VIRGINIA ASSOCIATION OF CLINICAL COUNSELORS

P.O. BOX 7066

VIRGINIA BEACH, VA 23457

Serving the needs of Virginia clinical counselors since 1980

August 7, 2010

Evelyn B. Brown, Executive Director

Virginia Board of Counseling

Perimeter Center
9960 Mayland Drive, Suite 300
Henrico, Virginia 23233-1463

Dear Ms. Brown:

The Virginia Association of Clinical Counselors requests a rule change, such that application fees and license fees be separated for those clinicians licensed in another state and applying for licensure by endorsement.  A member forwarded to us her Petition for Rule-making, which we as practitioners find to be quite reasonable.  She makes the point that many other states separate the two fees, and raises the specific argument that one may not be able to complete additional licensure requirements within a specific time range, thus forfeiting the licensure fee.  In our opinion, it makes sense to separate the two fees.  In closing, we would request that the Board of Counseling address this issue at its next meeting.

Sincerely,

Michael E. Nahl, LPC, LMFT

Chair, Advocacy Committee