Email form: https://somgovweb.state.mi.us/GovRelations/ShareOpinion.aspx
An Oakland University Counseling Department Director recently contacted Gov. Whitmer’s office and expressed opposition to LARA’s proposed rule change. He spoke with a friendly staffer named Adam, who knew the broad outline of our concern and that HB 4325 would address LARA’s concerns. He said they were monitoring how many people were contacting their office about the LPC matter. It is important that everyone call the Governor’s office!
Govornor Whitmer’s office
Phone: 517-373-3400 and 517-335-7858
Template Letter/Phone Script: Supporting HB 4325
Message that can be used when calling or emailing your State Representative serving in the House of Representatives or Senate or Governor’s Office:
Hello my name is XXXX.
I am a (Licensed Professional Counselor/Counselor in training) residing/practicing in your district.
I am calling to urge you to support HB 4325 when it comes up for a vote in the House Floor. This bill, sponsored by Rep. Aaron Miller, simply codifies some provisions of counselors’ scope of practice that have been in rules and in practice since the law was passed in 1988.
The key provision in these long standing rules is the ability to diagnose, for which counselors receive substantial training. However, new directives affecting LARA require that scope of practice is codified in legal statute, rather than Administrative Rules. If such changes are not made, the proposed rule changes by LARA will result in the inability of counselors to continue practicing, leaving Michigan’s 10,000 licensed professional counselors unable to practice and far more clients without mental health care.
This bill in no way changes a counselors scope of practice or who is eligible for licensure — it would continue the same as it has been for more than 30 years. Again, please vote yes on HB 4325. The passage of this bill is vital to retaining strong mental health counseling services for Michiganders. I thank you for your time.
Template for Written Testimony: Opposing current effort by LARA
I am writing to express my concern with LARA’s proposed rules changes for Licensed Professional Counselors (LPC) that have significant consequences on the counseling profession and the workforce in Michigan’s public mental health system. Michigan’s CMH system relies heavily on LPCs – as much as 25-30% of the workforce is made up of LPCs.
Despite the unanimous objections of the Board of Counseling Rules Committee, LARA is recommending the repeal of virtually all the rules that define an LPC’s scope of practice under R338.1751. These are rules that have been recognized as part of the scope since they were first promulgated after the passage of the Licensed Professional Counselor statute in 1988. Instead the department insists these definitions should apply only to the educational preparation of counselors and not to counseling practice.
Included in this repeal is the practice of “counseling techniques” and the related ability to “diagnose and identify the problem”. Without these and numerous other definitions, the counseling scope of practice is severely limited. Restricting scope in this way will most certainly reduce the availability of mental health professionals in Michigan’s CMH system and at a time when there is growing demand for these services.
These changes in scope would also put Michigan’s LPCs in violation of the American Counseling Association’s Code of Ethics (E.5.a. Proper Diagnosis), which requires the proper diagnosis of a client’s mental disorder before treatment, and could subject them to permanent expulsion from the profession. Additionally, insurance companies will likely stop reimbursing for the services of LPCs due to the significant limits on scope these rule changes would impose.
LARA is also pursuing the repeal of the rules identifying the requirements for providing counseling supervision (R338.1757), one of which is specific training in supervision. This training is a national standard for professional counseling.
Again, if this rule is rescinded, counselors who provide supervision without training would be practicing in violation of the ACA’s Code of Ethics (F.2.a Supervisor Preparation). Furthermore, LPCs who received their supervision in Michigan may not be eligible for licensure in other states because their supervisor would not be qualified in the state to which the counselor is moving.
I strongly encourage LARA to wait for HB 4325 (sponsored by Rep. Miller) to pass, which would negate the need for any proposed changes. Thank you in advance for your consideration.