Document Library

Below are some important documents that we feel shine light upon the CACREP situation.


Final Rule from Federal Register for TRICARE Certified Mental Health Counselors

This is the final rule on provisions for professional counselors to be paneled with TRICARE.  At preliminary glance, this looks like a win!  It appears that CACREP unaffiliated counselors will be able to continue to practice indefinitely under supervision, and that the time period for certifying for independent practice with TRICARE has been extended through January 1 2017.


TRICARE Position Paper

Position paper from the Coalition of Concerned Counselors on alternative paths to eligibility for TRICARE.


Why is TRICARE Dropping Mental Health Counselors: Twenty-Two Veterans Commit Suicide Each Day

Advanced draft of an article hopefully awaiting publication in Counseling Today.  After citing the grim suicide statistics amongst veterans and the need for expanding services, this article discusses the decision of DoD to instead restrict available service providers to the CACREP-only subset of counselors, despite the high quality of providers graduating from institutions such as Hopkins, Columbia, Seton Hall, and George Mason.  This baffling decision goes beyond the IOM Study recommendations.  Speculation as to why such a restrictive decision could occur suggests graduate school competitive advantages and military costs savings as possible motives.  This paper was co-authored by the Officers of The Licensed Clinical Professional Counselors of Maryland, the New Jersey Counseling Coalition, and the Massachusetts Mental Health Counselors Association.


Maryland Congressional Delegation Letter to Assistant Secretary of Defense for Health Affairs Woodson

Letter from the entire Maryland Senate and House delegation to the assistant secretary outlining the problems with the current proposed TRICARE regulations for whom can counsel veterans and their families.  As outlined, these include the removal of the majority of Maryland-trained clinicians and counseling psychology programs, and the impact to the mental health of service men and women.  In issuing this letter, the Maryland delegation is weighing in support of the opinions of the University of Maryland Board of Provosts.


Summary of Key Points from February 21st 2014 Meeting at ACA Headquarters

This paper summarizes the results from the 2/21/14 meeting including what ACA would consider.


ACES’ Position on Educational Standards for Licensure

This ACA Division, composed of Counselor Educators, seems to be arguing for a position that would not try to vigorously protect or advocate for currently licensed counselors, who did not graduate from CACREP schools. It sounds as though they see some harm to members of our profession as inevitable in the interest of collective professional development.  The president of ACES, interspersed with comments about hope for grandfathering and long lead times on change implementations, states:

Moving toward a unified standard and licensure portability would represent major growth for the profession.  We also recognize that growth often involves loss, and this process may create challenges for individuals and programs as we try to move forward. (Bold added for emphasis)

Yes, it sound like ACE leadership is willing to sacrifice you.


Solutions to Concerns over Growing CACREP Restrictions on Practice and Higher Education
This is the solutions position paper that LCPCM presented on 2/21/14 to senior ACA staff at ACA Headquarters.


Counselor Identity & Accreditation: Inclusion and Right to Work

Jill Ritchie LMHC remarks to the American Association of State Counseling Boards 27th Annual Conference.  Some of the more interesting topics from this discussion are:

  • How CACREP does not represent the full range of competent training programs in the country and should not be the sole pathway to counselor legitimacy.
  • Other voices and paths to accreditation that need to be part of a broader national certification discussion (such as Masters in Counseling Accreditation Committee (MCAC) among others).
  • The value of the multidisciplinary training approach
  • How CACREP is a regional phenomenon.  Of 254 CACREP accredited programs in clinical mental health, mental health, and community counseling; only 8 are in New England, 44 in the North Atlantic region, 16 in the Rocky Mountain states, and 17 in the Western states. The majority of the CACREP approved programs (67%) are in the North Central states (with 71), and the Southern states (with 102). A similar pattern prevails for counselor education doctoral programs.  CACREP is a regional phenomenon.  (How CACREP graduation can be applied as a national standard is a thorny problem.)


Letter from Assistant Secretary of Defense for Health Affairs Woodson to Senator Sarbanes

This letter shows several factual misunderstandings and misconceptions that need to be overcome.   For one it implies a fair transition period in which CACREP-unaffiliated counselors can take an exam in order to remain eligible for TRICARE.  While technically true, few counselors are able to take advantage of this as NBCC has restricted the ability to take the test to counselors who satisfy many of the standards of CACREP anyway.  It also implies that IOM designated CACREP as the national standard — IOM only recommended that there be a national standard.  Finally, it does not adequately address why CACREP should be a standard of TRICARE participation in the first place.


Letter from USM Provosts to Maryland Congressional Delegation

The University System of Maryland Provosts of Maryland argue against the TRICARE regulations and suggest more inclusive language.  They highlight the point that CACREP arbitrarily cuts out “psychology” programs from CACREP consideration in favor of “counseling” programs — despite equal high standards in counseling psychology programs (whose graduates typically license as counselors).

Summer 2013

Letter to Counseling Today

Unknown to many counselors, CACREP-only language in state and federal regulations would restrict counseling services to large segments of society.  Many counselors are unaware that training programs have declined to pursue CACREP accreditation for prohibitive cost reasons and because of restrictions on professors allowed to teach in graduate training programs.  CACREP is encouraged to embrace a national credentialing model that includes the diversity of viewpoints and training backgrounds enriching our profession.  This letter was authored by the Boards of the Licensed Clinical Professional Counselors of Maryland and the Massachusetts Mental Health Counselors Associations.


CACREP and AMHCA Letter Pressuring College Deans and Showing Likely Intent

This is a letter from CACREP and AMHCA pressuring college deans to adopt the CACREP standard.  They use the threat of TRICARE exclusion of program graduates to make their case (despite recent video claims that they did not lobby TRICARE for CACREP-only standards).  They go further to speculate that:

  • CACREP-only standards will make it into MEDICARE legislation when counselors are finally allowed to participate in that program,
  • It is “only a matter of time before professional counselor licensure boards begin requiring graduation from a CACREP-accredited program”,
  • It is important to work with licensing boards to push CACREP-only standards.

Many CACREP-unaffiliated counselors will be very surprised to learn that AMHCA is directly lobbying graduate programs against their best interests, and anticipating the day when they will be unable to serve the beneficiaries of federal insurance programs or even obtain licenses.


ACA Comments on TRICARE Qualification Criteria Sent to Assistant Secretary Woodson

This document is incredibly interesting because ACA came to the same conclusions as Concerned Counselors in their analysis of how CACREP would adversely  impact the ability of licensed counselors to grandfather into TRICARE.


CACREP Letter in Support of TRICARE CACREP-Only Restrictions

This misleading letter by the CACREP President and Board Chair is clearly in support of DoD adopting CACREP program graduation and NCMHCE exam requirements for TRICARE participation.  It implies that CACREP-only restrictions are a matter of quality, despite little to no evidence indicating this.  It claims an overly wide pool of participating programs (601 counseling programs) — conveniently obscuring the fact that many of these are school counseling programs and so are not relevant to the discussion.  (Our research shows there are only 120 CACREP approved clinical mental health counseling programs.)  The IOM Study recommended that CACREP-unaffiliated counselors continue to be able to accept TRICARE under supervision, not that they be eliminated entirely.  When talking about CACREP standards (such as a minimum of 60 semester credit hours) they leave out the fact that many state board licensure standards equal or exceed CACREP standards (such as Maryland for example).  CACREP only language has NOT been adopted by the American Counseling Association (ACA) — ACA officially supports all counselors.