1. CORE Response to 20/20 Frank Lane, Ph.D., CRC, LCPC Executive Director Tom Evenson, Ph.D., CRC President Patricia Nunez, M.S., CRC Vice President 10/17/2012

2. Introduction  History  Proposal  Introduction  IOM Recommendation  Parity  General Counselor Licensure Laws  2007 Merger Decision  Accreditation in other Professions

3. History  On March 22, 2012 in San Francisco, CA, the 20/20 educational requirements workgroup had submitted a proposal to all delegates that they adopt language for licensure portability that included CACREP-only language.  The 20/20 delegates recognized CORE and would not entertain the proposal, at that time.  The delegates voted to “endorse the concept of a single educational accreditation body” because they believe it is a clear benefit to the counseling profession.  The Council on Rehabilitation Education (CORE) submitted a proposal to the 20/20 delegates to offer an innovative model for a structure that can facilitate 20/20’s collective efforts to effectively unify the profession.  This proposal was proposed by the CORE Board at its annual meeting in July 2012.

4. 20/20  Born in 2005, due to concern about lack of unity within the counseling profession leading to multiple variations in state licensing titles and regulations, hampering development and implementation of AASCB portability plan.  Co Sponsored by ACA and AASCB  Consensus model  Principles for Unifying and Strengthening the Profession approved by 97% of participating organizations

5. Principles for Unifying and Strengthening the Profession  Sharing a common professional identity is critical for counselors  Presenting ourselves as a unified profession has multiple benefits  Working together to improve the public perception of counseling and to advocate for professional issues will strengthen the profession.  Creating a portability system for licensure will benefit counselors and strengthen the counseling profession.  Expanding and promoting our research base is essential to the efficacy of professional counselors and to the public perception of the profession.  Focusing on students and prospective students is necessary to ensure the ongoing health of the counseling profession.  Promoting client welfare and advocating for the populations we serve is a primary focus of the counseling profession.

6. Proposal  The CORE Board proposes a consortium model for counseling accreditation and unification as the organizational paradigm consistent with the 20/20 delegation’s 3/22/12 endorsement.  CORE views a consortium model as an association of two or more accreditation organizations with the objective of participating in accreditation activities and coordinating each organization’s resources to achieve the goal of licensure portability.  CORE’s proposal directly supports the vision for generic counseling and the counseling specializations.  The principles of unification, through this consortium model, will strengthen the counseling profession and advances 20/20’s principles.  A consortium model also equalizes power differentials so that those involved in a relationship each has its voice heard and is not dominated by one of the members within that relationship.

7. Proposal  A consortium of accreditation bodies will support the principles of the 20/20 delegates in that it would:  present us as having a common professional identity (Principle #1);  demonstrate our diverse and unified profession (Principle #2);  work together to improve the public perception of counseling (Principle #3);  create a portability system that will benefit counselors (Principle #4) because it will ensure that all counselors graduating from an accredited program can get licensed in all 50 states, the US Territories and Commonwealths;  focus on students and prospective students (Principle #6); and  promote client welfare and advocate for the populations by ensuring that qualified, trained counselors serve all individuals, from all backgrounds, sexual orientation, cultures and abilities (Principle #7).

8. IOM Recommendation  CACREP has been recognized in federal legislation over the past three years for mental health counseling and substance abuse counseling much like rehabilitation counseling has been recognized in legislation specific to its specialty for nearly 40 years.  CORE believes that the matter of recognition for practice within a specific system (under TRICARE, for example) and portability of counselor licensure are two very separate issues.  Rehabilitation counselors have long been recognized by the Veterans Administration (VA) for vocational rehabilitation counseling services to veterans with service-connected disabilities.  TRICARE and the VA are now recognizing mental health counselors. These and similar decisions in the rehabilitation counseling and mental health specialties are supplemental to licensure. They further evaluate the qualifications of licensed counselors for practice in specific job classifications within the professional counseling occupation, much like board certifications in the medical profession.  Certification as a Clinical Mental Health Counselor (CMHC), similar to the Certified Rehabilitation Counselor (CRC) certification, designates a credentialed professional for practice in a specific specialization.

9. Parity Resolution  Original parity motion- 1999  Parity reaffirmation resolution- 2003  Original documents can be viewed at www.arcaweb.org and go to the “Counselor Parity” tab www.arcaweb.org

10. Parity Reaffirmation  ACA reaffirms that preparation of students educated by both CORE and CACREP accredited programs is functionally equivalent for purposes of licensure and further, that NCC’s and CRC’s have met equally rigorous standards of education and experience in achieving these credentials. Further, it is the policy of ACA that the alternate equivalency of CORE and CRCC to their counseling credentialing counterparts be given full and proper consideration and voice in all credentialing, professionalization and advocacy actions and policy communications taken by ACA. This position is especially relevant within the context of ACA’s positions of statutory and regulatory licensure issues such as recommended examinations, and educational requirements involved in core course evaluations, as well as counselor licensure portability models and policies unanimously passed March 2003 – ACA Governing Council

11. Parity  The ACA parity resolution has prompted some to ask “How can the ACA Governing Council establish parity when the IOM recommended CACREP accreditation over CORE for mental health counseling?”  The recommendation by the Institute of Medicine (IOM) to recognize the CACREP standards for mental health counselors (a specialty practice in the generic field of counseling) will shape the criteria by which a mental health counselor may practice.  Rehabilitation counseling (a specialty practice) went through a similar process in the early 1970s when its credentialing bodies began to further define rehabilitation counseling practice. It would have been inappropriate for CORE to point to the US Department of Education’s Rehabilitation Services Administration recognition of CORE accredited programs as evidence of superiority when advocating for inclusion in counselor licensure laws. That misses the point and causes disparity in the power equation.  The same is true of the IOM recommendation to use CACREP mental health standards for a specialty counselor. Parity Resolution  IOM’s recommendation to use CACREP’s mental health counseling standards is specific to only one specialty area in counseling, not all specialty areas. Thus, the recommendation to use CACREP’s standards in this single area should not be blurred with the federal government’s endorsement of CACREP’s standards across all areas of counseling. This is not reality. Mental health, rehabilitation, school, career, marriage and family, and transition specializations share a common counselor identity. Parity refers to the core educational competencies that all counselors share. The chart below compares the CACREP eight knowledge areas considered to be the foundation for professional counselors. You will notice that the knowledge areas correspond, almost word for word, with CORE standards. The two knowledge areas under CORE focus on the specialty of rehabilitation counseling. Therefore, all counselor specializations should be included in generic counselor licensure. Any proposal for portability of counselor licensure must be on the common thread – general counselor licensure.

12. General Counselor Licensure Laws  An analysis of general counselor licensure laws in all 50 states, DC and Puerto Rico reveals the following:  The Council on Rehabilitation Education (CORE) is currently mentioned in the licensing laws of 14 states.  CACREP is mentioned in the laws of 27 states.  These statistics alone do not reflect the path by which graduates of counseling programs become licensed.  In looking at the 27 states that mention CACREP, it is important to note that this includes the 14 states that also mention CORE. The remaining 13 state laws that mention CACREP also include specific language that provides alternative routes to meet educational requirements such as recognition of regionally accredited institutions, degree titles, minimum degree hours and course content areas.  The remaining 25 states, the District of Columbia and the Commonwealth of Puerto Rico do not specifically mention an accreditation body by name but rather focus on the articulation of minimum educational standards.  Graduates of CORE accredited rehabilitation counseling programs currently have pathways that lead to the possibility of licensure in most of the states and territories.

13. 2007 Merger Decision  CORE’s Board decided not to vote on the merger solution in 2007 based on two reasons that still exist today.  First, the requirements that CACREP accredited programs must hire only graduates of CACREP accredited doctoral programs prevent the candidacy of many of the graduates of CORE programs.  This marginalizes a specialty area of counseling that draws from a variety of disciplines (e.g., occupational therapy, psychology, disability studies) to serve the diverse needs of people with disabilities.  We used Beatrice Wright as an example of a faculty member who would not meet the requirements set forth by CACREP and it is hard to imgaine rehabilitation counseling without her unique contributions  While CORE was informed that CACREP would consider an extended grandparenting period for CORE programs as potentially “reasonable,” the grandparenting period would eventually end. From the Board’s perspective, grandparenting merely prolongs the inevitable reality.

14. 2007 Merger Decision  The second point concerned the faculty size requirement of the programs.  Currently, CORE accredits 26 programs with two or fewer faculty members. They would be ineligible for accreditation under the CORE-CACREP merger.  While these two points may seem small to some, they result in a significant impact to the culture of rehabilitation counseling.  One might say “just have your doctoral programs pursue CACREP accreditation.” While this sounds simple, it is more difficult to accomplish in practice without having a negative impact on the rehabilitation counseling culture.  The rehabilitation counseling program at University of Wisconsin at Madison, for example, is titled rehabilitation psychology. According to CACREP Accreditation Process Policy #4 “Titles may not be used that have the potential of misrepresentation with regard to CACREP accreditation. Therefore, when an institution decides to seek CACREP accreditation for one or more graduate degree programs), the institution must use titles that:  1) clearly identify the programs and degrees as counseling programs and counseling degrees, and  2) accurately reflect the CACREP program area under which accreditation is being sought.” (CACREP Policy Document, February 2009, revised February 2012, page 3).  CORE believes the potential loss of the program under an alternate accreditation model impacts the quality of the educators in rehabilitation counseling programs.

15. Accreditation in other Professions  More than one accrediting body for a major profession is not unique.  At least four other professions have more than one accreditation body.  Audiology programs are accredited by the Accreditation Commission for Audiology Education (ACAE) and the American Speech-Language-Hearing Association’s Council on Academic Accreditation (ASHA-CAA.).  Nursing programs are accredited by the National League for Nursing Accrediting Commission (NLNAC) and the American Association of Colleges of Nursing, Commission on Nursing Education (CCNE). T  Teacher education programs are accredited by the National Council for Accreditation of Teacher Education (NCATE) and the Teacher Education Accreditation Council (TEAC), although these two groups are in the process of merging.  Business programs are accredited by three organizations, the Association to Advance Collegiate Schools of Business (AACSB), the American Council for Business Schools and Programs (ACBSP), and the International Assembly for Collegiate Business Education (IACBE).  The Council Higher Education Accreditation (CHEA) recognizes all but one of the accrediting organizations above, CCNE, which means that CHEA recognizes multiple accrediting organizations in the business, teaching, and audiology professions included in this example.

16. Accreditation in other Professions  Multiple accrediting bodies within a profession does not necessarily equate to a lack of a singular professional identity.  In conversations with staff from the organizations that accredit programs for nursing, teaching, and audiology.  CORE discovered that each organization is responsible for marketing the accreditation to state licensing boards.  Licensing boards are not resistant to the concept and the professional associations do not become involved in recognizing one accreditation over another.

17. 20/20 Educational Requirements  Among the 20/20 delegates, the workgroup on educational standards is comprised of ten members and chaired by the President and CEO of CACREP, Carol Bobby.  The workgroup has utilized the Delphi method to arrive at a consensus on the educational standards to recommend adoption to 20/20 delegates. The Delphi method is a powerful tool but, like all methodologies, it has strengths and limitations.  The Delphi method is well suited to build consensus around a topic by utilizing a series of questionnaires designed to collect data from a panel of experts. There are, however, potential limitations, which include unintentionally guiding feedback from the expert panel. Additional criticism of the Delphi method is that there is a normative influence on the consensus decision by the group rather than an informational one, which is what is intended by the method.  Put simply, six out of the seven accreditations for specializations within the counseling profession are sponsored by CACREP. These include addictions, career, clinical mental health, marriage couple and family, school, student affairs, and college counseling. Only one representative of this workgroup that we are aware of has a good working knowledge of CORE accreditation. The workgroup’s consensus and initial recommendation for CACREP accreditation as the model for licensure can be explained by public compliance, lack of relevant information and lack of understanding of CORE accreditation.  CORE is concerned that the consensus of the 20/20 workgroup on educational standards may be unintentionally but inappropriately influenced by the fact that CACREP accreditation is the norm but not representative of the entire profession.

18. Summary  We ask that the 20/20 delegates not confuse recognition of CACREP’s standards for mental health counseling by the IOM and other federal agencies as anything more than the credentialing of practitioners for this counseling specialization.  We ask the 20/20 delegates to consider a consortium model of accreditation bodies that support the principles of the 20/20 workgroup.  We ask the 20/20 delegates to recognize that two or more accreditation bodies for a major profession is not unique. At least four other professions have more than one accreditation body.  We ask the 20/20 delegates to recognize that the Council on Higher Education Accreditation (CHEA) recognizes CORE and that CHEA standards require the accreditation organization to make independent decisions without undue influence from outside organizations.  We ask the 20/20 delegates to consider the limitations of the Delphi process, and that the educational requirements workgroup recommendations may be unintentionally, but inappropriately, influenced by the fact that the CACREP accreditation may become the de facto norm skewing the group’s results.