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;
8) The program has a one year residence. Residence requires interaction with faculty and other matriculated students. One year's residence is defined as 24 semester hours taken on a full-time or part-time basis at the institution accumulated within the time frame and course of study of the program.
Iowa: Licensure as a mental health counselor in Iowa requires a degree from a CACREP accredited 60 credit (45 credits if the student graduated prior ot June of 2012) master’s or doctoral program with an emphasis in mental health counseling. Alternatively, an applicant may meet the educational requirement for licensure if their master’s or doctorate program transcript demonstrates educational equivalency to CACREP accreditation in mental health counseling. The equivalency determination is made by the Center for Credentialing and Education (CCE) at the applicant’s expense based on submission and review of the applicant’s transcript (IA Admin Code § 645.31.6). The full list of considerations made by the CCE can be found in IA Admin Code § 645.31.6, and very closely mirror the requirements for CACREP accreditation.
Michigan: Applicants for a counselor license must have degree from either a master’s or doctorate program in counseling or student personnel matters that is approved by the board (Mich. Admin Code § R 338.1752 (2)). Programs that are accredited by CACREP are automatically considered to be acceptable to the board. If the graduate program is not CACREP accredited, the applicant’s degree program must consist of a 600 hour supervised clinical internship and at least 48 semester or 75 quarter credit hours including all of the following counseling related topics:
1) Career development.
2) Consulting.
3) Counseling techniques.
4) Counseling theories.
5) Counseling philosophy.
6) Group techniques.
7) Professional ethics.
8) Research methodology.
9) Multicultural counseling.
10) Testing procedures and assessment.
11) Practicum.
(Mich. Admin. Code § R 338.1752a).
Minnesota: Minnesota law requires applicants to have either a master’s or doctorate in counseling or a related field, including at least 700 hours of supervised counseling experience. The course shall involve a minimum of 48 semester or 75 quarter credit hours and include all of the following topics:
1) The helping relationship, including counseling theory and practice;
2) Human growth and development;
3) Lifestyle and career development;
4) Group dynamics, processes, counseling, and consulting;
5) Assessment and appraisal;
6) Social and cultural foundations, including multicultural issues;
7) Principles of etiology, treatment planning, and prevention of mental and emotional disorders and dysfunctional behavior;
8) Family counseling and therapy;
9) Research and evaluation; and
10) Professional counseling orientation and ethics.
(Minn. Stats. § 148B.53).
Summary of factual data and analytical methodologies:
The board is concerned that some academic programs accredited by CACREP do not meet the requirements of the board for equivalency to a master’s in professional counseling in MPSW 14. The board would instead like to take a nuanced approach to the matter, allowing automatic approval of some CACREP accredited programs, while requiring graduates of other CACREP accredited programs that are not enumerated by rule to show that they have taken courses that meet the board’s additional educational requirements.
Analysis and supporting documents used to determine effect on small business or in preparation of economic impact report:
The rule draft was posted on the department’s website for 14 days to solicit economic impact comments from local governments and small businesses. No comments were received.
Fiscal Estimate and Economic Impact Analysis:
The Fiscal Estimate and Economic Impact Analysis is attached.
Effect on small business:
These proposed rules do not have an economic impact on small businesses, as defined in s. 227.114 (1), Stats. The Department’s Regulatory Review Coordinator may be contacted by email at Daniel.Hareth@wisconsin.gov, or by calling (608) 267-2435. Agency contact person:
Sofia Anderson, Administrative Rules Coordinator, Department of Safety and Professional Services, Division of Policy Development, 4822 Madison Yards Way, P.O. Box 8366, Madison, Wisconsin 53708 DSPSAdminRules@wisconsin.gov, (608) 261-4463. ------------------------------------------------------------------------------------------------------------
TEXT OF RULE
Section 1. MPSW 11.01 (2) (b) is repealed and recreated to read:
MPSW 11.01 (2) (b) A degree in one of the following specialty areas from a program which was accredited by the Council for Accreditation of Counseling and Related Educational Programs at the time the applicant graduated:
1. Addiction counseling.
2. Clinical mental health counseling.
3. Clinical rehabilitation counseling.
4. Marriage, couple, and family counseling.
5. Doctoral program in counselor education and supervision.
Section 2. MPSW 11.01 (2) (c) is amended to read:
MPSW 11.01 (2) (c) A program which is equivalent to a master’s or doctoral degree in professional counseling by meeting the requirements in s. MPSW 14.01 or 14.02, including Council for Accreditation of Counseling and Related Educational Programs accredited degree programs that are not listed in par. (b) but meet the requirements of s. MPSW 14.01 or 14.02.
