TRICARE Position Statement

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


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 .


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.