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:
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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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: https://www.counseling.org/news/aca-blogs/aca-government-affairs-blog/aca-government-affairs-blog/2019/08/27/urgent-contact-the-iowa-licensure-board-about-new-regulations