IMHCA’s Position on Proposed changes to Chapters 31 and 32 (Licensure of LMHCs and LMFTs)

Members, below is a memo from IMHCA dated August 26th with IMHCA’s points that were sent to the Board of Behavioral Sciences and after this member is a blog from the ACA dated August 27th with their stance on the proposed rule changes. This newsletter will be updated as additional information is received/published.

August 26, 2019

To: IMHCA members

From: The IMHCA Board

RE: Proposed changes to Chapters 31 and 32

Public comment was submitted on behalf of IMHCA regarding our position on the proposed changes for chapters 31 and 32. The following are highlights of the letter:

  • We explained the purpose, mission, and history of IMHCA
  • Discussed the 20 years of experience promoting the interests of LMHCs in the state
  • Addressed counterpoints from those who are opposing these changes
  • The following supporting explanations:

Proposed Change: NCMHCE Requirements

The Institute of Medicine previously provided recommendations to the Department of Defense that would require LMHCs to verify that they obtained a degree from a CACREP accredited program in Clinical Mental Health Counseling in addition to passing the National Clinical Mental Health Counselors Examination (NCMHCE) as it assesses more clinical competencies than the National Counselor’s Exam (NCE) which is a broader knowledge exam and one that appeals more to new graduates in our experience. The recommendations that were provided by the Institute of Medicine have helped guide IMHCA’s efforts as we continuously work to ensure that all prospective licensees attend a CACREP accredited program and understand the importance of taking the NCMHCE.  The changes recommended here are critical to ensuring that LMHCs are fully recognized under TriCare, enabling them to help fill a chronic need for mental health providers within the VA and potentially leading to their eligibility under Medicare should Federal legislation pass granting LMHC’s inclusion in that program.

Proposed Change: 2 Years of Clinical Experience

IMHCA has and continues to be a champion for supervision requirements in the profession as we feel it is a critical factor in maintaining the highest level of care for clients in Iowa.  The two-year requirement (as opposed to full-time equivalent) eliminates any opportunity for a potential licensee to fast-track their required supervision period by claiming full-time experience, and therefore, ensures all LMHCs are only granted the right to provide services after at least two full years of supervision.  This provides protection for both the client and the clinician regarding standards of care.

Proposed Change: Adoption of the AMHCA Code of Ethics

IMCHA is a strong supporter of this change for many reasons.  Not only are the code of ethics currently recognized in Iowa (the ACA Code of Ethics) far broader than those adopted by AMHCA, they also undermine current efforts by LMHCs to establish a clear and distinct professional identity in Iowa.  ACA represents a host of different “professional counselors,” so understandably parts of their code do not readily apply to mental health practitioners. A large portion of ACA’s membership is made up of school counselors, for example, who lack the clinical training and experience necessary for providing clinical mental health services.  The ACA has a history of not representing or understanding the scope and practice of clinical mental health counselors.

The effort to appeal to a broader membership base has also resulted in the Association’s exclusive promotion of the title ‘Licensed Professional Counselor’ (LPC) in all states, despite the negative consequences adoption of that title tends to have on mental health counselors specifically.  An ‘LPC’ designation not only lacks clarity of the services provided, it typically includes school counseling professionals (guidance counselors), art therapists, and music therapists among others.  These professions are licensed and/or endorsed separately here in Iowa and adhering to ACA’s current language only muddies the waters and makes our job of educating Iowans on how to go about accessing quality mental health services and how to ensure the care they are getting is of the highest standard, far more difficult.


Conversely, AMHCA exclusively represents mental health counselors in its efforts, and the Code of Ethics is reflective of this exclusivity.  It does not align with an agenda full of social justice issues as the ACA code tends to do, but is instead more responsive to the needs, issues, and realities faced by nearly all LMHCs practicing here in Iowa, in addition to being more conducive to what is taught in CACREP programs. Most importantly, unlike the ACA code of ethics which leaves many professionals stuck in situations that are not good for them or the clients they serve, the AMHCA code maintains greater levels of protection for all parties.  One example of this is the fact ACA considers it an ethical violation if a practitioner believes they are providing services outside of their scope of practice and decides referring the client to another qualified clinician would be in the best interest of all parties (one might see this with LGBTQ+ populations, with children found to be on the autism spectrum after therapy has already been initiated, and in other unique but equally qualifying cases).  A practitioner who chooses to exercise his/her right to protect clients from this reality faces a loss of licensure for that decision under ACA’s code, despite the fact providing services to a client that one is not properly trained or prepared to serve will result in (at its best) subpar treatment, and (at its worst) irreparable harm to that client.

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ADDED 8/29/2019

Hello members, I want to include what the ACA has published about these proposed changes so you can make an informed decision to message the Iowa Board of Behavioral Sciences should you choose. Here is a link to the ACA call to action:

Here is what the ACA blog says as of 8/27/2019:

Aug 27, 2019

Urgent: Contact the Iowa Licensure Board About New Regulations

The Iowa Board of Behavioral Health is considering changes to its Educational Qualifications for Mental Health Counselors. In the Professional Orientation curriculum, the Board proposes to replace the American Counseling Association with the American Mental Health Counselors Association as the primary one to be studied, despite ACA’s much longer history and larger membership.

More significantly, under the Ethical Standards curriculum, the Board proposes to replace ACA with AMHCA as the source of counselor ethics to be studied. ACA’s Code of Ethics is the standard across the nation. Moreover, it is the code of ethics adopted and used by the Iowa Board of Behavioral Health. There is no logical reason to adopt the code of ethics of one association for all counselors to work under and then require students to learn about the ethical standards of a different association.

Finally, the proposal would greatly limit the ACA and NBCC-approved online conferences and courses available for continuing education credits.

If you are affected by licensure in Iowa, please send the attached message to the Board of Behavioral Health immediately at this address by September 1st:    You can add your own thoughts on these three recommended changes, as well as your experience and work setting.

To the Iowa Board of Behavioral Sciences:

I am concerned about three of the drafted pre-notice rule changes to the Board of Behavioral Science’s rules. The first would replace the American Counseling Association (ACA) with the American Mental Health Counselors Association (AMHCA) as the primary organization to be studied under Professional Orientation (Section 31.6(2)a.(10)3 on page 9 and 31.6(2)b(1)6 on page 10). This seems ill-advised as ACA is the much larger and older organization. In fact, AMHCA was a division of ACA until just this year. I believe it makes more sense for students to primarily study ACA when learning about professional organizations.

More importantly, the second change would replace ACA with AMHCA as the source of ethical standards to be studied, including “their evolution, legal issues, and applications to various professional activities.”  This is a puzzling change because the Board of Behavioral Health goes by the American Counseling Association Code of Ethics. It makes more sense to continue to study the ethical standards of the association whose code of ethics you have adopted, rather than those of the one you have not.  (Section 31.6(2)a(10)4 on page 9 and 31.6(2)b(1)10 on page 10.)

Finally, the Chapter 32 rule changes would remove all ACA and National Board for Certified Counselors (NBCC) – approved distance conferences and courses. ACA and NBCC provide opportunities for continuing education sessions through video conference that are especially valuable for counselors in rural areas.

In short, I am opposed to all of these changes and I hope the Board will reconsider them, and ultimately, not adopt them.

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AMHCA’s stance on separating from the ACA:

AMHCA and ACA Separate Associations

By Alan Goodman posted 04-26-2019 11:28

The American Counseling Association (ACA) and the American Mental Health Counselors Association (AMHCA) are now completely separate associations.  It should be well understood that there are many types of counselors nationwide, but AMHCA was the ACA division tasked to support the needs of clinical mental health counselors.  Now, AMHCA as a standalone association is the only one that is uniquely dedicated to the academic, internship, supervision, and licensure of clinical mental health counselors.  AMHCA supports students, faculty, supervisors, supervised pre-licensed and licensed clinical mental health counseling professionals.  As ACA has stated in a recent public release, there was agreement that it was time for the two associations to disaffiliate.  ACA and AMHCA will remain sibling associations as we will with other organizations such as NBCC, NASW, NAMI, APA, and more so that we may work on projects of joint importance to the larger behavioral health community.

In the academic community it is of course important for faculty and students to be aware of this change.  The need for students to associate themselves early in their careers can be critical to their future as it helps them to feel a sense of identity and to have a voice in decisions that may directly impact their future endeavors.  Requests for additional information or materials should be directed to the AMHCA CEO, Mr. Joel Miller, whose email address is

The board members of AMHCA are thrilled to be taking on this new chapter in our association’s history.  Given the growth of clinical mental health counseling nationwide, it simply makes sense that mental health counselors have their own association.  We remain grateful for the many years of support we received from the ACA and look forward to working with them in the future.

AMHCA’s response to the Real Simple article:

My Thoughts on the Real Simple Article: How to Find a Therapist

By Alan Goodman posted 10-01-2018 11:18

If you have read the article “How to Find a Therapist”, by Andrea Peterson in the latest edition of Real Simple magazine, then you are probably upset and bewildered.

The piece is in part based on an interview with Dr. David Kaplan, American Counseling Association’s (ACA) Chief Professional Officer, among others. The article is patently incorrect on many levels and stands as an indication that the author simply didn’t do the most basic fact-checking. Even a rudimentary online search would have led her to the AMHCA website and more information on who counselors are and what we do. In the article Dr. Kaplan is quoted as follows:

“If you’re having problems at work or in your relationships or just feeling blah about life, a licensed professional counselor might be a good person to start with. Counseling doesn’t usually focus on treating severe mental health issues but helps people “figure out the factors that get in the way of being happy,” says Dr. Kaplan, PhD, chief professional officer at the American Counseling Association.”

Not only does he do us a grave injustice, but nowhere in the article does he reference AMHCA, though other behavioral health related associations and organizations are mentioned freely.

I have been responding to as many emails and phone calls as I can with some of our AMHCA members calling for some explicit act of contrition on the part of ACA. I have not had a single item of correspondence supporting the views presented in the article. I understand the frustration and share it and the AMHCA CEO and Board of Directors will be asking ACA leadership how they propose to resolve this issue.

I have also had some members asking why they should continue their membership with ACA, but in my view that’s a personal decision and not one I can address. The best advice I can offer on this matter is for existing ACA members to contact ACA and discuss their concerns with them directly. I can say that AMHCA is still and always has been the only organization that is 100 percent dedicated to supporting (and understanding) clinical mental health counselors; who we are and what we do.

We know how academically prepared, skilled, and qualified CMHC’s are.

We know CMHC’s offer critical services to the communities and populations you serve, and that includes those with severe mental health issues.

We also realize that it’s important to educate the public as to what we have to offer. In that respect, sadly we view the Real Simple article as a missed opportunity.

The executive director/CEO and members of the AMHCA board of directors take this issue very seriously. We will not let it drop, and we will continue to serve you, our members as you deserve to be served; with dignity and respect for all that you know, and all that you do.