Category Archives: TRICARE

The Trouble With the CACREP-Only Counselor Movement

A lot of people are wondering what the fuss is about professional counseling moving to CACREP accreditation standards, especially since organizations like the ACA, AMHCA, ACES, and NBCC are promoting this move.

Therein lies the first problem: COMPLEXITY (and acronyms)

A whole post could be written about just the players and organizations involved. (CACREP = Council for Accreditation of Counseling and Related Educational Programs, ACA = American Counseling Association, AMHCA = mental health counseling division of ACA, ACES = counselor education division of ACA, NBCC = National Board of Certified Counselors which handles national testing and increasingly looks like an ACA rival). Then we could badly use a dictionary of terms… then a history lesson… then a paper on each of the problems outlined below…

Busy counselors don’t want to sort through this complexity.

 

The second problem: BOREDOM (and perceived irrelevance)

The CACREP accreditation issue is usually described as a new standard for graduate schools to adhere to. Yawn. If you graduated 10 years ago and work seeing clients, an academic discussion on standards puts you to sleep. Nowhere in the usual discussions of this issue is there a suggestion that your FUTURE CAREER may be affected.

 

The third problem: ASSURANCES

If you have listened at all to the ACA and other advocates, you have been told that this won’t effect those currently licensed, that ACA will advocate for your equality, and that its all for “great reasons” (see below). Official associations keep on speaking ever so carefully so as to not quite lie, while giving the impression all is well.

 

So, in a nutshell (or as short as we can make it), what are the fastest descriptions possible of the problems with a CACREP-Only approach?

CACREP-ONLY: There are other styles of training and other emerging standards. Few people are rallying against the CACREP accreditation standard itself as an optional accreditation. It’s the implications of only having CACREP that is the problem.

FUTURE EMPLOYMENT: Graduation from a CACREP-accredited program in the past increasingly makes a difference in your ability to get a future job. TRICARE and the VA both prefer or require CACREP degrees. CACREP-Only partisans are working very hard to get CACREP mentioned in any Medicare regulations passed to allow professional counselors to accept Medicare. The fewer panels are willing to accept you, the harder it will be to make a living or get hired by employers. (This is why being able to keep your license is not enough. CACREP graduation or CACREP-influenced certifications may also be required.)

MEDICARE – THE GATEWAY: Private insurance companies often set their policies by what Medicare does. This is why we are so worried about CACREP-Only language getting into Medicare.

REPUTATION: The ACA’s official policy is now to lobby all 50 state Boards for CACREP-Only licensure. ACA goes to pains to say they will support the equality of currently licensed non-CACREP counselors. We hope so. How does one get a message of equality out to government, health plans, and the general public in the middle of persuading state Boards that CACREP is the “gold standard” that must be switched to? A DoD official was interviewed last year to discuss TRICARE’s two-tier policy in which certain (mostly CACREP) counselors are allowed independent practice, whereas non-CACREP counselors (otherwise independently licensed) are judged in need of doctor supervision. This kind of messaging will work its way into the public mind.

LOSS OF DIVERSITY: The problem with too rigid a standard is that you can lose some diversity. There are hundreds or thousands of approaches to counseling. Some arguments have been made that special communities (American Natives, disabled counselors-in-training) may be better served by alternatives.

BASIC FAIRNESS, “COUNSELING PSYCHOLOGISTS” AND VENGENCE VENDETTAS: CACREP-Only partisans are dead-set on excluding future students with master’s degrees in counseling psychology from obtaining professional counselor licenses (after a grandfathering period for current students). These programs have been with counseling since its inception. CACREP won’t even accredit these programs unless they make arbitrary changes requiring absurd expense and turn-over of core staff – its closer to truth to just say that CACREP won’t accredit them (see that part about not quite lying in assurances section above). There is a constant campaign to conflate and confuse in the public mind professional counselors holding master’s degrees in counseling psychology (who identify as professional counselors) with Ph.D. psychologists who have psychologist licenses. The two are not the same. More than a few commentators have opined that at one level the intractability of this dispute is about vengeance. The Ph.D. counselor educators are not allowed to teach in Ph.D. psychology programs. They are trying to push Ph.D. counseling psychologists out of their traditional role in teaching master’s level professional counselors (at “counseling psychology” masters programs). This is in part a war between two feuding groups of professors.

CONSOLIDATION OF CONTROL AND MONEY: At another level this may also be about money and control. The ACA helped create CACREP a long time ago, and now does not have official control over standards. CACREP partisans are also persuading state licensing boards to give-up control of their standards to this outside entity. CACREP charges a lot of money to programs wishing to obtain and maintain accreditation. NBCC controls at least two key gateways to the professional counseling career: national exams and national certifications. Currently no one is fighting over their control of the NCE and NCMHCE exams (unless they restrict taking them to only CACREP students…). They also control the NCC (National Certified Counselor) and CCMHC (Certified Clinical Mental Health Counselor) certifications. These certifications are currently of questionable value, but NBCC is working hard to get these certifications required for licensure portability between states, as a stepping stone to independent TRICARE provider status, and more (See Portability below). It costs MONEY and lots of it to maintain certifications in addition to your state license.

PORTABILITY: There are currently conflicting proposed plans from NBCC/AMHCA/ACES and from AASCB (American Association of State Counseling Boards) for licensure portability when counselors move between states. The NBCC/AMHCA/ACES plan requires CACREP graduation to move between states unless a stubborn state board goes its own way or unless current non-CACREP counselors obtain and hold the NCC certification before 2022 (at which point CACREP graduation is required for the NCC). This is one example where NBCC can make millions of dollars from non-CACREP counselors by requiring them to grab an NCC certification while they can if they ever wish to work in another state in the future.

“GREAT REASONS” FOR THE “GOLD STANDARD”: Here are the most prominently mentioned reasons for moving to CACREP-Only:

So far here is what we’ve gleaned from CACREP-Only partisans as to reasons for CACREP-Only:

  1. Obligation to our forefathers. One CACREP-Only inclined historian states “We have an obligation to all of our forefathers/mothers and mentors to be good/honest stewards of the history of Professional Counseling. Please see that we pass on our family’s story.” (This sort of invites you to join a shared destiny and unity in which it is glorious to kick dozens of excellent graduate schools out of existence, destroy professional diversity, and cede immense power and money to organizations like CACREP and NBCC that are far less accountable to members than the ACA with its elections system.)
  2. Only immersion in a CACREP program can impart the correct spirit of shared IDENTITY and UNITY. (No training after-the-fact short of redoing graduate school will give this mystic feeling and purpose. We’ve never managed to get a definition of what this IDENTITY is, other than being told to read the 20/20 vision statement again (hint: nope, that does not solve it). UNITY if you are them we suppose.)
  3. Quality (Which, when challenged, results in vague mutterings about testing and program inspection standards… then reference to really flawed studies about NBCC tests being passed at higher percentage by CACREP students.)
  4. Counseling psychology master’s programs have more reliance on testing and the medical model. (If true, is that a problem?)
  5. Control of the standards of our own profession. (Because master’s in counseling psychology are somehow not our own profession…?)
  6. The government demands one standard. (It’s murky as to whether or not perhaps the government was first advised as to what standard it ought to ask for… Also – the “one standard” could so easily have been two (nursing has a few accreditation bodies) or have been a national certification allowing counselors from several backgrounds to attain the certification after demonstrating competence.)
  7. The IOM Study recommendations (Which some of us have described at some length as flawed.)

This letter is envisioned as something of a 101 primer. Problem is, this is such a complex topic that it will surely need revision and expansion almost as soon as its published. Consider this a draft.

 

WHAT CAN YOU DO?

At the immediate moment – BE LOUD. Participate in this Linked-In Group, on the Concerned Counselors listserv (see www.concernedcounselors.org), on ACA Connect Open Forum, and on CESNET. Plans will shortly be announced for a new national association dedicated to fighting the CACREP-Only injustice.

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.”

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.

tricarecounseling@concernedcounselors.org

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: http://www.concernedcounselors.org/wp-content/uploads/2015/06/LCPC-letter-to-Congress-6-19-151.docx ]

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:

tricarecounseling@concernedcounselors.org

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.

Thanks

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 http://www.cacrep.org/for-programs/ ).  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 http://www.cacrep.org/for-programs/cacrep-accreditation-fees/ ) 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.

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

Final Rule Published for the TRICARE Certified Mental Health Counselors Designation

The final rule for the TRICARE Certified Mental Health Counselors designation came out in the Federal Register this morning:

PDF HERE:

We have the .pdf of the Rule available on our website here.

FEDERAL REGISTER LINK:

https://www.federalregister.gov/articles/2014/07/17/2014-16702/tricare-certified-mental-health-counselors?utm_campaign=email+a+friend&utm_medium=email&utm_source=federalregister.gov

We need to analyze this carefully.  In the meantime it looks like providers without CACREP certification can still practice as before, under the supervision of a physician, and the timeframe to meet their certified criteria is extended another two years.

This is a strong win!  We’ll take a look and see what next steps are.

SUMMARY FROM FEDERAL REGISTRY:

The Department of Defense is publishing this final rule to implement the TRICARE Certified Mental Health Counselor (TCMHC) provider type as a qualified mental health provider authorized to independently diagnose and treat TRICARE beneficiaries and receive reimbursement for services. Additionally, we are extending the time frame that was mentioned in the Interim Final Rule for meeting certain education, examination, and supervised clinical practice criteria to be considered for authorization as a TCMHC. The time frame has been changed from prior to January 1, 2015, to prior to January 1, 2017. One final set of criteria shall apply for the authorization of the TCMHC beginning January 1, 2017. The supervised mental health counselor (SMHC) provider type, while previously proposed to be terminated under TRICARE, is now continued indefinitely as an extramedical individual provider practicing mental health counseling under the supervision of a TRICARE authorized physician.

DATES:

Effective Date: This rule is effective August 18, 2014.

Counseling Students Who Will Never Get to Help TRICARE Clients

Another piece of great reporting by Crystal Price at KFOX in El Paso, TX.  She interviews an intern/student therapist about how — after all her work — she is never going to be able to help military children on TRICARE if the new regulations stand.  Ms. Price also interviews a school official for his comments.

Transcript available at: http://ow.ly/zd3WY

The CACREP Party line about current licensed counselors being able to grandfather into TRICARE if they take an exam is repeated in this story.  While that is true, its also the case that counselors must have received all of their supervision from a counselor or counselor educator (not a psychologist, a social worker, or other licensed mental health professional).  Most older counselors came up through school when supervisors from other professions were needed due to few fully trained counselors.  This renders the “grandfathering” options of TRICARE about useless for many of us.

This news segment does utilize a much more likely statistic for how many CACREP-trained counselors there actually are in this country.  Ms. Price AVOIDS using the following frankly embarrassing nugget that we are told is currently being passed around by CACREP in response to inquiries:

CACREP, which was formed in 1981, accredits the majority of post-graduate counseling programs in the country – over 650 graduate counseling programs at more than 290 institutions.  A random sample of licensed and non-licensed counselors used in the 2010 National Counseling Examination (NCE) job analysis study showed that 71% of counselors are CACREP graduates.  Of the remaining participants, 17% indicated that they graduated from a non-CACREP program and 12% reported to have earned their degree before CACREP was formed in 1981.

This quote is just so wrong in so many ways, most of them discussed here.

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.

~~~~~

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.

 ###

Congressman Beto O’Rourke: Impact “Could Not Be More Grave” of TRICARE Rules on Military Mental Health

Yet another strong article out of the El Paso Inc. newspaper.  This is starting to get interesting.

O’Rourke: Impact ‘could not be more grave’: Proposed changes to military benefits could reduce care

Representative O’Rourke is on the Veterans Affairs and Homeland Security committees, so he may be in a position to do something.

The article also mentions the part of the IOM recommendations that so frequently does not get mentioned by CACREP-only advocates — the part where IOM recommended that CACREP unaffiliated counselors be allowed to continue practicing in TRICARE in order to “maintain the continuity of care” and that TRICARE should continue supervising CACREP unaffiliated counselors “using a scheme that provides for successively greater levels of independent practice.”

This would be a very good time to start writing Congressional delegations to put greater pressure on TRICARE to amend the rules and to support Rep. Beto O’Rourke.