Section 457.03 (1), Stats. states that the board shall “[u]pon the advice of the social worker section, marriage and family therapist section, and professional counselor section, promulgate rules establishing minimum standards for educational programs that must be completed for certification or licensure under this chapter and for supervised clinical training that must be completed for licensure as a clinical social worker, marriage and family therapist, or professional counselor under this chapter and approve educational programs and supervised clinical training programs in accordance with those standards.” Related statute or rule:
Section MPSW 14.
Plain language analysis:
This rule project removes automatic acceptance of all CACREP accredited programs as equivalent to a master’s or doctorate in professional counseling for the purposes of meeting the education requirement for licensure as a professional counselor. Instead, the board will provide automatic acceptance for certain enumerated CACREP accredited specialty programs. These include CACREP accredited programs in addiction counseling, clinical mental health counseling, clinical rehabilitation counseling, marriage, couple, and family Counseling, and doctoral programs in counselor education and supervision.
Applicants with degrees that are not CACREP accredited, or CACREP accredited but not in one of the enumerated specialties, must show that their degree program meets the requirements for equivalency within MPSW 14
Summary of, and comparison with, existing or proposed federal regulation:
None.
Summary of public comments received on statement of scope and a description of how and to what extent those comments and feedback were taken into account in drafting the proposed rule:
The Marriage and Family Therapy, Professional Counseling, and Social Work Examining Board held a preliminary hearing on the statement of scope for this rule at its January 28, 2020 meeting. The board received written comments from the following people:
Dr. Lisa M. Edwards, Dr. Alan Burkard, Dr. Weneaka D. Jones, Dr. Sarah Knox, and Dr. Lynne Knobloch-Fedders, all with the Department of Counselor Education and Counseling Psychology at Marquette University.
Dr. Jennifer M. Cook.
The Marriage and Family Therapy, Professional Counseling, and Social Work Examining Board summarizes the written comments received at the hearing as follows:
Dr. Lisa M. Edwards, Dr. Alan Burkard, Dr. Weneaka D. Jones, Dr. Sarah Knox, and Dr. Lynne Knobloch-Fedders, all with the Department of Counselor Education and Counseling Psychology at Marquette University, as well as Dr. Jennifer M. Cook all commented on the following:
They are opposed to entirely removing automatic acceptance for CACREP approved programs on the following grounds:o
CACREP approved courses are rigorously and continuously assessed to ensure they are creating nationally recognized standards that adequately prepare professional counseling professionals in a way that will enable them to provide counseling services in a way that is consistent with optimal human development in a diverse and dynamic society.o
Removing automatic acceptance entirely will create a burden for the board in that all applicant’s course history will need to be reviewed for compliance with the educational equivalency requirements in MPSW 14, and in a related vein, will increase wait times for licensure. o
CACREP approved courses generally do meet most of the requirements for educational equivalency in MPSW 14.
They suggest allowing applicants who have graduated from a CACREP program only be required to demonstrate proof that they have completed the additional educational requirements in MPSW 14 that go above and beyond what is required for CACREP accreditation.
Dr. Cook’s comments point out that CACREP and CORE have merged, and the body is now referred to only as CACREP. The Marriage and Family Therapy, Professional Counseling, and Social Work Examining Board explains modifications to its scope statement proposal prompted by public comments as follows:
The board did not opt to amend its scope statement in light of the public comments received, but did take the comments into consideration when drafting the rule.
Comparison with rules in adjacent states:
Illinois:
For the purposes of licensure as a clinical professional counselor, Illinois law recognizes any CACREP or CORE approved program or any doctorate in psychology approved by the American Psychological Association and the Council for the National Registry of Health Service Providers as approved programs (Ill. Admin Code § 1375.145 (c)).
Applicants who do not have a degree from a program approved by one of the above entities must demonstrate that their educational background meets the following requirements (Ill. Admin Code § 1375.145 (a)):
a) The educational requirements are as follows:
1) Master's degrees shall be from a college, university or school that is a regionally accredited institution of higher education and recognized by the U.S. Department of Education;
2) The programs, wherever they may be administratively housed, must be clearly identified and labeled as offering counseling, rehabilitation counseling or psychology programs. Such a program must specify in institutional catalogues and brochures its intent to educate and train counselors;
3) The program is an organizational entity within the institution;
4) The program has an integrated, organized sequence of study;
5) The program must be at least 2 academic years in length and require an individual to graduate from a program with a minimum of 48 semester hours or 72 quarter hours with a minimum of one course ("course" is defined as 3 semester hours or equivalent) in each of the areas listed in this subsection (a)(5). The 13 areas are the same as those listed for the licensed professional counselor. "A minimum of one course" is defined to mean that the objectives and content of a course need to meet the requirements for one content area and cannot be used to meet the objectives and content requirements of another content area. (See Appendix A (Course Descriptions) for a definition of the subject content for each core area with examples of course titles that relate to each of the core content areas.) Students who started their educational program after January 1, 1999 and graduated before January 1, 2008 who make application for the Licensed Clinical Professional Counselor after January 1, 2008 must meet the hour requirements for each core areas established by their educational program at the time they started their graduate studies. In some cases, this may not be 3 semester hours or equivalent for each core area. All students, however, graduating after January 1, 2008 must meet the "3 semester hour or equivalent" requirement.
A) Human Growth and Development
B) Counseling Theory
C) Counseling Techniques
D) Group Dynamics, Processing and Counseling
E) Appraisal of Individuals
F) Research and Evaluation
G) Professional, Legal and Ethical Responsibilities Relating to Professional Counseling, Including Illinois Law
H) Social and Cultural Foundations
I) Lifestyle and Career Development
J) Practicum/Internship
K) Psychopathology and Maladaptive Behavior
L) Substance Abuse
M) Family Dynamics;
6) The program has faculty responsible for the program and has a sufficient number of full-time instructors to make certain that the educational obligations to the student are fulfilled. The faculty must have degrees in their areas of teaching from professional colleges and institutions;
7) The program has an identifiable body of students who are matriculated in that program for a degree;
