June 2, 2003

Irmo Marini, PhD
Chair, Commission on Rehabilitation Counselor Certification
1835 Rohlwing Road, Suite E
Rolling Meadows, Illinois 60008 U.S.A.
847-394-2104

RE: D.4 Option

Dear Dr. Marini:

This letter is being written to address a concern shared by a majority of the Executive Board of the National Council on Rehabilitation Education (NCRE). The issue relates to a request that the Council will receive from the Council on State Administrators of Vocational Rehabilitation (CSAVR) to extend and make permanent the D.4 option.

This is a sensitive issue for members of the human resource development committee of CSAVR as well as NCRE members. Even within NCRE there is not universal agreement on the D.4 option. The representatives from CSAVR to the Rehabilitation Training Group of the Rehabilitation Services Administration brought their request to this body of individuals representing NCRE, CSAVR and RSA. It led to thought provoking discussion. The result? The letter you will receive will not include a number of signatures, particularly those of us representing NCRE. Why? The CSAVR representative chose not to modify the request for permanency of the D.4 option, despite our concerns.

I might note that, in rereading the HRD request, I fond some misinformation about the D.4 option. The draft I was provided said: Currently to be eligible for the CRC exam, a VR Counselor hired with a Masters degree would need to have been employed by December 2001. Because the extension is time limited, those hired with a related degree after December 2001 are not eligible for the exam. The D.4 option does not address individuals with related degrees but with a degree from any discipline. I point this out because it is at the heart of our objection to allowing a permanent D.4 category could a person with a masters degree in home economics or forestry qualify? CRCC is quite appropriate in including options for individuals who have masters degrees from counseling-related programs. These programs provide a core of skill development related to what is considered important to successful outcomes the effectiveness of the counselor in creating relationships and working with a person with a disability.

I presented this information to the members of our Executive Board and talked to a sample of our regional representatives. The majority opinion, by far, was not to support the request for permanency of the D.4 option. They identified a number of reasons for this and believed it was important for CRCC to understand the viewpoint. They are as follows:

  • The Rights of People with Disabilities - we stand for the right of people with disabilities to have access to the most qualified individuals to assist them in meeting their vocational rehabilitation needs. No other program prepares people to (1) understand and be effective in addressing the needs of people with disabilities; (2) develop the skills to assist people in addressing life concerns; (3) advocate for universal access; and (4) conduct job development and placement activities. The D.4 option does not provide for real verification of adequate clinical training in rehabilitation counseling or any standard held by programs accredited by the Council on Rehabilitation Education or Council for Accreditation of Counseling and Related Programs.

  • Temporary Intent of D.4 - the D.4 option was first initiated to assist rehabilitation counselors who had significant experience in the federal-state program of vocational rehabilitation but did not meet the educational requirement of a degree in a related discipline. It was comparable to grandfathering people into a licensure or certification when the process is new. It also prevented the loss of a great personnel investment. Those individuals have had time to undertake the coursework necessary to be eligible to sit for the CRC examination. Continuation of the option can no longer be considered a grandfathering procedure but becomes part of the minimal expectations for certification, which leads to the next point.

  • Devaluation of the CRC - no other counseling-related (or social work) certifying body allows for a person with a Masters degree from ANY discipline to gain access to their certification. What do we mean by ANY discipline that is not covered by one of the other options. I have enclosed a two-page analysis outlining these certification expectations with regards to educational requirements. If we continue the D.4 option, it will devalue the CRC in the eyes of our students, colleagues and potential employers of our students. Members of NCRE and others have worked hard to gain parity for rehabilitation counselors in the larger discipline. Perceptions to date have been that rehabilitation counselors were less qualified than that of other specializations, including community, mental health and addictions. We are challenging that perception with a strategic plan to inform others (including employers and doctoral programs) of the rigor of the educational and certification processes.

  • Interference with NCRE Strategic Plan - one example of how devaluing the CRC will interfere with our work is the project we have undertaken with the American Association of State Counseling Boards to include the CRC examination in their portability project which could have significant impact on the resiliency of the careers of our students in rehabilitation counseling and the impression of the value of a CRC. We have made significant progress toward equality with other certification examinations in the process of licensure for professional counselors. Permanency of the D.4 option will significantly weaken our credibility.

The argument for supporting the D.4 option, as expressed by the minority opinion, was to support the state agencies. The belief was that we were focusing too much on the licensure aspect of our student needs and not on the needs of the state agency. There was fear that it we would potentially lose the funding for the rehabilitation training grants that fund scholarships and stipends for students in rehabilitation counseling.

These are valid points of concern but I do not think they are reasons for ignoring the ultimate implications of continuing the D.4 option. Times have changed and we must too. Potential applicants in our programs no longer make decisions about careers by looking at what one employer would offer or expect. They have learned that downsizing, shifting of priorities and expectations are the norm in the world of work. In fact, they could learn a lot from state vocational rehabilitation counselors about the need for a resilient career portfolio.

We must concern ourselves with the resiliency of the masters degree in rehabilitation counseling in order to attract students in our academic programs of study. It is a priority that strengthens both academic programs and potential employers. A satisfied employee is one that is working (1) for the right employer, and (2) sees potential for advancement or lateral movement in his or her career. That person is not stuck but is actively engaged in professional development and proactive in their career planning. Rehabilitation counselors must have options available to them and, as educators, we must consider what those options require and meet them. We must also be concerned with our own careers as the majority of the members of rehabilitation counseling education programs hold a CRC.

State agencies are indeed in a problematic situation at present. They must meet the intention of CSPD while dealing with recruitment problems compounded by massive retirements. Accepting just anyone into the system with the intent of providing a few courses to ensure they are CRC-eligible is not the answer. It can create a multitude of problems, the least of which is inadequate training to address the needs of our constituents people with disabilities. The agencies may want to look further into why a limited number of qualified rehabilitation counselors graduating from CORE-accredited programs choose the federal state system as an employer.

People with disabilities deserve to have people in all helping professions. We are one of the few that specifically address disability in a new paradigm and practices informed choice and person-first approaches. The values and practices developed by rehabilitation counselors need to be infused into advanced practice settings such those which employ licensed professionals as counselors, and counseling psychologists. If we limit the potential of our students to advance into these practices we are limiting the potential for people with disabilities to find individuals competent to provide counseling and psychological services to them outside of the vocational rehabilitation arena.

Rehabilitation counselor education programs have undertaken distance education programs that can meet the needs of place-bound person who does not have ready access to an institution of higher learning. The development of this extensive system of distance education programs by rehabilitation counselor educators and with the assistance of RSA provides the state-federal system with the tools necessary for their staff to meet the qualifications necessary for CRC eligibility in a effective manner. It is for this and the other reasons described above that NCRE does not support the request presented to CRCC by CSAVR to create a permanent D.4 category. We would support a limited extension of a year although it should be noted that the hiring of individuals in December 2001 was done after initiation of the CSPD standards.

Sincerely,

Margaret K. Glenn, Ed.D., CRC
President

(enclosure)