry Epp, President of the Licensed Clinical Professional Counselors of Maryland, states “most counselors who graduated and obtained their licenses years ago think of graduate program accreditation as something that no longer concerns them.  They have no idea that licensing boards, government programs and, potentially in the future, private insurance panels may start to restrict participation by the training you obtained in the past.  CACREP-unaffiliated counselors will find themselves on gradually dwindling islands of practice.  The sufficiency of state licensure is being challenged.”

Counselors who are dimly aware of the issue assume that there must be grandfathering clauses or upgrade paths to certification available as this would only make sense.  But this is not the case, as grandfathering in TRICARE only opens a narrow window for most LPCs and the Veteran’s Administration offered no option for grandfathering at this time.

Some other problems in brief with current CACREP restrictions:

~ The exclusion of other professions from supervision and core facility positions, leading to the loss of training diversity, the threatened extinction of masters level counseling psychology programs, and the invalidation of supervised experience from the past when counselor supervisors were not available.

~ The potential loss of huge numbers of therapists at a time when public mental health needs are soaring.

~ The definite loss of trusted counselors from the TRICARE system in light of the mental health difficulties of returning veterans and their families.

~ The continual and unsubstantiated portrayal of CACREP-unaffiliated counselors as inferior in training.  Top notch universities including Harvard, Columbia, George Mason, Towson, University of Maryland, Seton Hall, and (until recently) Johns Hopkins have graduated excellent CACREP-unaffiliated counselors for years.

~ The complete failure of any of a number of possible solutions, from multiple allied standards, to upgrade paths to certification, to generous grandfathering.

~ The decades-long divisions and animosity likely to ensue in the profession.

We invite counselors and the public to take a closer look at the issues, sign-up to take action and receive newsletters and alerts, and to read the many documents in our document library outlining the lack of organizational leadership in appropriately addressing this crisis.  You can also find FAQs, the latest blog entries, proposed solutions, and more at http://www.concernedcounselors.org .

About The Coalition of Concerned Counselors (CCC): CCC is a growing confederation of individual counselors, client rights advocacy organizations, counseling associations, and professional graduate programs created in order to educate counselors and the public on the growing threat of CACREP restrictions on counseling practice.
About Licensed Clinical Professional Counselors of Maryland (LCPCM): LCPCM is a 501c6 advocacy organization for the rights of clients and the development and equity of professional counselors in Maryland.

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