Category Archives: Taking Action

Alliance for Professional Counselors Launches!

(For more information – please see the new APC section of the Concerned Counselors website at )



We are very happy to finally be able to report that the Alliance for Professional Counselors (APC) went public this past Friday 10/16/15 at the Licensed Clinical Professional Counselors of Maryland (LCPCM) fall conference!

APC is a membership organization that aims to include all qualified counselors at all important career checkpoints including program accreditation, state licensing, license portability across states, and govt. and insurance paneling. The first (and very tall) order of business is mounting a response to the relentless CACREP-only onslaught underway in our professional associations, and at the Federal and state levels.

The Licensed Clinical Professional Counselors of Maryland (LCPCM) are proud to be the first organizational affiliate of APC. At our packed business meeting on Friday (estimated 200-300+ people?) the membership voted unanimously to endorse the LCPCM organization affiliating with APC.

The Alliance for Professional Counselors website is currently very sparse — just a few paragraphs and a membership form. In the near future the website will be expanded to include a lot more necessary information and to address what members can do to help with efforts. APC felt that it was important to launch in time for the LCPCM fall conference, and so the website currently online is bare bones. I have attached at the bottom of this email the initial statement from the website.

You can view the APC website at:

More information is online at the Concerned Counselors website. You will find a very brief history of why APC became necessary, as well as some draft goal thoughts for the organization and what it can do for non-CACREP counselors. Please take a look at this unofficial information at:

APC is asking new members to join at a nominal yearly cost which will help with putting together an operating budget. You may also contribute additional funds to the political action committee (PAC). The membership form is available for download from their website.

ACA Deletes Its Own Thread and Latest News Post on North Carolina CACREP-Only Bill

ACA had posted a discussion thread yesterday entitled “ACA Affirms Commitment to Nondiscrimination, Expresses Disappointment in the NC Legislature’s Decision to Coopt Counselor Licensing Bill”.

In it they expressed some confusingly-worded sentiment about the grandfathering for non-CACREP counselors not being enough, and disappointment with the discriminatory add-ons tacked to the bill by the NC legislature which had nothing to do with the original bill.

Apparently ACA is censoring itself now.

As of 4:35pm EST 10/08/15, not only did they remove their own discussion thread, they also killed the article in the “Latest News” section of their website. (Perhaps the Open Forum thread will be reposted later… this has happened before.)

It used to be at this link and was removed:
Makes us wonder at what was objectionable:
1. The sentence in which they wished for better grandfathering for non-CACREP counselors?
2. They decided that they were not committed to non-discrimination after all? (honestly we don’t really think this)
3. They just don’t want to talk about it until after the governor signs it? (our best bet for the sudden removal)

We are attaching what we can retrieve of it below.

The bill on the governor’s desk can be seen here:

This would be a good time to write the governor and ask him not to sign this legislation:
North Carolina Governor Pat McCrory
116 W. Jones St.
Raleigh, NC 27603-8001


Oct 7, 2015 2:55 PM
[ACA Staffer]

Last week, ACA received notification that a bill pertaining to the licensing of counselors in North Carolina, Senate Bill 279, had been scheduled for an immediate vote in the House after passing out of a joint conference committee the day before. A version of S279, a bill pertaining to “Amending Qualifications/Practice of Counseling,” has been sent to the Governor’s desk to be signed.

ACA is glad to see that CACREP standards have been legislated in the state of NC to be included in the state’s licensure requirements. However, ACA is disappointed in the lack of clear pathway for those LPCS with non-CACREP degrees. ACA is committed to supporting adequate grand-parenting for those with degrees from non-CACREP accredited programs.

Read more here.

American Counseling Association
Alexandria VA

2. Re: ACA Affirms Commitment to Nondiscrimination, Expresses Disappointment in the NC Legislature’s Decision to Coopt Counselor Licensing Bill

Oct 7, 2015 4:55 PM
James Michael Reeder

My quick read of the bill sent to the governor for signature (see below) is that it DOES have grandfathering of non-CACREP applicants through 2022. While my opinion is that grandfathering in general is inadequate, I don’t yet see what is lacking in this bill in terms of the grandfathering that is desired by ACA and CACREP. Maybe I am missing something here?

I am also not sure if the ACA is worried about adequate grandfathering for LPCs (regular counselors) or LPCS (supervisors). Clarification welcome, thanks.

To the extent that grandfathering in this bill does not meet ACA hopes, this speaks to my earlier points about it being nearly impossible to maintain the equality of non-CACREP counselors while simultaneously pushing for CACREP-Only in new licensing. Things have a way of getting out of control. (The loudest message sent is that CACREP is better.)

I’ve also expressed hope that ACA efforts to protect non-CACREP counselors will be as vigilant and well-funded as planned efforts to get CACREP-Only licensing language passed in all 50 states. Such a large campaign implies funding and coordination – which I hope will be applied to somehow convincing people that currently licensed non-CACREP counselors should be treated equally. Happily ACA has the grace to cognizant about this issue in regards to this North Carolina legislation.


North Carolina Legislature Passes CACREP-Only Legislation

[5:00pm EST 10/08/15 edit — ACA has deleted its Open Forum post and the news item on their website.  Some of the links in this story will not work anymore.  Read this story first, then click here for the update.]

The bill is apparently on governor’s desk.

Contacts expressing the damage that this bill will do to professional counseling should be addressed to:

North Carolina Governor Pat McCrory
116 W. Jones St.
Raleigh, NC 27603-8001

The ACA is doing damage control about how disappointed they are that the bill lacks adequate grandfathering measures.  See below.  I guess it’s impossible to control all bills everywhere, but this gets to our earlier points about it being nearly impossible to maintain the equality of current non-CACREP counselors while simultaneously pushing for CACREP-Only in new licensing.  We’ve also expressed hope that ACA efforts to protect non-CACREP counselors will be as vigilant and well-funded as planned efforts to get CACREP-Only licensing language passed in all 50 states.  Such a large campaign implies funding and coordination – we hope more such legislative slips will be few and far between.

HOWEVER — Our read of the bill (see below) is that it DOES have grandfathering of non-CACREP applicants through 2022.  We don’t yet see what is lacking in the grandfathering as desired by ACA and CACREP (other than the whole idea of grandfathering being inadequate).  What are we missing here?  Not sure if the ACA is worried about adequate grandfathering for LPCs (regular counselors) or LCPS (supervisors).


[5:00pm edit – This link no longer works.  Deleted by ACA]



ACA Affirms Commitment to Nondiscrimination, Expresses Disappointment in the NC Legislature’s Decision to Coopt Counselor Licensing Bill

Oct 07, 2015

Last week, ACA received notification that a bill pertaining to the licensing of counselors in North Carolina, Senate Bill 279, had been scheduled for an immediate vote in the House after passing out of a joint conference committee the day before.

A version of S279, a bill pertaining to “Amending Qualifications/Practice of Counseling,” has been sent to the Governor’s desk to be signed.

ACA is glad to see that CACREP standards have been legislated in the state of NC to be included in the state’s licensure requirements. However, ACA is disappointed in the lack of clear pathway for those LPCS with non-CACREP degrees. ACA is committed to supporting adequate grand-parenting for those with degrees from non-CACREP accredited programs.

While S279 was written to make amendments to the licensure process, the bill was utilized for other political agendas. In mid-September, the House amended the bill to include significant provisions regarding sex education in North Carolina’s schools, an issue that is unrelated to the licensing of counselors. These provisions, if signed into law, will mandate the promotion of abstinence-only education and write into statute sex education curricula, without including the expertise of educators in the field.

The conference committee version of the bill bore fruit to an even more egregious version of the bill. This version included sections regarding local governance that took away the authority for local government to pass laws raising the local minimum wage, ensuring fair housing, and enforcing non-discrimination in employment practices. As counselors, we understand how important it is that we empower local communities to make the decisions that best serve the people who live there. Local government decisions foster innovation and local control exists to reflect the unique values and needs of different communities.

ACA stands firm in our commitment to nondiscrimination. It is against the 2014 ACA Code of Ethics (section C.5.) and antithetical to the nature of the profession, a profession that is committed to improving the lives of all people. ACA actively fought against the inclusion of these provisions and remains disappointed at those in the North Carolina legislature whom utilized this opportunity to advance other agenda items, distracting from the need to promote and improve access to qualified mental health practitioners in the state.

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: 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: – 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


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.

TRICARE Congressional Conference Committee MONDAY — Letters Needed

[Posted for LCPCM and Concerned Counselors]

Dear Colleagues:

On Monday, the 22nd, a Congressional Conference Committee will be meeting to decide whether ALL Mental Health Counselors will be able to see TRICARE beneficiaries, irrespective of whether they went to a CACREP School. The American Counseling Association advocated for a special provision in the National Defense Authorization Act that would grandfather ALL Mental Health Counselors as independent providers who possess 5 years of clinical experience. This grandfathering period would last 10 years.

This is a VERY IMPORTANT precedent and I am asking every member to take a moment on Monday to send an email to a specially created listserve below that emails every legislative director involved in the conference committee. I need you to write a brief statement telling Congress why CACREP should not be used as the sole criterion to select providers for TRICARE. I fear if we do not stand strong now, the use of CACREP as a selection criterion for insurance reimbursement will seep into MEDICARE and other insurers.

It is a heavy burden to serve as President of our state association while knowing that many of us could face employment and insurance discrimination in the future if we do not act concertedly now to address this threat. I want to do everything possible on my watch to stand up for our profession in Maryland, but I need your help. Thank you for taking a moment to email these legislative staffers. You could make a difference in securing the profession we love into the future.

Larry Epp, President

Licensed Clinical Professional Counselors of Maryland

PS – I have attached a letter with some language you can borrow for your email. Your email does not have to be long to be effective. Short, passionate statements can be effective.

[Please see the sample letter at the following URL and PLEASE modify it to be personal: ]

Letters Needed to Expand TRICARE Eligibility

The House and Senate will meet in conference shortly to work out differences to their versions of the National Defense Authorization Act.

We need language in The Special Rule adopted in H.R. 1735 would allow qualified mental health counselors who hold masters or doctoral degrees in counseling from institutions accredited by other than CACREP to receive TRICARE reimbursement for services provided to veterans and their families through 2027.

This language is not currently in the Senate version.

Letters sent to the following email address will distribute your letter to all the legislative directors serving the Congressmen and Senators involved in this process:

This is not a discussion list – it only exists for a short time in order to email the right Congressional senior staff.

Please consider using elements of the following modified letter which is written to a group rather than to individual members of Congress.

Letter to all legislative directors and their Senators and Congressmen

We strongly recommend that you modify this letter or write your own to include specific examples of how you have served military members, families, and veterans.  Personalize your story.

You are more than welcome to write individual members – please see our last post for the list of names and contacts, as well as an individual member letter format.


CACREP Update–Restricting the Practice of LCPCs

[Posted for Larry Epp — President of Licensed Clinical Professional Counselors of Maryland]

Dear Colleagues,

As President of the Licensed Clinical Professional Counselors of Maryland, I do not usually reach out to you on a professional issue unless it is very important. Some of you may have been following the developments with the accrediting agency, CACREP, whose supporters have been trying to restrict the practice of LCPCs who have not attended their accredited programs in the Commonwealth of Virginia.

Right now, supporters of this organization have instituted a campaign to close practice in Virginia to LCPCs from non-CACREP schools, counseling psychology, school psychology, clinical psychology, art/creative therapy master’s programs in seven years. While veteran LCPCs from Maryland can transfer their license to Virginia as the laws are currently constructed, the underlying concern is that the CACREP restriction will enter insurance regulations such as in Medicaid, Medicare, and private insurance plans, as has already occurred in Tricare, the Veterans Administration, and Department of Defense schools and programs.

Those who believe in the CACREP only standard have an ideological belief in separating psychology from counseling to create a pure and independent “mental health counseling profession.” Whatever the merits or pitfalls of their argument, the fact is that the changes they are promoting could potentially restrict the practice of many Maryland LCPCs in the future, especially if their thinking enters the recently introduced Medicare Bill on Capitol Hill or in the qualifications to practice in a Federally Qualified Behavioral Health Center under the Excellence in Mental Health Act. I do not have a crystal ball to know what will happen precisely, but this movement is certainly concerning and demands a response from those who favor the protection of existing practice rights and greater inclusivity in the future.

I urge you to weigh in on this important issue. I have attached the link below to the Virginia Board of Counseling’s website, who is for 30 days accepting comments on this issue. Virginia is a battle ground state, as it was one of the first to license professional counselors; and it is the headquarters for three national counseling associations. Thank you for considering my suggestion.


Here is the Virginia Board comment area that can be found online:

Virginia Protest Letter Help File and Background

Your assistance is needed to defeat proposed CACREP-only regulations for Virginia licensing.  The Virginia Board has posted a NOIRA (Notice of Intended Regulatory Action) for public comment, after which it will likely issue new CACREP-only license regulations.

The purpose of the proposed regulation states: To require graduation from a clinically-focused counselor preparation program accredited by CACREP or an approved affiliate of CACREP that includes a minimum of 60 semester credits (90 quarter hour credits) of curricular experiences and a practicum of at least 100 hours and an internship of at least 600 hours.  Allow a grandfathering of programs that meet current requirements for seven years from the effective date of the regulations.

Virginia is a particularly vulnerable state because it has far more than usual CACREP accredited programs. There are a few carrots being thrown to the non-CACREP counselors.  One is the 7 year grandfathering period.  After which the doors will be slammed on non-CACREP counselors in the state.  Another is that apparently Virginia does have some sort of process for accepting non-CACREP counselors licensed in other states wishing to move to Virginia.   These carrots are helpful, but really only soften the blow that CACREP is being forced as the superior standard and only standard.  One is also left to wonder at what point the regs allowing out-of-state transfers with non-CACREP backgrounds will be tightened?

Suggested Letter Text:

Please write your own letters, and feel free to cut and paste selections from the suggestions below into your letters.

“Counseling” vs. “Counseling Psychology”

The NOIRA states: “In recent years, the Board of Counseling has worked towards greater professional identity for counseling to help the public understand the clinical services a licensed professional counselor is qualified to provide… the Board continues to review applications for licensure from students whose educational programs are not clearly “counseling” in their identity. The lack of clarity in its regulations has been frustrating for the Board and very problematic for some applicants who have obtained a post-graduate degree that may or may not qualify them for a residency and ultimately licensure”

This innocent-sounding section of the NOIRA appears like it is about professional identity and qualification for licensure.  It would actually seem to be about the ongoing crusade of CACREP advocates to forcibly excommunicate graduates of “counseling psychology” masters programs in favor of “counseling” masters program graduates. One of the primary problems with CACREP is the inability of counseling psychology programs to obtain accreditation under CACREP. The differences, if any, between “counseling psychology” and “counseling” programs quickly fall apart upon examination.  The theories and techniques of “the talking cure” are the same regardless of label.  Most counseling psychology programs utilize the ACA ethics code in coursework (and the APA code is not that different).  There may perhaps be a greater reliance upon testing and medical model in some counseling psychology programs (some would applaud this).  CACREP advocates would like the American Psychological Association (APA) to rescue masters-level counseling psychology graduates (they only license at the Ph.D. level).  Counseling psychology graduates have been licensed as professional counselors and members of the ACA since the beginning.  This is in part a ridiculous petty squabble between Ph.D. level counselor educators versus Ph.D. psychologists dating back decades. Regardless – from the point of view of the public good – this has absolutely nothing to do with competence or public safety, but has great potential to impact the numbers of available counselors.  Booting “counseling psychology” graduates out of the licensing pool for Virginia in no way helps Virginia! (It’s doubtful that even professional identity is seriously different as counseling psychology graduates have always considered themselves professional counselors.)

Factual Corrections to the NOIRA (NOIRA original text in italics.)

“CACREP was established in 1981 to achieve some consistency in counseling educational programs.”

– True.  CACREP spent much of its early history accrediting school counseling (school psychology at one point) and has only accredited larger numbers of mental health counseling programs recently.  In fact CACREP is still in the process of converting even CACREP-accredited 48-credit Community Counseling programs to their newer 60-credit CMHC standard (see ).  The point being that when CACREP indirectly gives the impression that they are a very old and very established standard, this is not the case.

“CHEA recognition also assures the public that the programs that achieve CACREP accreditation are legitimate degree programs”

– The majority of non-CACREP programs in this country are also regionally accredited by CHEA and must maintain high quality standards.  This sentence implies that non-CACREP programs are usually not CHEA accredited and are illegitimate.

“One of the goals of CACREP is to establish a uniform set of educational requirements across the United States to facilitate portability of licensure from state to state.”

– True, but other methods of state-to-state portability would include an interstate agreement between the member Boards of AASCB, a simple choice to recognize out-of-state licensed counselors, or even CACREP-equivalent coursework and preparation.

“Three federal agencies have made graduation from a CACREP accredited program a requirement for independent practice in counseling.”

– This is not a reason to make the same mistake elsewhere.  Such requirements place a burden on counseling business owners and on clients who are looking for easy access to counselors in their communities.

“With a large military presence in Virginia, there is a need to equate graduation from a CACREP-accredited program with licensure to avoid public confusion and give licensees access to federal agencies.”

– This is exactly what should NOT happen for the good of both counselors and the public. Thousands of competent seasoned non-CACREP counselors throughout Virginia face increasing public confusion as to their competence.  A public which expects CACREP (despite no evidence of its superior quality) will start demanding CACREP and start discriminating against counselors without this accreditation in their past.  This will result in lack of employment for non-CACREP counselors even in situations where they are licensed and eligible to help with our burgeoning mental health community needs.  The likelihood of public confusion of CACREP with license eligibility and with competence is exactly why grandfathering provisions for non-CACREP counselors fall short of acceptable.

“The Board of Counseling has found that it has neither the resources nor the expertise to examine counseling programs across the country to assess the quality of the education in that program.”

– Plenty of Boards across the country do just this.  They typically require regional CHEA accreditation (for quality) and then require coursework in a variety or required categories.  Sometimes they choose to look for “CACREP-equivalency”.  When state Boards cede control of their standards to an outside entity they lose control over serving the needs of their state constituents.  Furthermore, several professions have two or more recognized accrediting authorities.  With variety comes a greater opportunity for a diversity of training to ensure a flexible and responsive (counseling) workforce for the unique needs of individual clients.  The Virginia Board might also avail itself of discussions amongst the various state Boards at the AASCB association – in which case it could at least have a strong voice in whatever national standards are enacted for standardization and license portability.

“Consistency and quality in educational preparation for professional counselors will provide greater assurance to clients seeking their services that they have been adequately prepared and appropriately licensed to protect public health and safety.”

– CACREP advocates have created a mostly false narrative of a public endangered by poor quality counselor preparation.  No doubt they can find isolated examples of such.  There is no epidemic of poor quality counselor preparation – controls and standards are already in place to protect the public without locking down the profession to one privately controlled gatekeeper.

Requested Public Participation in the NOIRA: The agency is seeking comments on this regulatory action, including but not limited to 1) ideas to be considered in the development of this proposal, 2) the costs and benefits of the alternatives stated in this background document or other alternatives and 3) potential impacts of the regulation. The agency is also seeking information on impacts on small businesses as defined in § 2.2-4007.1 of the Code of Virginia. Information may include 1) projected reporting, recordkeeping and other administrative costs, 2) the probable effect of the regulation on affected small businesses, and 3) the description of less intrusive or costly alternatives for achieving the purpose of the regulation.

Costs of the NOIRA proposal include the nearly $4500 in program application fees, and $2600+ annual maintenance fees charged to each CACREP accredited program (see ) which are paid for in some fashion by state school budgets, counseling students, and ultimately the public. Costs are also paid in terms of flexibility of curriculum in a field with MANY theories of psychology, loss of employment opportunities in CACREP programs for educators with slightly different qualified backgrounds than Ph.D.s in counselor education, and locking counseling psychology graduate students out of future licensure for no discernable reason related to competency to the public good. The future effects of CACREP on small businesses are murky and troubling. Many counselors in private practice are sole proprietors or at small clinics which would qualify as small businesses.  In the short-term under this proposal, these non-CACREP counselors will continue to be licensed and new graduates will be license-eligible until 2022.  However, the CACREP-only push creates a false perception of CACREP quality that is likely to impact these small businesses in the future.  The public may look for CACREP graduates in the false belief that they are more qualified.  Government programs (and private insurers?) may follow the bad TRICARE example and start requiring CACREP for licensure.  Employers may start only hiring CACREP graduates.  There is a potentially devastating longer term effect on small clinics and sole proprietors at risk of being cut out of the market. To the extent that non-CACREP counselors are cut out of the market, the public may experience counselor shortages or have to settle for newer counselors with less experience. Other Points: A careful look at the data will reveal that counselors who have graduated from CACREP programs are not more effective in their work with clients or in their service to their communities. A regulation limiting practice will not serve the people of Virginia well given that a majority of master’s level counselor training programs in the USA are not CACREP-accredited. A regulation limiting practice will not serve clients in Virginia given that the majority of currently practicing counselors graduated from schools free of CACREP accreditation. A restriction such as this would negatively impact current students and alumni from non-CACREP affiliated VA programs; negatively impact the public by reducing access to qualified counselors; negatively impact relocation of qualified and competent counselors from non-CACREP programs; reduce overall services available to VA residents; and increase cost of graduate education. Even the American Counseling Association (ACA), the largest national counseling association, opposes the CACREP-only restrictions highlighted in the rationale for this regulatory change. The people of Virginia need a strong Board that protects their rights to access quality mental health care.