“They Stay With You”: Counselor Educators’ Emotionally Intense Gatekeeping Experiences

Daniel A. DeCino, Phillip L. Waalkes, Amanda Dalbey

Emotionally intense gatekeeping experiences can require counselor educators to engage in a complicated, time- and energy-consuming, and draining series of events that can last years and involve legal proceedings. Research related to counselor educators’ experiences of intense emotions while gatekeeping remains limited. The aim of this transcendental phenomenological study was to investigate counselor educators’ (N = 11) emotionally intense gatekeeping experiences. Five themes emerged from the data: early warning signs, elevated student misconduct, dismissal, legal interactions, and change from experience. By being transparent about their feelings and challenges regarding emotionally intense gatekeeping experiences, counselor educators may compel other faculty, counselors in the field, and doctoral students to be better prepared for emotional gatekeeping experiences.   

Keywords: gatekeeping, counselor educators, transcendental phenomenological, emotionally intense, experiences


Gatekeeping is an important role for counselor educators in order to uphold ethical standards within the counseling profession and to protect clients, students, and faculty (Homrich & Henderson, 2018). Allowing unprepared individuals to become counselors can impede positive client outcomes in therapy and even harm clients (Homrich & Henderson, 2018). The American Counseling Association’s ACA Code of Ethics (2014) defined gatekeeping as “the initial and ongoing academic, skill, and dispositional assessment of students’ competency for professional practice, including remediation and termination as appropriate” (p. 20). In addition, the Council for Accreditation of Counseling and Related Educational Programs (CACREP; 2015) standards require counseling program faculty to follow gatekeeping procedures in line with university policy and the profession’s ethical codes.

Previous researchers have explored gatekeeping procedures (Swank & Smith-Adcock, 2014), gatekeeping policy (Rust et al., 2013), models for evaluating student counselor competence (Lumadue & Duffey, 1999), and problematic student behaviors (Henderson & Dufrene, 2013). Although research has focused on gatekeeping in counselor training, how counselor educators experience emotions tied to gatekeeping practices remains relatively unknown. Faculty who have engaged in some gatekeeping practices (e.g., remediation and dismissal) have reported experiencing strong emotions that may negatively impact the gatekeeping process (Wissel, 2014). Therefore, the purpose of this transcendental phenomenological study was to illuminate counselor educators’ emotionally intense gatekeeping experiences. We defined emotionally intense gatekeeping experiences as multilayered, complex, time-extended events that counselor educators identify as emotionally memorable.

Emotions and Gatekeeping
     In more serious cases, gatekeeping can be a multilayered series of interactions with administrators, university appeals boards, and lawyers (Homrich & Henderson, 2018). Ziomek-Daigle and Christensen (2010) framed counselor educators’ gatekeeping in terms of preadmission screening, postadmission screening, remediation plan, and remediation outcome phases. In many cases, students and educators often proceed through Ziomek-Daigle and Christensen’s linear gatekeeping phases, but in other cases, gatekeeping is non-linear. In these non-linear cases, a student may be dismissed from their program, file an appeal, and be granted re-admittance. In these intense gatekeeping scenarios, a considerable amount of attention, time, and energy are often required of counselor educators. Although Ziomek-Daigle and Christensen’s phases are aimed to promote more structured gatekeeping practices, little is known about what phases, specific topics, or dimensions of counselor educators’ experiences with intense gatekeeping may exist.

A fear of legal consequences as a result of gatekeeping practices can influence counselor educators’ decision making (Crawford & Gilroy, 2013). Homrich et al. (2014) found that gatekeepers experience negative emotions, including fear and apprehension, surrounding student dismissals. Recently, Schuermann et al. (2018) utilized consensual qualitative research to reaffirm counselor educators are fearful of some gatekeeping outcomes (e.g., threats of lawsuits or legal consequences). Despite this potential for negative feelings, little is known about how counselor educators’ emotions may be tied to gatekeeping-related lawsuits and how these experiences are processed and managed.

Gatekeepers can pay an emotional price for gatekeeping students (Gizara & Forrest, 2004). In a collective case study of 12 counseling psychologist site supervisors, participants unanimously expressed that student impairment issues (e.g., when students acted unprofessionally at clinical sites) were the most painful events to confront with supervisees (Gizara & Forrest, 2004). Similarly, participants interviewed in Wissel’s (2014) phenomenological study on counselor educators’ experiences of terminating students for non-academic reasons (e.g., students causing harm to clients during practicum) reported these experiences were uncomfortable because of role dissonance and responsibility. Kerl and Eichler (2005) claimed counselor educators may experience a “loss of innocence” as a consequence of emotionally taxing, isolating, and professionally challenging gatekeeping experiences (p. 83). Kerl and Eichler also stressed that counselor educators should emotionally explore the meaning of their gatekeeping experiences to uncover how these feelings interact with their gatekeeping practices. Unless emotions surrounding gatekeeping are addressed, counselor educators may “remain stuck in a place that holds on to us with powerful and overwhelming emotions” (Kerl & Eichler, 2005, p. 84).

Because gatekeeping can generate intense emotions, counselor educators’ failure to understand and bracket their emotions could result in flawed decision making that serves their needs instead of the ethical codes of the profession (Brear & Dorrian, 2010). Providing specific insights and strategies to help counselor educators become aware of their emotions during intense gatekeeping experiences may help them protect themselves, other faculty, peers, and future clients. Yet, there is currently a lack of depth in our understanding of counselor educators’ emotions related to gatekeeping. Therefore, guided by Moustakas’ (1994) notion that transcendental phenomenological studies should seek to uncover the essential structure of a particular phenomenon, our study sought to answer two research questions: First, what are the common elements of counselor educators’ emotionally intense gatekeeping experiences? Second, what, if any, important insights did counselor educators gain from emotionally intense gatekeeping experiences?


Phenomenological research generates descriptions of experiences that “keep a phenomenon alive, illuminate its presence, accentuate its underlying meanings, enable the phenomenon to linger, and retain its spirit, as near to its actual nature as possible” (Moustakas, 1994, p. 59). Therefore, we chose to use a transcendental phenomenological approach for this study to capture and share the essence of counselor educators’ lived experiences with emotionally intense gatekeeping (Lopez & Willis, 2004). Transcendental phenomenology allowed us to (a) explore how emotionally intense gatekeeping experiences affect counselor educators personally and professionally, (b) bracket our own assumptions about emotionally intense gatekeeping, and (c) understand the common elements of participants’ gatekeeping experiences.

     Participants qualified for inclusion in this study if they self-reported at least one emotionally intense gatekeeping experience and were currently employed as a counselor educator at a CACREP-accredited institution. Eleven counselor educators participated in this study, representing years of experience between 2 and 37 years (M = 19.8, SD = 11.58). Table 1 provides a snapshot of participant demographics.


Table 1

Participant Demographics

Name Gender Race or Ethnicity Rank Degree Major Degree Type Yrs. Exp. CES
Sue Female White Assistant CES PhD     0–5
Rosie Female White, Caucasian Full CP PhD 20–25
Rose Female White, Caucasian Associate CES PhD 15–20
Mike Male Caucasian Full CEs EdD 25–30
Mark Male White Full CES PhD 35–40
Maria Female White, Caucasian Associate CES PhD   5–10
Lila Female Multicultural Full CP PhD 25–30
Frank Male Caucasian Full CES EdD 20–25
Rita Female Hispanic Associate CES PhD 20–25
Herbie Female Asian Assistant CES PhD   5–10
Dan Male White Adjunct CES EdD 30–35

Notes. All participant names are pseudonyms. For gender, race, or ethnicity, participants’ responses were recorded verbatim. CES = Counselor Education and Supervision. CP = Counseling Psychology. PhD = Doctor of Philosophy. EdD = Doctor of Education. Yrs. Exp. CES = Years Working as a Counselor Educator and Supervisor.


Recruitment Procedures
     To seek out counselor educators with emotionally intense gatekeeping experiences (Miller et al., 2018), we recruited participants through three purposeful sampling and screening procedures. First, participants were recruited based on their authorship of at least one gatekeeping article published in a journal or magazine that noted their professional experiences with gatekeeping. Four articles addressing the authors’ personal experiences with gatekeeping were identified. Those authors were sent an email inviting them to participate in this study. Second, we used a purposeful sample of accredited counselor education programs listed on CACREP’s official website. This search yielded a total of 880 potential counselor training programs. We generated a stratified sample three times that resulted in three separate batches of 23 programs. Program coordinators were sent emails asking them to share the study invitation with their faculty members who may identify as having one or more emotionally intense gatekeeping experiences. Third, snowball sampling was used by asking all participants to identify other potential participants who fit our criteria for participation. To meet the study’s eligibility requirements, participants were required to (a) be employed at a CACREP-accredited counselor training program; (b) be instructors or adjunct, full, associate, or assistant professors (Schuermann et al., 2018); and (c) have been involved in at least one emotionally intense gatekeeping experience as a counselor educator.

Data Collection Procedures
Semi-Structured Interviews
     After the lead researcher obtained IRB approval, we collected interview data through telephone and Skype interviews. We contacted potential participants with a description of the study, including our definition of emotionally intense gatekeeping, and a copy of the informed consent form. Interested participants responded to our requests via email and the lead researcher scheduled a time to interview them. Semi-structured interview questions were designed from a review of the relevant literature on gatekeeping and our own professional experiences with gatekeeping as counselor educators to gather rich and thick descriptions of the phenomenon (Creswell & Poth, 2018). Interview questions, including “What do you remember most vividly about your emotionally intense gatekeeping experiences?”, were emailed to all participants prior to their interviews. Before audio recording began, all participants created a pseudonym to protect their confidentiality. All interviews were audio-recorded using Garageband. Interviews were between 24 and 45 minutes and were transcribed by Rev.com. Once interviews were transcribed, audio files were deleted.

Letter-Writing Activity
     Once interviews were completed, participants also were invited to complete a letter-writing activity based on their emotionally intense gatekeeping experiences. Letter writing can provide a concrete and lasting record of one’s experiences as opposed to spoken words, which usually disappear after they are spoken (Goldberg, 2000). We used this letter-writing activity to help triangulate the data. The letter-writing instructions asked participants to revisit their emotionally intense gatekeeping experiences, if other prior life events may have influenced their perceptions of gatekeeping, and what, if anything, they learned from these experiences. We received three letters, ranging from 94 to 2,027 words (M = 786).

Data Analysis
     We used Moustakas’ (1994) five-step transcendental phenomenological process to analyze the data. First, prior to reading the transcribed interviews and letters, the research team (composed of all three authors of this article) met and existentially bracketed (Gearing, 2004) their experiences with emotionally intense gatekeeping, identifying biases or presuppositions. Next, we read the transcripts and letters twice independently and began familiarizing ourselves with participants’ experiences. We reconvened to discuss our initial impressions of the data and engaged in horizontalization (Moustakas, 1994), or highlighting and clustering significant statements into groups with similar meaning. Forty-six initial codes were created and grouped into clusters to generate textural descriptions of the phenomena. We met three more times to discuss our emerging themes, reconcile any discrepancies in our analysis, and reach consensus on the findings. In between each meeting, team members independently reflected on the codes and emerging phenomena. We reconvened a fifth time and developed nine larger themes that were organized as textural and structural clusters, or meaning units (Starks & Brown Trinidad, 2007). Through this process of phenomenological reduction (Moustakas, 1994), we refined our themes and identified the crucial elements of participants’ experiences. At this point, two themes were discarded because of inconsistent support and a lack of consensus among the research team. Next, an external auditor, who was a counselor educator with qualitative research experience and numerous publications in counseling journals, reviewed the initial coding and theme construction and provided feedback to the research team. The auditor suggested the removal of one theme and the consolidation of two others. The research team discussed the external auditor’s feedback and incorporated their theme reduction suggestions to help clarify the meaning and representation of the data. Finally, we met one more time to discuss our final five themes and confirmed that our findings accurately represented the essence of participants’ experiences of emotionally intense gatekeeping.

     In this study, we used several measures to achieve congruent trustworthiness within the phenomenological research tradition (Flynn & Korcuska, 2018). First, in order to uncover the essence of our experience without completely detaching from the world, we bracketed our prior theories, interpretations, and assumptions of the phenomena through multiple team discussions (Gearing, 2004). To track our discussions during the data collection and analysis phases, the lead author kept a reflexive journal to help us account for our presuppositions and interpret the data accurately. Second, we offered participants a member check of their interview transcripts. Each participant was asked to review their transcript for accuracy and was provided an opportunity to elaborate further on their initial statements. Five participants elaborated on their thoughts to clarify meaning. Third, the lead author kept an audit trail detailing the times and dates of participant interviews, sampling procedures, and member checks, and a summary of the discussions between the researchers (Creswell & Poth, 2018). Fourth, the letter-writing activity yielded another data source to triangulate our findings (Merriam & Tisdell, 2016). Finally, the auditor in this study challenged the research team to revisit our prior assumptions of emotionally intense gatekeeping experiences to ensure monitoring of potential bias.

Reflexivity Statement
     The research team included two counselor educators employed as full-time faculty at two different midsized universities in the Midwest United States, and one graduate student with knowledge of gatekeeping and research experience at the first author’s university. The first author identifies as a White, able-bodied, middle-aged male and pre-tenured counselor educator. The second author identifies as a White, able-bodied, middle-aged male and pre-tenured counselor educator, and the third author identifies as a White, able-bodied, young adult female counseling graduate student. Our main assumptions before starting this study were that (a) emotionally intense gatekeeping experiences elicit only negative emotions from faculty; and (b) discussion of emotionally intense gatekeeping experiences is considered taboo for fear of litigation or unwanted attention. These assumptions stemmed largely from our own experiences as students in counselor training programs. Each of us experienced times when we knew faculty were engaged in gatekeeping. These experiences modeled gatekeeping for us and demonstrated how faculty balance protecting students from peers who may be engaged in problematic behaviors.


We identified five themes from counselor educators’ emotionally intense gatekeeping experiences: (a) early warning signs, (b) elevated student misconduct, (c) student dismissal, (d) legal interactions, and (e) change from experience.

Early Warning Signs
     Most participants (n = 10) discussed behavioral and academic issues with students that, at first, appeared to be fixable through remediation and interventions. During these experiences, participants reported feeling shock, frustration, irritation, and sadness. For example, Rose shared how faculty noticed that a student was making poor choices and how they tried to intervene quickly:

She really had tried to push herself too far, farther than she was ready to go. . . . I just knew the person, in spite of the faculty repeatedly saying don’t push yourself too hard to where you’re not even able to show up at your practicum internship site on a regular basis. They ignored our advice. And when somebody is simply not showing up on a regular basis, that’s behavior that can’t go on.

In other examples, participants shared stories of students exercising poor boundaries. In these experiences, students displayed behaviors that were symptomatic of larger issues that would reveal themselves later. Dan shared:

This student was chronically late, and when the student arrived, instead of just sliding in quietly, the student would make an entrance. . . . After this became a chronic problem, there seemed to be resistance. The next semester was similar, except by now, I could see that the student was being avoided by many of his classmates.

Like Dan, participants discussed a variety of outcomes after their early interventions with students regarding their problematic academic and professional behavior(s). Often counselor educators’ interventions helped students remediate and correct their behaviors. In other cases, students continued to act inappropriately or committed more serious infractions.

Elevated Student Misconduct
     All 11 participants described a more serious student violation after initial warning signs. These violations required a higher level of faculty intervention. In these interactions, participants felt anger, betrayal, and confusion. Sue discussed her emotions and process surrounding discovering her students had cheated:

I had one earlier this year that was very emotionally intense, that affected me personally and professionally, that was around academic honesty and integrity. During one of my classes, I discovered that a group of students cheated on an examination—a group of five out of a classroom of 12, so a very significant percentage. It was really shocking at first. I really did go through the stages of grief now looking back.

For several other participants, more serious violations occurred during students’ practicum or internship courses. Mike described hearing about one student’s ethical violation from their practicum site supervisor: “She has taken it upon herself to recruit individual clients from her group to see on her own, at home!” These events brought out anxiety, despair, and anger in faculty members and required more direct interventions, including direct meetings with students, discussions of students during faculty meetings, or removal of students from a class or courses.

Student Dismissal
     Participants (n = 9) reported feeling many intense emotions in their experiences when dismissing students. Most expressed extreme sadness and frustration with students. Students were usually dismissed after failing to comply with remediation plans (e.g., retaking an ethics course, attending personal counseling) within the time frame allotted. Some remediated students chose to leave the program on their own account. Some participants questioned if they were acting in the best interests of the profession, program, and university. For example, Rose reflected on her personal feelings and professional responsibilities with emotionally intense gatekeeping:

I would say that [gatekeeping experiences] took a lot out of me, emotionally. It was exhausting. Even today, I don’t feel the intensity that I felt at the time. But there’s still emotion. There’s still kind of a sadness and disappointment that we had to have conversations. And certainly, I’m very hopeful that . . . the people who were removed from the program have found something else to do where they can be successful.

Participants’ decisions to dismiss students also impacted them unexpectedly. Lila explained:

Once in a while it’s also very sad because you see people with a lot of potential, good people, that because of what’s happening in their lives might make poor choices. And the sad part is to see somebody with so much potential getting themselves into trouble because of personal issues. And then the investment they have made in their education and all this money they have put into it, it comes to an end because they made poor choices. It’s very sad to see something like this. It stays with you. Those are the things that sometimes will wake me up at three, four in the morning and think, “Ah, I wish things were different.”

Legal Interactions
     Among the most disruptive and emotionally intense phase of many participants’ (n = 7) gatekeeping experiences were legal proceedings. These moments were often physically and emotionally taxing, confusing, and disruptive on personal and professional levels. Participants frequently second-guessed their thoughts and behaviors. Usually this phase started with notification of a lawsuit that was filed on behalf of the student against the faculty, program, or university. Mark shared his feelings after discovering he was one of the primary people named in a lawsuit:

I was the department chair, and I had to deliver the news. I was named in the lawsuit along with the dean, and the Board of Trustees, and one other faculty member. . . . I questioned whether I had done things properly. I felt vulnerable. I felt like that my reputation might be compromised.

Legal proceedings involving participants (n = 6) were jury and judge trials in either civil or criminal court and sometimes generated publicity outside of their institutions. Several participants shared that legal proceedings came with an emotional cost to them and their respective programs. For example, Dan felt emotionally exhausted with his lengthy involvement with the legal system:

Along the way, there was tremendous amounts of angst, and time, and energy, and aggravation spent on this student, and on the trouble that he generated, and the accusations that he was making . . . 12 or 18 months later, we were notified that he had hired an attorney, and that he was going to sue the college. Depositions followed, hours of depositions. Because I was the faculty member that had the most time with him, I was deposed for about a day and a half, where his attorney asked me every imaginable question six different ways from Sunday. It was not a pleasant experience. Anyway, there would be many, many months that would go by without hearing anything, and then we’d be told that, “Okay, we’ve been scheduled for a trial.” Then we get up to the trial and there’d be some continuance, and the can would get kicked down the road again. From the time the student was expelled from the program to deposition, it was four years. From the time of the actual jury trial, it was 10 years.

Most participants were surprised and saddened by students’ efforts to win legal proceedings. Participants were aware of the importance of their legal encounters, yet also unsure how to balance them with multiple professional responsibilities. Lila expressed:

This was a student that was terminated and the student sued, started a lawsuit. . . . The student re-mortgaged their home so they could hire that attorney and take the university to court, take us to court. It was disruptive to our teaching because . . . the trial was happening about an hour and a half away. So we would have to find somebody to cover our class. We would get there, there would be delays, so we would be asked to go again the next day. . . . And we won the case because we had followed the policy and the student had refused to remediate . . . so the student lost their home. I mean it was a really sad situation.

Change From Experience
     All participants in this study shared what they learned from their emotionally intense gatekeeping experiences. In this theme, participants offered advice and wisdom for other counselor educators.

All participants shared that their emotionally intense gatekeeping experiences reinforced their commitment to ethics, program standards, transparency, and fairness. Despite their feelings of guilt and humility resulting from their experiences, participants wanted to be more proactive and clear with their gatekeeping processes. Dan shared:

It was a learning, not just for me, but for our entire faculty that we need to be really clear every step of the way, about who we are as a program, what do we stand for, what expectations do we have? And that when those expectations are in some way violated or are bent, we need to be very clear with the student about what’s going on. And when or if we ever arrive at a place where we see a student who is having this kind of a problem, we need to take action sooner.

Every participant expressed a commitment to engage in future gatekeeping practices more effectively. Several expressed feeling unsure about gatekeeping initially but eventually replaced vacillating feelings with more confidence and greater self-efficacy. Herbie noted:

I think initially there was much more apprehension and dread. Just a lot of uncertainty and a lot of ambiguity about like, okay, how is it going to go? What do I need to say? How can I be clear? How am I wrapping up this conversation and their understanding of the message I’m trying to communicate? Well, at the same time as, you know, like being a counselor, like how can I be like positive and supportive at the same time, which is a hard place to be in when you’re also being the disciplinarian. And I think now because I’ve had many more experiences with gatekeeping, and having those tough conversations, it’s much clearer to me. I go in and I have in my mind a plan that I need to follow.

Nine participants shared how bracketing their personal beliefs, emotions, and opinions of students helped them become more effective and ethical gatekeepers. Frank commented:

I was less aware of my emotional triggers years ago. And realizing that there are lots of different values, beliefs, knowledge, and skills that I bring in that I use to judge a situation. And in doing so I have to remember to bring it into the present. That I have to be able to separate what my values and beliefs, skills, and competencies are and what is expected of the profession, especially as delineated in the code of ethics.

Most participants also discussed how their programs and departments changed as a result of their intense gatekeeping experiences. Changes often occurred at multiple levels. For example, Sue shared, “I tightened my syllabi. I went back through the code. I actually advocated and we re-wrote all of the syllabi for my entire university in grad counseling.”

     All but one participant (n = 10) offered current and future counselor educators advice on emotionally intense gatekeeping experiences. Eight participants specifically mentioned that counselor educators should rely on trusted and supportive colleagues to help navigate emotionally intense gatekeeping. Dan said:

I want to say how critically important it is to make sure that you build a team of faculty, not just for the day when you’re going to have to engage in a gatekeeping process, but for all kinds of reasons. Building a team where there’s real trust, where there’s emotional vulnerability, and where differences about ideas . . . can be addressed is so very important.

In other examples, participants shared how each faculty member in their program developed a role. These roles helped faculty share responsibility with gatekeeping duties while also promoting due process and professionalism. Rosie commented:

We look at [gatekeeping] in a behavioral way, but certainly with a respect for the student’s interpersonal processes and personality style. . . . We’re always good at keeping each other (faculty) accountable. . . . We balance each other out. Then, when we do meet with the student as a faculty, if on one of those occasions we think that is necessary, we take different roles. We decide who’s going to be what person in that process.

Several participants offered tips for working with administrators (e.g., deans, human resource representatives, university lawyers, provosts, presidents), including how faculty may need to explain ethical codes, program policy, and gatekeeping philosophies to them. Lila shared, “Be prepared outside of the department, there are appeals committees. They may see it differently than you and your faculty see it.” Maria offered more proactive advice:

At the beginning of a semester, reach out to deans or upper administration, that, “we are looking to tweak or update our gatekeeping policy; we’d like to run it by you and get your feedback, and we’d also like to run it by legal counsel through university.” And that helps everybody be informed up front, and things tend to go much better when everybody knows what to expect and what our obligations are as gatekeepers.

Finally, all participants talked about ways in which counselor educators and counselor programs can better prepare doctoral students and support early career faculty for emotionally intense gatekeeping experiences. Herbie offered:

[The] messages I received and modeling that I saw were really helpful in me understanding the need for gatekeeping. Because the parameters that were set forth in both my master’s and my doctoral program, were just really clear on what’s okay and what’s not okay. And then having a cohort family . . . and having that support network and being able to talk about experiences that I was observing . . . within a safe container was really helpful.


To ensure the counseling profession is composed of qualified, competent, and ethical counselors, counselor educators must gatekeep even if they may experience intense emotions. The emotions stemming from participants’ intense gatekeeping experiences included dissonance, discomfort, guilt, anger, and role confusion, as well as empathy, compassion, and sensitivity for students. These emotions were similar to those reported by participants in other studies (Gizara & Forrest, 2004; Wissel, 2014). Regardless of the type (i.e., professional or academic) and the level of severity of gatekeeping counselor educators experienced, participants’ experiences were persistent and draining. Counselor educators engaged in intense gatekeeping should prepare for exhausting, emotionally layered events that will impact them professionally and personally. In addition, the time-intensive nature of emotionally intense gatekeeping is noteworthy. Several counselor educators reported that numerous years (the longest being 10) were needed for due process (i.e., academic appeals and legal proceedings).

The findings from this study also extend the concept of gatekeeping beyond the boundaries of what happens within a counseling student’s program and institution. Ziomek-Daigle and Christensen (2010) noted that unsuccessful remediation efforts may yield either students leaving their program voluntarily or being dismissed. This study highlights that when students challenge dismissal decisions, the dismissal process can involve legal proceedings that can last for numerous years. Over half of the participants in this study discussed legal encounters of some kind related to intense gatekeeping, and this may indicate that legal encounters related to gatekeeping may be occurring more frequently among counselor educators (Homrich et al., 2014; Schuermann et al., 2018).

Most participants expressed that their gatekeeping experiences fostered their professional growth, but also came with personal emotional costs. Many participants said that their intense gatekeeping experiences unexpectedly affected them personally. Some participants indicated they felt trapped because they could not share details of their emotionally intense gatekeeping experiences with partners, family, or others outside their department because of student confidentiality constraints. This finding aligns with Kerl and Eichler’s (2005) assertion that unless faculty actively take steps to process emotionally intense gatekeeping experiences, the experiences themselves may hold power over faculty until they are properly addressed.

Finally, as a result of their intense gatekeeping experiences, many participants took more preventative and systematic approaches to protect the counseling profession, students, and future clients by preparing for future intense gatekeeping encounters. Participants reported processing their feelings about gatekeeping as well as reassessing individual responsibilities plus program and university polices to better align with the ACA Code of Ethics (2014). Homrich (2009) suggested that faculty, including adjunct instructors and clinical supervisors, should plan for challenges that may arise when gatekeeping students. Multiple faculty stressed that their admissions decision making and criteria for new students were improved as a result of their emotionally intense gatekeeping. For instance, faculty reported recognizing rigid beliefs and concerning behaviors more quickly during admissions interviews and when students were starting their graduate training (Swank & Smith-Adcock, 2014.) Participants also reported how changes in gatekeeping practices at the individual (e.g., confronting problematic behaviors quicker), institutional (e.g., discussions with provosts and deans about professional ethics and gatekeeping practices), and professional (e.g., publishing articles) levels often took time and focused effort to change perceptions among stakeholders and others connected to their programs.

Implications for Counselor Educators and Counselors
     Based on our findings, we noted several implications for counselors and counselor educators. First, counselor educators should consider how doctoral training programs can facilitate learning related to emotionally intense gatekeeping experiences that include discussion of students’ potential emotional reactions to gatekeeping. Doctoral students may benefit from more transparency among current counselor educators in discussing their emotionally intense gatekeeping experiences. Discussions may help normalize how maintaining professional relationships with students and navigating intense emotions can be useful learning experiences during their doctoral training. Doctoral student gatekeeping training may inadvertently create dual relationship conflicts between master’s students and doctoral students if there are pre-existing relationships. Although a faculty mentor’s sharing of a student’s gatekeeping context may help doctoral students learn, faculty should balance this with the need to maintain the student’s confidentiality (Rapp et al., 2018).

Furthermore, more mentorship for future and beginning counselor educators regarding emotionally intense gatekeeping experiences may help alleviate adverse feelings. Departmental discussions of gatekeeping policies, a culture of openness, and mentorship from senior faculty (Homrich, 2009) can help reduce feelings of isolation, anger, sadness, betrayal, and other negative emotions for future and inexperienced faculty. Over half of participants mentioned mentorship from experienced faculty as support that helped them manage feelings of stress, anxiety, and fatigue during emotionally intense gatekeeping experiences. In addition, several participants in this study, regardless of prior experience with emotionally intense gatekeeping, sought consultation and comfort from other faculty within their departments. Counselor education programs should have a designated mentor for faculty who may feel overwhelmed with an emotionally intense gatekeeping experience and keep open lines of communication for all faculty (Homrich & Henderson, 2018). Of note, two participants expressed that they were aware of colleagues at other institutions who were unable to find encouragement and mentorship while imbued in intense gatekeeping, and those faculty either found other jobs or left the profession entirely.

Third, participants in this study experienced challenging and intense emotions surrounding legal proceedings. Counselor educators and clinicians should consider that lawsuits related to gatekeeping, impairment, and professional competence are on the rise (Schuermann et al., 2018). Counselor educators and counselors in the field should be better prepared for lawsuits and retain legal counsel, consult with colleagues, utilize personal counseling, and take other protective and therapeutic measures (Gaubatz & Vera, 2002). In addition, counselor educators and counselors may want to utilize self-care strategies to help bracket and monitor their emotions to allow for clear thinking and more ethical and intentional decision making if confronted with a lawsuit (Dugger & Francis, 2014).

     This study has three limitations. First, only three participants had less than 10 years of experience. Because perspectives, practices, and philosophies on gatekeeping can differ with experience (Schuermann et al., 2018), early counselor educators may have different experiences of emotionally intense gatekeeping. Second, only one participant in this study identified as an adjunct instructor. As institutions of higher education increase the number of their courses taught by non–tenure-track faculty, perspectives from adjuncts, lecturers, instructors, and other non–tenure-track training professionals, who are held to the same ethical standards and gatekeeping expectations, may be warranted. Likewise, site supervisors can play a vital role in the gatekeeping process and their perspectives on gatekeeping are important as well. Finally, given the complex and ongoing nature of emotionally intense gatekeeping experiences reported by participants, another data source (e.g., follow-up interviews) and more letters from participants might have provided a more thorough understanding of emotionally intense gatekeeping experiences.

Implications for Future Research
     This study was a first step in describing counselor educators’ emotionally intense gatekeeping experiences. Researchers of future studies might explore faculty groups’ collective emotionally intense gatekeeping experiences through focus groups. More understanding of how counselor education programs collect and document student information, make gatekeeping decisions, develop gatekeeping policies and procedures, and rely on gatekeeping-related ethical codes and standards are needed. Additionally, insights from adjunct instructors and clinical site supervisors who have experienced emotionally intense gatekeeping or students who have successfully completed remedial plans may provide unique perspectives on gatekeeping. Understanding how students navigate remediation plans and their emotional reactions to them may inform counselor educators and the profession as to what matters most to students and how to better reach them (Foster et al., 2014). Similarly, site supervisors often have more knowledge of students’ work with clients than counselor educators and may be an underutilized resource in gatekeeping practices. Finally, more research on counselor educators’ experiences with legal proceedings are warranted. Although several legal cases have generated considerable attention (see Plaintiff v. Rector and Board of Visitors of the College of William and Mary, 2005; Ward v. Wilbanks, 2009), this study seems to be the first that qualitatively explored counselor education faculty members’ experiences specifically with legal encounters. How counselor educators balance lawsuits and professional responsibilities, the prevalence of lawsuits against counselor education faculty for gatekeeping practices, and counselor educators’ levels of legal preparedness are rich topics for future study.


In conclusion, findings of this transcendental phenomenological study reveal the intense emotions counselor educators may experience when gatekeeping. In support of others’ research (Kerl & Eichler, 2005; Wissel, 2014), participants felt intense emotions such as anger, sadness, frustration, and vulnerability, as well as empathy for the affected students. Emotionally intense gatekeeping experiences seem time-consuming, usually involving multiple faculty members and administrators, as well as sometimes requiring legal counsel. The findings reveal how faculty should moderate their emotions and uphold ethical standards while engaging in emotionally intense gatekeeping. Finally, emotionally intense gatekeeping experiences can inspire counselor educators to revise their program policies, syllabi, and approaches to gatekeeping practices.


Conflict of Interest and Funding Disclosure
The authors reported no conflict of interest
or funding contributions for the development
of this manuscript.



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Daniel A. DeCino, PhD, NCC, LPC (Colorado), is an assistant professor at the University of South Dakota. Phillip L. Waalkes, PhD, NCC, ACS, is an assistant professor at the University of Missouri–St. Louis. Amanda Dalbey, MA, graduated from the University of South Dakota with a master’s degree in clinical mental health counseling. Correspondence may be addressed to Daniel DeCino, 414 E. Clark St., Vermillion, SD 57069, daniel.decino@usd.edu.

Teaching Gatekeeping to Doctoral Students: A Qualitative Study of a Developmental Experiential Approach

Brenda Freeman, Tricia Woodliff, Mona Martinez


In addition to developing teaching, clinical supervision, and research skills, new entrants into the counselor education workplace will also face the challenging responsibility of gatekeeping. Gatekeeping can be both anxiety-provoking and time-intensive for new faculty members. To enhance the confidence and competence of new entrants into counselor education faculty positions, strong doctoral preparation in gatekeeping is critical. In this article, the authors describe a developmental experiential model to infuse gatekeeping instruction into counselor education and supervision doctoral courses. The model includes six experiential gatekeeping modules designed for instruction at three developmental levels. A phenomenological qualitative study of the model was conducted, leading to the discovery of four themes: importance of gatekeeping, behind the curtain, understandings vary by developmental level, and uneven responses to experiential learning. Developmental, pedagogical, and administrative implications for counselor educators are discussed.   

Keywords: counselor education, gatekeeping, doctoral preparation, experiential model, phenomenological


For new entrants into the counselor education higher education workplace, involvement in gatekeeping can be unavoidable and challenging. Although direct gatekeeping responsibilities may be conducted by associate and full professors in many institutions (Schuermann et al., 2018), assistant professors often teach courses in which gatekeeping issues arise. Evidence suggests that faculty perceptions of gatekeeping differ by academic rank (Schuermann et al., 2018), with untenured professors reporting greater concerns about gatekeeping than tenured faculty (Gaubatz & Vera, 2002). Bodner (2012) asserted that “faculty and supervisors may receive little guidance on how to implement such [gatekeeping] procedures in a highly ethical manner and/or how to approach complex and challenging gatekeeping dilemmas” (p. 60).

The gatekeeping role is taught during doctoral preparation. In the doctoral standards set by the Council for Accreditation of Counseling and Related Educational Programs (CACREP), Section B (Doctoral Professional Identity) requires the instruction of students in five core areas, two of which (teaching and supervision) include gatekeeping standards (CACREP, 2015). Supervision standard 2.i. requires programs to include in the curriculum “evaluation, remediation, and gatekeeping in clinical supervision” (CACREP, 2015, p. 35). Teaching standard 3.f. states that the curriculum must include “screening, remediation, and gatekeeping functions relevant to teaching” (CACREP, 2015, p. 36). The inclusion of gatekeeping in CACREP standards signals the importance of providing doctoral students with the knowledge, skills, and experiences necessary for them to be effective in their future role as gatekeepers.

There is a dearth of literature on pedagogy for teaching gatekeeping to doctoral students. Barrio Minton et al. (2018) conducted an analysis of select published articles and concluded that there has been a lack of focus on doctoral-level counselor education preparation. With limited publications centered on doctoral preparation and a generally minimal focus on pedagogy, the instructional approaches to prepare doctoral students for gatekeeping are largely unknown.

The purpose of our study was to design and deliver a developmental experiential model for increasing doctoral student competence in gatekeeping and to examine student reactions to these learning experiences. We have titled the gatekeeping instructional approach the Developmental Experiential Gatekeeping (DEG) Model. The DEG Model was designed and implemented at one CACREP-accredited counselor education and supervision (CES) doctoral program in the Western United States with a focus on preparing students for academic positions. This article presents the results of a phenomenological qualitative study of the experiences and reactions of doctoral students to the DEG Model. The insights gleaned from the study are discussed from the standpoint of improving pedagogy for gatekeeping instruction. The rationale for the study was that gatekeeping is a challenging aspect of counselor education teaching and supervision roles, particularly for new entrants into academia. Effective preparation in gatekeeping practices may not decrease the strain of dealing with difficult student remediation, suspension, and potential legal issues, but preparation is necessary to bolster strong gatekeeping and remediation practices.

Developmental Framework With Experiential Pedagogy

The DEG Model is an approach to instructing doctoral students in gatekeeping through the delivery of six curricular units divided into three developmental levels. The model was developed and implemented at a midsize institution (classified in the Carnegie system as an R1: Doctoral University – Very High Research Activity) with three counseling master’s programs and a doctoral program in counselor education and supervision located in the Western region of the United States. All programs were fully accredited under the CACREP 2016 standards (CACREP, 2015).

The DEG Model is grounded in both developmental and experiential pedagogy. The developmental framework, based in cognitive developmental theory, endorses sequential movement in learning processes within an established hierarchy (Bloom, 1956; Loevinger, 1976; Piaget, 1977). Higher levels are not attained without first accomplishing less complex levels of cognitive understanding. The development of formal operations, in which more sophisticated connections and abstract concepts are understood, is gradual and is based upon the interaction between cognition and experiences (Case et al., 2001; Eggen & Kauchak, 2001). Formal operations are situation specific (Eggen & Kauchak, 2001). Students may have reached formal operations in learning domains where they have a supporting framework of experiences, such as in post-internship counseling skills, and yet not function in formal operations in other content domain areas (such as research skills).

The experiential learning approach, reportedly a more powerful pedagogy than didactic instruction alone (Borowy & McGuire, 1983; Shreeve, 2008), is focused on gaining knowledge through direct experience. The process typically begins with preparation for the experience, followed by engaging in the experience, and culminating with reflection or testing of observations (Galizzi, 2014; Kolb & Kolb, 2009). Positive outcomes associated with experiential pedagogy include increased student engagement in the learning processes, improvements in cognitive functioning, greater acquisition of knowledge across a variety of subject areas (Galizzi, 2014; Greene et al., 2014; Tretinjak & Riggs, 2008), increases in historical empathy, improved critical thinking, and greater cultural open-mindedness (Greene et al., 2014). Borders et al. (1996) found didactic and experiential practices were related to a significant increase in student self-appraisal of supervision capacity. It is reasonable to assume that because experiential activities in supervision led to greater student competence, experiential activities in gatekeeping may also lead to greater student competence.

Research supports that experiential learning is an efficacious approach to teaching multicultural counseling (Kim & Lyons, 2003), particularly when the experiences closely emulate real world applications (Furr & Carroll, 2003; Granello, 2000). Although research on experiential learning related to teaching gatekeeping was not found, experiential learning in gatekeeping may be similar to multicultural counseling in that the experiential activities often used in the instruction of multiculturalism may be unfamiliar or uncomfortable for students. The DEG activities were unfamiliar experiences for doctoral students. Also parallel to instruction in multiculturalism, there is a gatekeeping culture that is unfamiliar to most doctoral students. Students must be introduced to the culture of gatekeeping, including the cultural norms and the development of a gatekeeping mindset.

Two assumptions were foundational to the pedagogy of the DEG Model. First, the authors assumed the DEG Model would have greater impact on student learning if delivered over more than one semester to allow time for integration of knowledge. Second, to maximize the advantages of experiential pedagogy, we assumed each DEG module should provide students with the opportunity for reflection after every experiential activity.

The DEG Model

The DEG Model was structured through a hierarchy informed by developmental principles (Bloom, 1956). Level 1 modules designed to meet the overall learning goal, To increase student understanding of concrete knowledge related to gatekeeping, dispositional assessment, and admissions, were delivered in a first-semester, first-year doctoral seminar course. Although experiential assignments were included with each module, the focus in Level 1 was on student acquisition of concrete knowledge (Bloom, 1956). The modules in Level 2 were integrated into an introductory course in clinical supervision and were designed to address Bloom’s Taxonomy (1956) comprehension and application levels. The learning goal for the Level 2 modules was To increase student knowledge and applied skills related to remediation and gatekeeping in clinical supervision. The Level 3 modules, designed to be consistent with Bloom’s Taxonomy (1956) analysis and synthesis levels, were infused into Doctoral Seminar II, a course with a focus on teaching pedagogy. The modules were designed toward the following goal: To develop student skills in analysis and synthesis of knowledge related to gatekeeping, with a focus on developing a systems understanding of gatekeeping. Each module described in the next section incorporated an experiential element and a written reflection.

DEG Modules
     The specific content domains for each module were driven by the literature. Table 1 includes descriptive material on the content for each module. The overall design of the DEG Model involved the infusion of six gatekeeping modules over a 16-month time frame in three sequential CES doctoral courses.


Table 1 

DEG Modules: Developmental Level, Content Domains, and Source Material

Level DEG Module Content Domain Examples of Source Materiala
Level 1, Module 1 Grappling With Gatekeeping Through Dialogue Purposes and processes of gatekeeping; rationale for gatekeeping; ethics in gatekeeping; licensure boards and accreditation bodies and gatekeeping Bodner, 2012; Brown, 2013; American Counseling Association, 2014; Council for the Accreditation of Counseling and Related Educational Programs, 2015; Lumadue & Duffey, 1999
Level 1, Module 2 Professional Fit and the Prevention of Future Adversity: Dispositional Assessment in Admissions Admissions procedures in counselor education; suitability and dispositional assessment; impairment and problematic dispositional behaviors; dispositional assessment approaches Elpers & FitzGerald, 2013; Swank & Smith-Adcock, 2013; Winograd & Tryon, 2009; Brear et al., 2008; Tate et al., 2014; Reddy & Andrade, 2010; Taub et al., 2011; Swank et al., 2012; McCaughan & Hill, 2015


Level 2, Module 1 Gatekeeping Issues in Clinical Supervision Through the Lens of the Discrimination Model Supervisor roles in gatekeeping; giving feedback to supervisees; evaluation of supervisees; discrimination model


Association for Counselor Education and Supervision Taskforce on Best Practices in Clinical Supervision, 2011; Swank, 2014; Gazzola et al., 2013; Gizara & Forrest, 2004; Miller, 2010; Bernard, 2006; Bhat, 2005
Level 2, Module 2 Mentoring Students Through Monitoring Remediation Designing and monitoring remediation plans Dufrene & Henderson, 2009; Henderson, 2010; Kress & Protivnak, 2009; Lamb et al., 1987; McAdams et al., 2007; McDaniel, 2007; Russell & Peterson, 2003; Bemak et al., 1999; Crawford & Gilroy, 2013; Russell et al., 2007
Level 3, Module 1 Gatekeeping Through a Systems Lens: Designing an Ecological Gatekeeping Map Ecological model and gatekeeping; collaboration and teaming in gatekeeping; shadow organization; higher education culture Forrest et al., 2008; Johnson et al., 2008; Jacobs et al., 2011; Goodrich & Shin, 2013


Level 3, Module 2 The End of the Road: Gatekeeping and Heartbreaking Adversity Legal issues in gatekeeping; due process; working with legal counsel; documentation; managing grievances Brown-Rice, 2012; Elpers & FitzGerald, 2013; Enochs & Etzbach, 2004; Forrest et al., 1999; Frame & Stevens-Smith, 1995; Homrich, 2009; Hutchens et al., 2013; Kerl et al., 2002; McAdams et al., 2007

aSource materials appear in order of recommended reading.


Grappling With Gatekeeping in Level 1, Module 1
In this module, for three consecutive classes (9 clock hours), first-year students were required to read and discuss journal articles on foundational gatekeeping topics selected by second-year students with guidance from the instructor. The structured class instruction and discussions on the readings were facilitated by the second-year students. The experiential component for first-year students was engagement in structured dialogue. The experiential component for second-year students was teaching gatekeeping and leading discursive discussion with first-year students under live faculty supervision. Students then reflected on the process. 

Dispositional Assessment in Admissions in Level 1, Module 2
     Armed with background knowledge from Module 1, students participated in the dispositional assessment training video for the Professional Disposition Competence Assessments—Revised Admissions (PDCA-RA; Freeman & Garner, 2020; Garner et al., 2020). The training video entails participant ratings of dispositions during admissions interview clips without training, followed by training in the assessment process, post-training rating of interview clips, and instructions on use of the PDCA-RA in actual admissions interviews. Following the PDCA-RA training, the doctoral students co-interviewed (with CES faculty) the master’s program applicants, using the PDCA-RA as the admissions dispositional assessment tool. This was followed by written reflections about the experience.

Gatekeeping Issues in Clinical Supervision in Level 2, Module 1
     This module was preceded by several weeks of instruction in clinical supervision theory and the assignment of one master’s-level supervisee to each doctoral student. Midway through the semester, students were instructed in best practices for giving evaluative formative and summative feedback in clinical supervision through the lens of the discrimination model (Bernard, 1997). The experiential component of this module consisted of students being required to deliver either formative or summative (positive or corrective) evaluative feedback to clinical supervisees related to the expected student dispositions under faculty supervision. Students then reflected on the process.

Mentoring Students Through Monitoring Remediation in Level 2, Module 2
     This module was designed to provide doctoral students with an experiential opportunity to partner with faculty in providing support for master’s students working on mild remediation issues. Examples of mild remediation issues included problems with class attendance or punctuality, difficulty adjusting to the professional expectations of graduate school, and challenges with interpersonal relationships in the classroom. The faculty team working in concert with the master’s student needing remediation determined the nature of the specified growth experiences for the master’s student. The doctoral students then implemented structured processes to support the remediation process, such as facilitating a reflective process on a student’s effort to become more culturally sensitive or serving as an accountability partner for a student working to become more conscientious. Doctoral students were not involved in working with any students where dismissal was a likely outcome. Doctoral students then wrote journal reflections on the experience.

The Ecological Gatekeeping Map in Level 3, Module 1
     With the developmental goal of synthesizing complex knowledge, students were tasked with creating an ecological gatekeeping map. The process began with didactic instruction in Bronfenbrenner’s (1977) ecological systems theory, followed by discussions of microsystems, mesosystems, exosystems, and macrosystems in higher education. The goal was to assist students in acquiring a systems perspective on gatekeeping, including subsystem interactions that influence the feasibility and outcomes of remediation, suspension, and dismissal of counseling students. As part of the module, students were introduced to the concept of the shadow organization (Allen & Pilnick, 1973). Allen and Pilnick (1973) described organizations as having two organizational structures—one being the visible structure obvious in the university organizational chart and the other (the shadow organization) consisting of the unwritten cultural expectations and daily behaviors of the institution. An example of the shadow organization influencing gatekeeping would be if the counseling handbook states that the program gatekeeps, but there is an unwritten culture in which the administration will not allow the program to dismiss even the most unethical student. Working as a team, the students had 6 weeks to interview administrators and faculty, collect policy and procedure documents, read and apply relevant literature, and prepare a group presentation of a visual ecological gatekeeping map.

Gatekeeping and Heartbreaking Adversity in Level 3, Module 2
     The final DEG module began with assigned readings of gatekeeping legal cases. Students were then charged with the responsibility to create a non-academic dismissal scenario, write and compile all documentation, and prepare to dramatize the scenario through a mock dismissal hearing. Roles adopted by students for the mock hearing included the fictitious master’s counseling student, the faculty member central to the dismissal scenario, the department chair, and the college dean. The mock hearing was enacted and was judged in real time by a university attorney and a university administrator (a dean or provost). Immediately following the hearing, the judges processed the hearing with the students, offering legal and procedural corrections. Students then reflected on the experience.


The question “What are the lived experiences of doctoral students as they engage in gatekeeping instruction?” was addressed through qualitative methodology. Because we were interested in the subjective experiences of the student learners, the qualitative study was conducted using a phenomenological approach (Creswell, 2013; Moustakas, 1994). Investigation through deep exploration of lived experiences is part of the phenomenological paradigm (Creswell, 2014). Deep exploration of lived experiences with the gatekeeping experiential activities was congruent with the goal of understanding the journey of doctoral students to capture the essential meanings of gatekeeping. Husserl (2001) postulated that it was possible for researchers to bracket their own experiences to capture the essence of the experiences of others, which was one of the objectives in this analysis. The ontological assumption, informed by the constructivist paradigm, was that socially constructed multiple realities of gatekeeping exist (Mertens & Wilson, 2012).

The study was primarily conducted as scholarly inquiry into the developing professional identity of doctoral students relevant to the gatekeeping role. Aligned with the research question, the data analysis was accomplished through a phenomenological tradition, with a primary goal of revealing rich and concrete descriptions of the learning process and the translation of formal and experiential instruction into professional identity.

Subsequent to the analysis, the findings were also used to inform program development and pedagogy for counselor educators. This secondary use of the findings to inform program improvement is aligned with the values branch of program evaluation in which participant responses to program experiences are often viewed through a qualitative, constructivist perspective (Abma & Widdershoven, 2008). The use of the findings to inform counselor education pedagogy did not influence the interview protocol, data collection, or analysis process, which were conducted utilizing the phenomenological approach.

     For phenomenological studies, Creswell (2013) recommends between 3 and 15 participants. At the point of data collection, there were 12 students enrolled in the CACREP-accredited counselor education and supervision doctoral program where the DEG modules were delivered. The doctoral program was housed in the College of Education at a midsize university, classified in the Carnegie system as an R1: Doctoral University – Very High Research Activity.

Each of the 12 potential doctoral student participants had experienced some or all of the DEG modules, allowing the research team to gain insights from different levels of doctoral student professional identity development. Two students were removed from the participant pool because of a conflict of interest, yielding a participant pool of 10 students. Following human subjects research review board (IRB) approval, the 10 potential participants were contacted by email and invited to participate in the study. All 10 consented to be interviewed; however, one student was unavailable during the data collection window, leaving nine study participants.

As a precaution to mask the identity of the participants, specific demographics are not reported in this article. In general terms, the participants were primarily self-reported females, predominantly White, and ranged between 24 and 39 years old. Educationally, all participants had earned master’s degrees in counseling prior to entering the doctoral program. The students earned their counseling master’s degrees in institutions located in the West, South, Southwest, East, Midwest, and Rocky Mountain regions.

     All nine doctoral student participants agreed to be interviewed and to allow electronic recording. Face-to-face interviews ranging in length from 30 to 60 minutes were conducted by a single member of the research team. No incentives were offered. Participants were informed that they could skip any of the interviewer questions. The items for the semi-structured interview protocol were first written by the lead author and then piloted with the second and third authors. The final items were determined by consensus of the research team. The interview protocol included nine items. Three were global items such as “Describe your learning experiences with gatekeeping and remediation in counselor education.” Of the remaining six items, each was dedicated to one of the DEG units. The interviewer first asked the student if they recalled having participated in the specific unit, followed by the prompt: “Please describe your experience with this unit. What was that learning experience like for you?” The same question was repeated for each of the six units.

Although the DEG Model was part of required coursework, participation in the study was strictly voluntary. To protect student participants from social pressure to participate in the study, all communications with participants were initiated by a single member of the research team with no evaluative relationship to the students. Further, the interviews were conducted during a time frame when no participants were enrolled in courses instructed by any member of the research team.

As a second source of data, student reflections were collected at the end of each unit. The reflections were ungraded and were used in the study to triangulate the interview data for the purpose of considering the consistency between the interview data and the reflections, part of the establishment of trustworthiness. The reflection data consisted of written, open-ended reflections on the experiences of students with each of the DEG modules. The reflections were submitted immediately following the experience with each DEG module. To scaffold the reflection process for students who found unstructured, open-ended reflections challenging, three prompts were offered: “Please share your reactions to the learning experience you engaged in today.” “What did you learn today that you consider to be important to your understanding of gatekeeping and remediation?” and “What questions come to mind as a result of engaging in this learning experience?”

Data Analysis
     The overarching purpose of the data analysis process is to bring structure and order into understanding the data for the purpose of addressing the research questions (Patton, 2015). In phenomenological research, there are many paradigms and differing worldviews on data analysis, including the issue of whether it is most suitable to analyze participant narratives through an ideographical approach or amass the data into qualitative themes (Moules et al., 2015). Accumulation of data with an analysis of themes was selected as the phenomenological data analysis approach. The results of the study were analyzed through Creswell’s (2014) approach to phenomenological analysis. Throughout the analysis, the research team bracketed their presuppositions and assumptions. The purpose of bracketing was to allow the voices of the participants, not the researchers, to dominate the analysis.

Following the interviews, the recordings were transcribed (using pseudonyms), and the transcriptions were reviewed for accuracy. The analyses of both the interviews and the reflections were conducted using NVivo12 (QSR International). The interview analysis was a three-part process that included open coding, thematic analysis, and thematic integration (Rossman & Rallis, 1998). The process began with reading and rereading the transcripts to deduce a list of core meanings for each transcript. This work was conducted by the lead author and verified by independent analysis of the second author. Once core meanings of individual transcripts were agreed upon, the meanings were cross-analyzed for repetition and clustered into themes and subthemes by the first and second authors working independently of one another. Team consensus was reached, and the data were then organized into a codebook. Data saturation was accomplished when it was determined that no new themes were emerging. The themes were then reviewed in relation to one another to clarify overlapping areas and collapse subthemes into broader themes. Direct quotes were extracted to support both textural and structural descriptions. After the analysis of the interview data, student reflections were analyzed using the codebook derived from the interview data. An “inconsistent” codebook category was created to code data inconsistent with the data found in the interviews. An “other coding” category was created to code data that reflected new concepts or themes not apparent in the interview data.

     An important aspect of considering trustworthiness in phenomenological research is addressing bias (Creswell, 2013). The research team consisted of two White female researchers and one Hispanic and American Indian female researcher. One was a tenured full professor with extensive CES experience. Another had conducted research related to dispositional assessment. The third member of the research team had no specific background or personal experiences with gatekeeping. The team members had a wide range of experience in program evaluation and qualitative research. The shared assumptions of the research team were that understanding gatekeeping was an important professional obligation and that doctoral students with career aspirations of entering counselor education needed a solid foundation in gatekeeping.

     The process of establishing trustworthiness began with an understanding that the findings represented only one of many interpretations of the data (Corbin & Strauss, 2008). Early in the process, we consulted with a qualitative research expert who confirmed the analysis process (D. Barone, personal communication, December 2, 2018). Peer debriefing was used throughout the process (Creswell, 2014). The debriefing process included the research team presenting tentative findings at one regional and one national counselor education conference, a process that fostered research team deliberation on the interpretation of the data.

The areas for bracketing were identified prior to the interviews and consisted primarily of the delineation of the presuppositions and assumptions of the research team in order to avoid hindering the capacity of the team to listen to the participants. The actual bracketing was performed during the analysis stage by making notations of areas where presuppositions and assumptions might influence interpretation. Participants were not asked to bracket their assumptions. Direct quotes were heavily relied upon in the analysis to assure that the voices of the participants were heard throughout the process. An expert reviewer, a counselor educator not involved in the study, audited the results (Creswell, 2014; Patton, 2015), providing the team with feedback. Last, member checking was used to ascertain that we had not misunderstood or used participant statements out of context.


The analysis yielded four themes: importance of gatekeeping, behind the curtain, understandings vary by developmental level, and uneven responses to experiential learning. Pseudonyms used during data collection were replaced with participant numbers for reporting purposes.

Importance of Gatekeeping
     The theme importance of gatekeeping describes the valuing of gatekeeping, remediation, and dispositional assessment by participants. Across all participants, gatekeeping and related processes were perceived as critically important. The rationale for valuing gatekeeping varied from participant to participant, with most offering more than one justification. Five participants positioned their responses within the professional mandate to protect the public. P1 stated:

I learned that some of my experiences as a counselor really influenced the importance that I put on gatekeeping . . . I’ve been doing counseling . . . so I had exposure to what it looks like when counselors in the field aren’t well suited or act from their own personal needs.

Two participants reflected that the protection of the public was particularly important because of the attraction of emotionally wounded individuals to the profession. As stated by P2:

[Gatekeeping and remediation] . . . are extremely important because people oftentimes I find go into the counseling field for the wrong reasons. Whether it’s a personal history with mental health issues and they’re trying to solve their own issues or because. . . maybe they like the power differential that is created in a helping relationship . . . they want to somehow take advantage.

Protecting counseling programs, universities, and the profession was also expressed as a reason for valuing gatekeeping. P3 stated: “The counseling profession is our own and needs to be protected,” later adding, “Despite how difficult it can be, if warranted, I want to play hardball to protect my students, other faculty, alumni, program, and the profession.”

Behind the Curtain
     Eight of the nine participants reported that they had limited awareness of gatekeeping and related processes in their master’s programs. P4 stated: “I mean, I’m sure we were gate checked in my master’s program, but I don’t really remember anything about it.” Participants discussed the process of learning about gatekeeping after the experience of being unaware of it in their master’s programs, noting that this process gave them a glimpse of what goes on behind the curtain. P9 described it as being given a different seat in the house, stating:

In my master’s program, I didn’t have any knowledge of anything like this . . . but now in my first year of the doctoral program, I feel like I have so much more of an understanding and kind of . . . like a different seat in the house. I can see how it all works and the importance of it.

Feelings associated with peeking behind the curtain were varied. P3 described it with positive affect: “So the first seminar class was really helpful. It was very much like the Wizard of Oz, pulling the curtain back and seeing what goes on behind everything in higher education.” P4 reported it to be an unsettling experience: “So our first year when we were learning about it, it was still a bit mysterious . . . kind of scary . . . I didn’t really know this process was going on . . . not like, so overtly. . . . it was kind of like, oh my God.”

Understandings Vary by Developmental Level
     All participant interviews reflected the theme understandings vary by developmental level. Some participants overtly addressed changes in developmental understandings, like P3, who said simply: “I thought it was tricky until it wasn’t.” She described her journey as becoming more comfortable over time. P5 reported: “I think the scaffolding was appropriate. . . . more content focused initially and then more at the process level with the application piece later on. It wasn’t like we were jumping right into applicability before we actually understood the different concepts.”

From the standpoint of developmental level, Level 1 students like P6 were inclined toward a concrete understanding of the concepts: “So my understanding of gatekeeping and counselor education is that it’s a process to make sure that the counseling students are where they’re supposed to be . . . academically and emotionally.” More advanced students like P1 reflected greater complexity in their understandings:

So part of our responsibility as counselors is to make sure the field is engaging ethically, and if we’re allowing people that are wounded in such a way that they’re not able to engage productively as counselors, then as a profession we’re acting essentially unethically. . . . Counseling is fundamentally about the person of the counselor and so we have to take that into account as counselor educators . . . gatekeeping or remediation become a big part of the more nebulous component of what makes a good counselor.

Another developmental issue was that the experiential frame or voice reflected by the participants varied throughout the process. Sometimes, particularly but not exclusively early in the developmental process, participants spoke with a student voice. At other points, participants reflected on their experiences through the perspectives of a clinical supervisor or counselor educator, reflecting a faculty voice. Sometimes participants shifted between the two voices. P5 directly addressed this issue:

So each of us was going through the process of being evaluated because there was a gatekeeping process for us as doctoral students . . . and so knowing that that was happening for us at the same time we were teaching it . . . it was just a pretty complex process.

P4’s comment on learning to give direct feedback in the clinical supervision unit reflects a conflicted voice:

But with a supervisee, it was different because you’re also in this evaluative role. . . . I wanted to like, be really supportive, you know . . . [but] I also had to evaluate their work. I wanted to be direct, but I also don’t want to give them a bad evaluation. It was just very difficult.

In this statement regarding the Level 1 module, P8 spoke through a counselor educator perspective:

I’m thinking about potentially becoming a faculty member . . . in interviewing at universities, I’d like to really try to understand their philosophy of gatekeeping and remediation to see if it could, like, be a good fit for me. If I went to a school and found out they didn’t do gatekeeping, I would have a really hard time being there . . . it’s just kind of like, “Well, what are we doing to ensure that the people we’re serving are protected?”

Uneven Responses to Experiential Learning
     Across all nine interviews, participants indicated a strong, positive response to experiential learning. However, some experiential elements were more powerful than others. Reflecting on the experience of participating in the PDCA-RA training video and the master’s admissions interviews, P7 stated: “I think it was just really, really fun to be a part of the training . . . and then to actually get the chance to do it again during admissions.” Teaching gatekeeping was described as a positive experience by P4:

Being forced to teach anyone anything is a good learning experience . . . a lot of pressure is on me. Like, oh, I really, really need to know this stuff so I can teach it pretty well. So, I definitely knew my presentation . . . so that was a good learning experience.

In relation to the mock hearing, P5 reflected: “I learned a lot. I was actually the student in the mock hearing and so I learned . . . from their perspective what they might experience, but I also learned from the other side of it too, from the institution side.”

Not all experiential activities were considered impactful. Three participants reflected that the remediation experiential module was confusing. The confusion may reflect on the module but could also be related to the concept that remediation is not a science and requires judgment, experience, and consultation with others. Stated by P8: “It was hard for me to tell [if the student made improvements] because I didn’t have like a clear baseline.” P1 reported: “I mostly ended up just having confusing conversations with the student.”

The ecological gatekeeping map also appeared to be lacking in experiential power. Although the group experience of working together on the module was deemed valuable, three participants could not recall what they learned from the experience. A word count showed participants gave shorter descriptions on the ecological map than on any of the other experiential units. It is possible that a deeper level of preparation in the ecological model would enhance the experiential learning. Understanding the system elements of higher education and how they overlap with gatekeeping is fraught with complexity, even for junior faculty.

Analysis of Reflections Data
     The data from the reflections were used to triangulate the interview data. In general, there was a high level of consistency between the reflections (submitted immediately following the modules) and the qualitative interviews (conducted after a time lapse). One interesting finding more evident in the reflections than in the interviews was the description of the emotional reactions to gatekeeping material. At the end of the analysis process, we created word clouds (pictorial displays of word frequencies) of the most common words used by participants. Through this process, we discovered there was a high frequency of a minimum of 12 emotionally laden words such as “scary” and “upsetting” in the data set, with more emotionality expressed in the reflections than in the interviews. Because the reflections were written, it appears that students were more likely to express emotional reactions in reflections than in the qualitative interviews. It is also possible that because the reflections were collected right after the experiential learning activities, emotional reactions were more accessible when the students wrote their reflections than at the time of the interviews.

Discussion and Implications

The CACREP expectation that counselor educators instruct doctoral students in gatekeeping and the awareness that new entrants to the counselor education workplace may experience considerable distress in their roles as gatekeepers inspired the study. Although gatekeeping and remediation may require a relatively small time commitment for new counselor educators, the nature of the work can be difficult and legalistic. The predominant goals of the study were to develop and infuse into the doctoral curriculum an experiential model for gatekeeping instruction and to gain insights into the lived experiences of doctoral students as they engaged in the learning modules.

The DEG Model is presented as one approach to doctoral instruction in gatekeeping. The experiential and developmental foundations for the approach are strongly supported in research, but literature on the application of these theories to the context of teaching gatekeeping to doctoral students was not available. Thus, the DEG Model and the qualitative study of the student learning experiences with the model are exploratory in nature. Nine students reported their perceptions and reactions to the DEG Model. An analysis of the lived experience of the students led to the discovery of four themes: importance of gatekeeping, behind the curtain, understandings vary by developmental level, and uneven responses to experiential learning. 

All nine participants were of one mind that gatekeeping, dispositional assessment, and remediation are important. Given that all nine students were from different master’s programs representing institutions located in various regions of the country, this finding suggests that gatekeeping has assumed a position of primacy as an essential function in counseling academic programs and an expected role for counselor educators. Earlier gatekeeping research reported hesitancy in trainees related to gatekeeping because of factors such as program culture, lack of protection for the gatekeepers, and confusion about the standards for gatekeeping (Shen-Miller et al., 2015). The results of this study suggest a possible shift in the perspective of new entrants to the counselor education workplace. In addition, state licensure boards have underscored the importance of gatekeeping the profession. Shen-Miller et al. (2015) also found that trainee ambivalence about the gatekeeping role mirrored faculty ambivalence, suggesting that faculty modeling of appropriate gatekeeping and remediation may be a critical factor in the changing attitudes of doctoral students. An alternative viewpoint is that though the students unanimously supported a belief that gatekeeping is important, their belief system may not translate well to their first actual gatekeeping situation as a counselor educator. The study participants had no direct experience with the often painful situations faculty face when legal action or student grievances are directed against them.

The behind the curtain theme illuminated the lack of transparency in gatekeeping, in that students were surprised by the gatekeeping processes. The finding is puzzling because remediation and gatekeeping literature encourages transparency in identification of dispositions, remediation processes, and reasons students might be dismissed from any given academic program. Perhaps for legal or other reasons counselor education programs are somewhat opaque in their explanations of gatekeeping.

The results provide support for delivering content in gatekeeping through developmental and experiential approaches. Consistent with developmental theory (Piaget, 1977) and findings in doctoral instruction in clinical supervision instruction (Baker et al., 2002; Granello & Hazler, 1998), students began the process with concrete understandings and moved toward more complex interpretations. Also, mirroring other studies in doctoral pedagogy (Dollarhide et al., 2013; Granello & Hazler, 1998), students attributed learning to engagement in experiential activities, rarely referencing lectures or reading assignments except as sources of foundational knowledge.

Aligned with developmental theory (Piaget, 1977), we learned that experiential learning must be carefully cross-walked to parallel to the developmental level of the participants. Two of the six modules (Mentoring Students Through Monitoring Remediation and Gatekeeping Through a Systems Lens: Designing an Ecological Gatekeeping Map) contained experiential elements that in retrospect the authors believe were not well aligned with the developmental levels of the students. Regarding the remediation module, at the time of the study, the doctoral students were working to embrace the new roles of teacher, researcher, and clinical supervisor. Adding the difficult-to-define role of remediation mentor was perhaps experienced as role overload. On the ecological map, the authors hypothesized that the task was too complex, requiring more didactic instruction and experience with systems in organizations.

The finding that two experiential elements were perhaps not targeted at the designated developmental level was less critical than the underscoring of the importance of conducting research on pedagogy in doctoral-level courses. Until conducting the study, we were unaware that the two experiential units were problematic and would have argued that the ecological gatekeeping map was one of the strongest experiential components in the DEG Model.

Implications for Counselor Education
     The findings of the study led to insights that inform program development and pedagogy for counselor educators. The values branch of program evaluation (Abma & Widdershoven, 2008) advocates the use of qualitative analysis to develop deeper understandings of how knowledge is constructed.

The finding that doctoral students expressed more emotion in the immediate aftermath of experiential activities reinforces the importance of prompt attention to emotional processing after experiential components. The emotional–motivational theory on learning posits that anxiety negatively impacts concentration and desired outcome as well as reduces interest in engaging in future learning experiences in the content area. This relationship is well documented in research on math anxiety (Passolunghi et al., 2019). Anxiety was expressed in some student reflections, but not unexpectedly, as gatekeeping can be laden with conflict.

The results point to several practical pedagogical issues referred to in program evaluation theory by Stufflebeam (2003) as input factors. One such factor is that experiential pedagogy requires more instructional time than didactic instruction. The authors concluded that the importance of gatekeeping and the overall positive results justified the time investment but recognize the difficulties involved in implementing time-intensive experiential activities. The findings reflect another counselor education input issue, which is the importance of building strong relationships with administrators and the legal department in order to offer students the opportunity to gain perspectives on gatekeeping from stakeholders outside the core counseling faculty. The End of the Road: Gatekeeping and Heartbreaking Adversity module could not be implemented without strong relationships with administrators and legal services.

The unique contributions of this study for counselor educators include an underscoring of the importance of instructing doctoral students in gatekeeping and the power of using experiential strategies. The interview data showed that students initially had a concrete interpretation of gatekeeping, but through participation in the experiential modules, they reported more comprehensive understandings. The importance of matching the learning experience to the developmental level of the student has been previously well established in developmental theory, but through the study we gained the insight that doctoral instruction in gatekeeping should begin at a concrete developmental level. The doctoral students in our study may have been advanced in terms of clinical and research skills, but their initial understanding of gatekeeping was unidimensional.

The study also underscores the importance of helping students reflect and identify their individual belief systems and personal approaches to gatekeeping. Although legal services may recommend that faculty consistently speak in one voice on gatekeeping issues, an essential first step in eventually developing departmental consensus is transparency between individual faculty on their differing perspectives. Beyond the department level, this ongoing conversation is also foundational to growing the profession in our collective understanding of gatekeeping. The study highlights the importance of starting this process at the doctoral student level.

Limitations and Future Research

One limitation of the study is that qualitative research is not intended to be generalized. Therefore, it is unknown if the findings apply to doctoral students enrolled in other counselor education programs. Although there were advantages in utilizing a participant pool with different levels of engagement in the DEG Modules, a limitation associated with this research team decision was that participants who had only experienced early modules may have reflected different perspectives if they had been interviewed after participation in the final modules. Second interviews were not conducted. Another limitation is that the students, though not enrolled in courses from the lead author at the time of the study, may still have been influenced to offer a positive perspective on their learning experiences. Follow-up post-graduation interviews could be a useful mechanism to address this limitation.

A limitation inherent in the design of the DEG Model is that although the design was appropriate for the context of one CES doctoral program, it may not be applicable to the institutional environments of other CES doctoral programs. The context of a high research institution may differ from an institution with a stronger focus on teaching, which could influence student reactions to the DEG Model. A second limitation related to the model itself is that departmental agreement was necessary to infuse gatekeeping material into three courses with different instructors with differing personal values and beliefs on gatekeeping. In addition, agreement to include doctoral students in master’s remediation experiences and admissions interviews was necessary to implement the DEG Model. This level of faculty collaboration may not be possible in all doctoral programs.

More research on counselor education doctoral preparation is needed. The dearth of CES research on pedagogy for instructing doctoral students is apparent in content areas well beyond gatekeeping. Within pedagogy for doctoral student preparation in gatekeeping, research is needed on outcome measures for the attainment of gatekeeping competence. In addition, a greater understanding of the impact of the personal experiences of those doctoral students who were remediated during their master’s preparation on their perspectives as future gatekeepers would be useful to the profession. Also, research on the amount of instructional time needed to effectively teach gatekeeping to a level of minimum competence is needed.


Conflict of Interest and Funding Disclosure
The authors reported no conflict of interest
or funding contributions for the development
of this manuscript.



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*Swank, J. M., Lambie, G. W., & Witta, E. L. (2012). An exploratory investigation of the Counseling Competencies Scale: A measure of counseling skills, dispositions, and behaviors. Counselor Education and Supervision, 51(3), 189–206. https://doi.org/10.1002/j.1556-6978.2012.00014.x

*Swank, J. M., & Smith-Adcock, S. (2013). Creative group strategies for interviewing applicants for counselor education programs. The Journal of Counselor Preparation and Supervision, 5(1). https://doi.org/10.7729/51.0039

*Tate, K. A., Bloom, M. L., Tassara, M. H., & Caperton, W. (2014). Counselor competence, performance assessment, and program evaluation: Using psychometric instruments. Measurement and Evaluation in Counseling and Development, 47(4), 291–306. https://doi.org/10.1177/0748175614538063

*Taub, D. J., Servaty-Seib, H. L., Wachter Morris, C. A., Prieto-Welch, S. L., & Werden, D. (2011). Developing skills in providing outreach programs: Construction and use of the POSE (Performance of Outreach Skills Evaluation) rubric. Counseling Outcome Research and Evaluation, 2(1), 59–72. https://doi.org/10.1177/2150137811401019

Tretinjak, C. A., & Riggs, E. M. (2008). Enhancement of geology content knowledge through field-based instruction for pre-service elementary teachers. Journal of Geoscience Education, 56(5), 422–433.

*Winograd, G., & Tryon, G. S. (2009). Counseling expectations among students in an opportunity program: Dispositional and cultural influences. Journal of Counseling & Development, 87(4), 438–448.


Brenda Freeman, PhD, NCC, LCPC, CPC, is a professor at the University of Nevada, Reno. Tricia Woodliff, PhD, NCC, ACS, CPC, is an assistant professor at the University of Nevada, Reno. Mona Martinez, PhD, CPC, is Downing Clinic Director at the University of Nevada, Reno. Correspondence may be addressed to Brenda Freeman, William Raggio Building Rm. 3007, University of Nevada, Reno/0281, Reno, NV 89557, brendafreeman@unr.edu.

Legal and Ethical Challenges in Online Counselor Education

Donna S. Sheperis, Ann Ordway, Margaret Lamar


Counselor education has moved firmly into the online space with multiple accredited programs available to students and potential faculty. These programs can cross state lines, either by location of training, placement of faculty, or both. As such, there are legal and ethical considerations that are outside of those that are typically considered. This article addresses some of the more common legal and ethical considerations in counselor education, such as vicarious liability and cybersecurity, and how they differ in the online education environment. Licensure and other laws and obligations for educators are explored. Opportunities for gatekeeping are discussed through the lens of a case study. A second case study with guiding questions is provided to raise visibility of state differences in practice laws. Finally, helpful resources for navigating online counselor education from a legal and ethical perspective are offered.


Keywords: counselor education, online, legal, ethical, gatekeeping


There are many reasons to consider online education when becoming a counselor or choosing a career as a counselor educator. Convenience, accessibility, and opportunities to interface with colleagues across the country and around the world are common attractions of an online environment. As of the beginning of 2020, 79 online programs were accredited by the Council for Accreditation of Counseling and Related Educational Programs (CACREP; 2020). As many opportunities as there are in this educational space, legal and ethical challenges also exist. Although these challenges may be unique to the online world, they are certainly navigable. This article tackles some of the experiences distinctive to faculty and students in counselor education who choose an online environment for training.


Considerations for Online Counselor Educators


Counselor education is a distinct professional identity geared toward the preparation of professional counselors across disciplines (e.g., clinical mental health counselor, professional school counselor, substance abuse counselor). Counselor educators who teach in CACREP-accredited programs are required to have terminal degrees in counselor education and supervision, as opposed to psychology or another helping profession, as well as active involvement and participation in the counseling profession (Calley & Hawley, 2008). These educators receive training in five core areas, including counseling, supervision, teaching, research and scholarship, and leadership and advocacy, making them uniquely qualified to prepare master’s-level clinicians in counseling (CACREP, 2015).


Prior to the publication of the 2016 CACREP Standards, counselor educators may or may not have received training specific to online counselor education. And yet as of 2014, at least 67% of students in public universities took an online course (Allen et al., 2016). To attend to this emerging trend, CACREP recognized the need for all counselor educators to understand “effective approaches for online instruction” (CACREP, 2015, p. 35). Whether fully online or fully in person, most counselor education programs contain some online elements in their instructional pedagogy. Thus, the opportunities to teach and learn counseling in an online format are present regardless of whether the program is considered an online program.


For the purposes of this article, an online counselor educator is a person who provides some or all of their teaching via a distance education format (Stanford University Teaching Commons, n.d.). Most universities offer some form of training to assist the educator in moving to online education (Dimeo, 2017), but that training is not specific to the content of counselor education. With this in mind, some of the inherent opportunities and challenges in online teaching, specifically as they relate to legal and ethical concerns, including vicarious liability and supervision in online education settings, will be discussed.


Vicarious Liability as a Counselor Educator

The counselor education literature is replete with research related to vicarious liability in supervision (Mikkelson et al., 2013; Pearson, 2000; Sheperis et al., 2016). Essentially, vicarious liability refers to a situation in which one person is held responsible for the actions or inactions of another person (Bell, 2013). In counseling, we see this term most commonly used in relation to a clinical supervisor having some responsibility for the care of the clients of a supervisee.


This definition of vicarious liability does not make concessions for the manner in which clinical oversight is provided. In other words, online or not, clinical supervisors continue to carry vicarious liability for the clinicians they supervise. By extension, counselor educators serving as practicum and internship supervisors would also be held responsible for the services provided by students under the terms of vicarious liability. According to one popular provider of malpractice insurance for counselors, CPH & Associates (2019), liability insurance covers the holder for incidences of negligence, misrepresentation, violation of good faith, and inaccurate advice. The key term to consider is inaccurate advice, as that is how supervision could be characterized in a lawsuit.


The Counselor Educator as Supervisor and Gatekeeper

Slovenko (1980), in his seminal article on the topic of supervisor responsibility to the client, stated “litigation against supervisors may be called the ‘suit of the future’” (p. 468). Over the years, we have not seen that prophecy come to fruition in counselor education, but the caution remains that counselor educators who serve as supervisors must be mindful of their potential vicarious liability. With regard to the provision of online counselor education, the opportunities to supervise students who are seeing clients that are in different cities, states, or countries exist. Although this is an exciting development in terms of working with a variety of students, it is daunting to consider the legal implications.


Counselor educators may assume that only teaching didactic classes online and not supervising practicum and internship students will reduce their overall liability. But the reality is that all counselor educators have a responsibility to gatekeeping that extends to protecting potential future clients of the students we train. To that end, we must maintain an approach to our work that keeps the concept of vicarious liability in mind.


For example, in fully online programs, there is often a residency model. The residency is a period of time in which students gather for in-person training and observation, often of clinical skills (Holstun, 2018). Walden University, which trains counselors in a fully online format, describes residency as a time to “conceptualize and develop research that contributes to positive social change; establish networks of professionals who support and practice scholarly endeavors; [and] develop and refine practice skills essential to your profession” (2019, Mission and Vision section). That may occur at the university campusor a neutral destination depending on the type of institution. These residencies are opportunities to be physically present with students, uncover any clinical or dispositional concerns, and allow for multiple faculty to relate to students. Although some of this is clearly possible in a fully online format, the majority of online programs opt for at least one in-person experience with the students they serve (Holstun, 2018).


While an online class may involve some interaction and evidence of interpersonal ability, a residency increases the opportunities for faculty to make a more accurate assessment of skills and dispositions. Thus, program administrators may be apprised of gatekeeping and supervisory issues observed in this setting.


Case Study

Malkha chose an online counselor education master’s program because she lives in a remote area, over 75 miles from the nearest CACREP-accredited campus program. She works full-time at her holistic health practice where she practices Reiki, acupuncture, and holistic health coaching, including dietetics and nutrition. She is certified as a Reiki practitioner, licensed in her state as an acupuncturist, and has recently begun offering the coaching option for her clients who need additional care. Malkha has an emotional support animal that accompanies her to sessions, and she hopes to eventually be able to provide appropriate documentation to her clients that will allow them to have emotional support animals as well.


Malkha has several academic gifts. She writes well and generally does well on course assignments. She does have a pattern of asking for last-minute extensions as she often needs more time than is allotted to complete her assignments. Faculty have also noted that Malkha occasionally engages students in the discussion board in inflammatory ways. She uses her background and training to offer advice to fellow students in ways that are not always helpful nor appropriate to the context of an academic forum. She argues with those who do not utilize alternative, holistic approaches in their own theoretical orientations, calling them “shortsighted” and “old-fashioned.” Students seem to like Malkha but have complained that she comes on too strong.


At her first residency, Malkha shares a room with two other students and her emotional support dog. Unfortunately, one of the roommates is allergic and alleges that Malkha did not disclose that the dog would be attending residency. There is conflict between the roommates about handling the payment for the room that spills over into their work as a group. Malkha also brings her animal to residency, which is allowed, but she continually talks to the dog throughout the faculty lecture and group work. While working on skills, for example, Malkha asks her dog what his opinion is, how she should proceed, and then appears to listen for a response.


A large part of the time at residency is spent in clinical skills training. Faculty spend a lot of time redirecting Malkha from giving advice and offering treatment solutions during the early phases of therapy. She continually moves away from the person-centered approach she states she is practicing and becomes more prescriptive as the practice times continue.


Faculty teaching Malkha at residency bring the concerns about her distracting interactions with her emotional support animal as well as her skills to the attention of the training director. Questions to consider underscore potentially unique dimensions of practice for online faculty and academic leadership with respect to programming, policies, and gatekeeping. For example:


  1. Are there ethical or gatekeeping concerns that need to be addressed? If so, what are they?
  2. How do those concerns fit with the American Counseling Association’s ACA Code of Ethics
    (2014) and any gatekeeping procedures established by your program?
  3. What are some potential next steps to take with Malkha and/or faculty?
  4. What, if anything, could have prevented the problems that arose at residency?


While these questions are fundamental to counselor educators, they point to the importance of established policies and procedures for face-to-face residencies, effective communication of policies and expectations to online students, and preparedness to apply ethical decision-making models in navigating the ethical and legal challenges that may arise in online counselor education.


Considerations for Online Counselor Education Students


For the purposes of this article, an online counseling student is a person who receives some or all of their training via a distance education format. With this in mind, some of the inherent opportunities and challenges in this format, specifically as they relate to legal and ethical concerns, will be considered. A more comprehensive analysis of the experience of the online counseling student is addressed in another article in this special section (Sheperis et al., 2020).


Opportunities and Challenges

Opportunities for students in online programs include flexibility to accommodate life, work, and school. Online students may not be able to attend a graduate program in another format because of geographical, employment, or family considerations. Online students also have the opportunity to learn from faculty and fellow students from around the United States and the world.


Yet as appealing as this can sound, being an online student is challenging. Students are faced with the need to self-regulate, and, depending on the amount of instructor interaction, this may include deciding when to enter the class, turn in assignments, and engage with their peers (Wong et al., 2019) There can be a sense of isolation and loss of social community in virtual learning that is not present in a physical classroom (Phirangee & Malec, 2017). When looking at successful online students, it is recommended that they possess time-management skills, are self-regulated learners, and are self-motivated to complete tasks when compared to their traditional face-to-face classroom counterparts (Vineyard, 2019).


Legal and Ethical Considerations

As an online student, the ethical considerations are very similar to those experienced by on-campus students. There are gatekeeping considerations, concerns about fitness to practice, and general academic expectations regardless of the mechanism of education (CACREP, 2015). However, there are additional legal considerations that online students should be apprised of.


Each state, province, and territory has its own licensure law for professional counselors (Sheperis et al., 2016). Campus-based faculty become familiar with the state in which they offer education and may not be as familiar with licensure laws outside of that state. It will be incumbent upon the online students to familiarize themselves with state regulations so that they can ensure that their training will meet the standards for the educational component of licensure. For many states, graduation from a CACREP-accredited program is an acceptable standard of training. However, there can be exceptions even for CACREP-accredited programs. For example, the state of Georgia requires practicum and internship supervisors to have three years of postlicensure experience (State of Georgia, 2019), which is more than the CACREP standard.

In addition, not all online programs are able to provide training in every state. Applicants to online counselor education programs need to be well-educated consumers. In addition, enrollment services staff, program leaders, and counselor educators involved in admissions decisions need to be apprised of various state requirements. For example, the state of North Carolina requires that online programs, including those in private, out-of-state institutions, be approved by the University of North Carolina Board of Governors before they can engage in postsecondary degree activity in North Carolina
(University of North Carolina System, 2017).


Considerations for Cybersecurity in Counselor Education


With the rate of technology innovation, counselor education programs may find it challenging to keep up with how specific technology aligns with laws or ethics. When it comes to online counselor education and technology, student privacy and client confidentiality are of utmost importance and are often tricky to navigate with new technological development. In this section, we examine the two primary regulations and how to maintain compliance when using technology.


The Family Educational Rights and Privacy Act (FERPA)

FERPA (1974) is a regulation that protects the privacy of a student’s educational record. All programs, regardless of their delivery format, need to be aware of how FERPA impacts them and the technology they utilize. For instance, programs using online providers to help track internship hours, supervisor evaluations, and other paperwork need to be in line with FERPA best practices. The Department of Education, through their Privacy Technical Assistance Center (PTAC), provides resources for programs, including what to look for in a terms-of-service document (PTAC, 2016) and best practices (PTAC, 2014). Online programs using videoconferencing software need to be aware of the limitations on the use of videos created in a classroom or supervision setting.


Under FERPA, a photo or video of a student is considered an educational record when it is directly related to the student and is maintained by the program (Student Privacy Policy Office, n.d., para. 1). A video of a class is considered to be directly related to the student if they are visible doing a class presentation or even asking questions. The use of videoconferencing software is new enough to leave some ambiguity in the regulations surrounding recording of classes or supervision sessions. We will address supervision sessions in the section on the Health Insurance Portability and Accountability Act of 1996, which follows. Relative to teaching, there are a number of university recommendations suggesting that faculty record only themselves in class and do not include images of students in the recording. If a faculty member wants to release a recording of a class that directly relates to a student, they must gain signed consent from the student to do so. In practical terms, the faculty should gain consent from all members of the class if they appear in the recording of the class.


FERPA regulations require that institutions use “reasonable methods” to safeguard student information (PTAC, 2015). The law does not include specific requirements for firewalls, security monitoring, or response methods, but leaves that to universities to determine. It is also recommended that programs have a plan in place should a security breach occur.


Although counselor educators may use the term confidentiality when referring to a student’s experience, dispositional issues, or educational record, it is important to note that a student does not have the same rights of confidentiality as a counseling client. In fact, FERPA allows faculty and programs to share student educational records (including disciplinary records) with other faculty and other institutions where a student may be transferring. If a counseling student is dismissed for causing harm to clients, it is within the bounds of FERPA for program faculty to share that information with faculty where the student is applying for admission.


The Health Insurance Portability and Accountability Act of 1996 (HIPAA)

It is important for online counselor educators to be fully informed on HIPAA regulations as they relate to technology. These regulations provide protections for confidential and protected health information and are commonly referenced in the modern health care lexicon. With relation to training, online counselor education students and faculty frequently use various forms of software or other communication technology to communicate about client issues in practicum or internship classes and supervision sessions. It is not within the scope of this article to cover every aspect of technology and client personal health information (PHI) as defined by HIPAA. This section will focus specifically on the utilization of videoconferencing software (e.g., FaceTime, Skype, Zoom) to hold class and supervision sessions, which are often the primary ways distance faculty, supervisors, and students meet.


First, a key principle to understand in any discussion of HIPAA is that the user (e.g., faculty, supervisor, student counselor) is responsible to maintain compliance with HIPAA regulations. Videoconference software companies that counselor educators and supervisors choose to use could be considered business associates. Business associates are contractors who handle PHI of clients and have agreed to uphold HIPAA regulations.


There is no clear guidance on the need for business associate agreements for videoconferencing software. Some researchers have said that it is necessary for videoconferencing providers to have business agreements (Rousmaniere et al., 2016). Others have suggested that videoconferencing software falls under the HIPAA conduit exception (Caldwell, 2019). The conduit exception allows service providers to transmit or transport PHI without entering into a business agreement (Office for Civil Rights, 2016). To be eligible as a conduit, software providers must not store the data and may only transmit it (Taylor, 2015). Generally, videoconferencing software companies do not store any transmissions on their servers (Caldwell, 2019). FaceTime, Skype, and Zoom, for example, provide end-to-end encryption to create a peer-to-peer connection. It is not possible for them to decrypt the data as it goes from the device of the supervisor to the student. Therefore, given that no data from a supervision session or class is being recorded, the argument has been made that a business associate agreement is not necessary to use these platforms (Caldwell, 2019; Taylor, 2015). Recordings of supervision sessions or classes should not be saved to cloud services unless there is a business agreement in place, as now the company will be potentially storing PHI. As a reminder, it is still up to the faculty and student to be HIPAA-compliant when they use technological tools. Talking about a client over Facetime while in a coffee shop is still not considered HIPAA-compliant.


Technology moves swiftly. For example, Amazon has recently equipped their Alexa devices to handle PHI and has begun signing business agreements with select health care providers (Jiang, 2019). But there is little in terms of policy, law, or ethics to address anecdotal reports that the Amazon Alexa device is recording conversations in homes and therefore likely in offices where it is used. For the online educator and student, that could mean that a piece of technology intended to make home life easier creates a HIPAA or FERPA violation if portions of classes or client sessions are recorded. We anticipate this technology, and thus the policies, laws, and ethics that govern its use, will continue to develop. At this point, it is recommended that these devices not be in homes or offices where counselor education or supervision occurs.

Counselor Education Across State Lines

In general, teaching students who all live in the same state or who live in a variety of states is fairly similar. Counseling theory in Michigan is going to be the same as counseling theory in Alabama, and educational practices will be similar. However, there are some considerations unique to the online educator. As described, many of those relate to practicum, internship, and licensure. Because faculty will often be the first line of inquiry for students, online faculty need to be aware that codes of ethics and laws related to client care vary from state to state. Although the content of theory classes may stay the same across states, conversations about what to do when a client reveals something in session that may require duty to warn or other action may change from state to state. Being prepared to navigate those conversations is essential to success as an online faculty member. It would benefit the online counselor educator to become familiar with the main state licensure board challenges confronted by the department. For example, specific curricular requirements and variations in state laws that impact abuse reporting are common considerations. While faculty members cannot be experts on all state, province, and territory law, it is helpful to have a solid understanding of the primary issues impacting students.

Online programs are often part of institutional efforts to recruit international students (Lee & Bligh, 2019). In addition to differences in state regulations, program faculty then must have an awareness of international counseling practice. Many countries have no formal licensing of counselors, so a comparison of licensure laws cannot be done. The lack of laws related to the practice of many forms of counseling outside of the United States makes it impossible to declare any uniform statements about such practice. Students who are outside of the United States and the faculty who train them need to be especially vigilant in investigating standards and laws that impact training and practice.


Ethics Across State Lines
Just as there is no universal licensure law across states, there is no universal adoption of a code of ethics across states. The code of ethics provided by ACA is the most commonly used single code in the United States; however, only 19 of the 52 jurisdictions with licensure laws have adopted the ACA Code of Ethics into their rules and regulations (ACA, 2015). As you can imagine, it can be challenging for educators and students to navigate all of the complexities of the various codes. Students are guided to consult state laws to better understand the code of ethics under which they will fall.

Although codes of ethics are generally more alike than conflictual, there are a number of differences. The ACA Code of Ethics (2014) empowers counselors to warn identified others when there is a threat of serious and foreseeable harm. That code is historically rooted in the famous Tarasoff ruling in which the clinician provided information to the police, but not to the identified person that the client was threatening (Sheperis et al., 2016). However, the Texas code of ethics requires counselors to report only to authorities and not to warn the identified third party (Texas State Board of Examiners of Professional Counselors, 2011). Another example is that counselors are ethically allowed to barter under the ACA Code of Ethics. However, Texas code prohibits bartering (Texas State Board of Examiners of Professional Counselors, 2009). Thus, students and educators need to be able to assess those differences as they proceed with training across states.

Laws Across State Lines
Just as ethical codes vary from state to state, laws also vary. Few laws that govern the practice of counseling are enacted at the federal level. Instead, each state is empowered to determine what is best for their population in terms of developing laws that govern scope of practice for counselors. Licensure laws are the first areas that counseling students and counselor educators should familiarize themselves with. In addition to licensure law differences, there are other challenges that may exist.

One area of difference occurs within mandated reporting laws. Each state specifically sets out the definitions of abuse and neglect while also outlining who is considered a mandated reporter. In Mississippi, any person who knows about or has reason to suspect abuse or neglect of a child by a parent, legal custodian, caregiver, or other person(s) responsible for the child’s care is required by law to make a report (Mississippi Department of Child Protection Services, 2019). In other states, such as Pennsylvania, only mandated reporters have this requirement (State of Pennsylvania, n.d.). Mandated reporters typically include professionals expected to encounter children such as school personnel, medical professionals, and counselors. Counselors will always be required to report, but some states give that designation to any and every person, which can make a difference in working with clients who may have reason to suspect abuse.

Another distinction is found in laws related to warning identified third parties about an intent to harm. In the ethics classes of counselor training programs, we highlight the Tarasoff v. the Regents of the University of California (1974) case and subsequent rulings as the way to handle duty to warn any identified third parties. After multiple court and state supreme court rulings in California, where the Tarasoff case occurred, many states have elected to follow this case law and allow or even require counselors to report the intent to harm to the identified potential victim as well as the authorities (Sheperis et al., 2016). However, some state laws are silent on this matter. In Georgia, there is only a small mention in the code for psychologists and nothing to guide counselors (State of Georgia, 2020). Texas has a law related to Tarasoff, but it goes counter to the laws in the vast majority of states. The Texas Health and Safety Code (2005) states that counselors are not allowed to notify the identified victim:

A professional may disclose confidential information only to medical or law enforcement personnel if the professional determines that there is a probability of imminent physical injury by the patient to the patient or others or there is a probability of immediate mental        or emotional injury to the patient. (p. 4,182)

In practice, this means that two students from different states in the same ethics course could respond to a case involving a threat to harm an identified party in vastly different ways and still be correct.


Gatekeeping Across State Lines
The gatekeeping aspect of counseling pertains both to the obligation of counselor educators to ensure the competency of students entering the profession and the responsibility of practicing professionals to confront and address the unethical practice of colleagues when it comes to their attention. The gatekeeping responsibility has become so much more complex because of the evolution of distance counseling and distance counselor education. Distance practices raise questions about how well a professional in one location can monitor the behavior of another located in an entirely different place. The implications, which require familiarity with federal laws such as HIPAA and FERPA, state statutes and regulations for local licensing, and other local laws pertaining to the plethora of issues a counselor may encounter in therapy with clients, are nothing short of overwhelming. The responsibility is vast when considering the overabundance of variations of rules and consequences for not following them.


Lawsuits, Inconsistent Laws, and Varying Codes of Ethics
As mentioned, the practice of counseling is not federally regulated for the most part. Each state or territory has a degree of autonomy over the regulation of professional licensure, and therefore there is a significant disparity from jurisdiction to jurisdiction. Federal laws impose uniformity and create a reliability regarding the rules and regulations for any area governed by the federal government. For example, in 2015 the U.S. Supreme Court ruled that same-sex marriage would be a legal right across the United States. The impact of the ruling was that the 14 states that had bans on same-sex marriage could no longer prevent same-sex couples from legally marrying in their individual jurisdiction. However, the application of federal laws are sometimes locally compromised, such as when a specific religious denomination refuses to perform marriage ceremonies for same-sex couples by asserting freedom of religion and the separation of church and state. The religious argument is not that the same-sex couple cannot marry in that state, but rather that the couple simply cannot marry in a religious ceremony in that church. This example sets the stage for recent legislation that impacts counselor education.

The state of Tennessee implemented legislation in 2014 that allowed counselors to refuse to provide services to someone on the basis of “strongly held personal beliefs,” thus allowing professional counselors to impose their own values as a lens for whether or not they would work with particular clients. The mere existence of this legislation led to ACA moving the annual conference in 2017 from Nashville, Tennessee, where it was scheduled to be held, to San Francisco, California. The ACA Code of Ethics (2014) calls for counselors to refrain from imposing their values on clients. As of 2015, the ACA Code of Ethics is used by 19 states, ironically with Tennessee being among them. In other words, the licensing statute in Tennessee incorporates the language of the ACA Code of Ethics, while there is a separate law indicating that a counselor cannot suffer loss of license when that code is violated through the refusal of services to someone because of what the counselor personally believes. It is noteworthy that, while the LGBT population was the likely intended target of the new law, the language would allow for a further and widespread regression to blatantly discriminatory practices under the justification that the practice is rooted in what the individual believes.

Case Study
     Carolyn is a student pursuing her doctoral degree in professional counseling. She is 35 years old and her best option for pursuing her education was through a distance-based program. Accordingly, though she lives in a rural community outside Nashville, Tennessee, she is enrolled in a graduate program at Towaco University based in Chula Vista, California. Throughout her enrollment, she has attended three residencies in California, and she is presently in the field experience segment of her education. Carolyn is employed full-time as a counselor at a Christian counseling center. She has her master’s degree and she is licensed. She arranges her practicum hours at a local inpatient addictions recovery center around the requirements of her full-time job so that she is usually working at her practicum site on nights and weekends.

As a student at Towaco, she was asked to sign a statement as a condition of enrollment committing to follow the ACA Code of Ethics. She has always abided by the provisions of the code in the context of her role as a student. However, at her primary place of employment, Carolyn and her coworkers do not treat individuals who are part of the LGBT community.

This week, Carolyn has been assigned a new client at the addictions center. Dominic is a 28-year-old gay male who has been married to James for 8 years. They have a 4-year-old son. The relationship is solid. Dominic was admitted to treatment because he became addicted to pain medication following a serious car accident. James is very supportive, visits Dominic as frequently as is allowed, and attends family therapy sessions. Carolyn is assigned to work with Dominic both individually and as a facilitator of the family group. As a conservative Christian, Carolyn is uncomfortable working with a gay couple. She has never had to do so at her full-time job. In Tennessee, there is a law that allows a licensed professional counselor to refuse to provide services to anyone based upon “strongly held personal beliefs.” Carolyn tells her supervisor that she declines to work with Dominic and his husband and requests that the client be reassigned. The site supervisor suspends Carolyn and contacts her university supervisor in California.

Given Carolyn’s enrollment in an online counselor education program located in another state, this raises a number of questions when considering next steps. For example:

  1. Which law or guideline is the primary guide for Carolyn’s conduct as a practicum student at the addictions center?
    2. What relevance is there to the fact that Carolyn is already a licensed professional counselor in Tennessee but only a student at the university in California?
    3.  What if any implications will there be if Carolyn similarly refuses to see a client who is gay at her full-time job?
    4. Is Carolyn bound by the ACA Code of Ethics if she is not a member of the American
    Counseling Association?

These questions illustrate some of the complex terrain to be navigated by online counselor educators.

Other Legal Considerations
Ward v. Wilbanks (2010), though not the first case of its kind and certainly not the last, garnered significant attention in the profession through the focus on a student-driven lawsuit against a counseling program at Eastern Michigan University and the individual faculty members. The plaintiff, Julea Ward, was enrolled in a practicum course and providing counseling services under supervision at the in-house clinic at Eastern Michigan University. She was assigned a client who presented with depression and issues related to a same-sex relationship. Ms. Ward sought to refer the client, citing a conflict with her personal religious beliefs, and she was expelled from the program, which she cited as a violation of her rights. A lower court recognized the importance of the right of educational programs to self-regulate. However, a higher court found in favor of Ms. Ward, and the Ward v. Wilbanks case became critical in the further evolution of the ACA Code of Ethics (2014), through which clarification came in terms of referrals that are rooted in competency and referrals that are rooted in the imposition of values and judgment.

Thus, in the prior case study, Carolyn could be allowed to refer in an educational program and in her state, but may not be allowed to refer under the same circumstances outside of her state. Because most states follow the ACA Code of Ethics, anyone functioning as a counselor could be held to those standards regardless of ACA membership status (Sheperis et al., 2016).


The aforementioned examples serve to underscore the complications that arise just by virtue of the differences among the laws and regulations on like issues from state to state. With students being trained in the same program but living in different states and being trained by faculty who are also living in different states, opportunities for legal and ethical challenges abound. As counselor educators, we are trained to develop competent, ethical clinicians to serve clients, yet modern-day training, especially across state lines, requires the educator be informed of legal, ethical, and other challenges impacting the profession and students they serve.

Currently, counselor educators teaching through distance learning platforms cannot teach solely based upon licensing requirements in one state. In fact, the educator might be located in one state, while the student is in another, and the university is in yet another. The counselor educator, who might live and be licensed in Texas, is bound to follow the regulations in that state—but those regulations might not be relevant to (and might even be blatantly in conflict with) the regulations that apply to the student who resides in Tennessee. Moreover, the same professor can have 10 students in one class from 10 different states. The university, in California, will be bound by both federal and state regulations pertaining to higher education, including FERPA, but also by any relevant laws that might pertain to the different subject matters taught through that university. For example, in Alaska, if someone assists another in the act of suicide, that person can be charged with manslaughter. However, in California if that person is a medical doctor and assists another in ending their own life, the assistance could be considered a medical treatment under the End of Life Options Act (State of California, 2015).

Legal differences such as these call into question what can be taught about the professional handling of certain issues. Significant variations in law exist around confidentiality and mandatory reporting, counseling with minors and parental consent, and the nuances of licensing. Thus, it is incumbent upon counselor educators to be alert in their practice and prepared for the complex considerations that coexist with the accessibility of online counselor education.

Navigating the online space in a legal and ethical manner means staying up to date on current trends, resources, and laws. There are some resources counselor educators will find helpful in knowing licensure laws such as Licensure Requirements for Professional Counselors, A State by State Report (ACA, 2016). Also available from ACA is Licensure & Certification: State Professional Counselor Licensure Boards (2020), which links to all state requirements and is updated regularly. Other resources are more helpful for general legal concepts such as The Counselor and the Law, by Wheeler and Bertram (2019), currently in its 8th edition. For more state-specific considerations, counselor educators will want to look for resources like Caldwell’s Basics of California Law for LMFTs, LPCCs, and LCSWs (2019).


The myriad of legal and ethical complications inherent in online counselor education is navigable. For all of the complications of online learning, the benefits can outweigh the disadvantages. The opportunity to learn across state and national borders, interface with colleagues across the country and around the world, and develop one’s identity and practice as a professional counselor or counselor educator within this space is replete with rewards for all parties. Realistically, education is moving more and more to this format, and for counselor education, it is simply a matter of being cognizant of the legal and ethical dilemmas in order to meet them head-on.


Conflict of Interest and Funding Disclosure
The authors reported no conflict of interest
or funding contributions for the development
of this manuscript.



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Donna S. Sheperis, PhD, NCC, CCMHC, ACS, LPC, is an associate professor at Palo Alto University. Ann Ordway, JD, PhD, NCC, is a core faculty member at the University of Phoenix. Margaret Lamar, PhD, LPC, is an assistant professor at Palo Alto University. Correspondence may be addressed to Donna Sheperis, 5151 El Camino Real, Los Altos, CA 94022, dsheperis@paloaltou.edu.

Becoming a Gatekeeper: Recommendations for Preparing Doctoral Students in Counselor Education

Marisa C. Rapp, Steven J. Moody, Leslie A. Stewart

The Council for Accreditation of Counseling & Related Educational Programs (CACREP) standards call for doctoral preparation programs to graduate students who are competent in gatekeeping functions. Despite these standards, little is understood regarding the development and training of doctoral students in their roles as gatekeepers. We propose a call for further investigation into doctoral student gatekeeper development and training in gatekeeping practices. Additionally, we provide training and programmatic curriculum recommendations derived from current literature for counselor education programs. Finally, we discuss implications of gatekeeping training in counselor education along with future areas of research for the profession.

Keywords: gatekeeping, counselor education, doctoral students, programmatic curriculum, CACREP


Gatekeeping practices in counselor education are highly visible in current literature, as counselor impairment continues to be a significant concern for the mental health professions (Brown-Rice & Furr, 2015; Homrich, DeLorenzi, Bloom, & Godbee, 2014; Lumadue & Duffey, 1999; Rapisarda & Britton, 2007; Rust, Raskin, & Hill, 2013; Ziomek-Daigle & Christensen, 2010). V. A. Foster and McAdams (2009) found that counselor educators are frequently faced with counselors-in-training (CITs) whose professional performance fails to meet program standards. Although gatekeeping practices in counselor education have been cursorily examined over the past 40 years (Ziomek-Daigle & Christensen, 2010), more recent literature indicates a need to further address this topic (Brown-Rice & Furr, 2016; Burkholder, Hall, & Burkholder, 2014).

In the past two decades, researchers have examined the following aspects of gatekeeping: student selection; retention; remediation; policies and procedures; and experiences of faculty members, counseling students, and clinical supervisors (Brown-Rice & Furr, 2013, 2015, 2016; V. A. Foster & McAdams, 2009; Gaubatz & Vera, 2002; Homrich et al., 2014; Lumadue & Duffey, 1999; Parker et al., 2014; Rapisarda & Britton, 2007; Ziomek-Daigle & Christensen, 2010). Although the aforementioned areas of study are needed to address the complex facets of the gatekeeping process, there is a noticeable lack of research examining how counselor education programs are preparing and educating future faculty members to begin their role as gatekeepers.

Because doctoral degree programs in counselor education are intended to prepare graduates to work in a variety of roles (Council for Accreditation of Counseling & Related Educational Programs [CACREP], 2015), program faculty must train doctoral students in each of the roles and responsibilities expected of a future faculty member or supervisor. Authors of previous studies have examined constructs of identity, development, practice, and training in the various roles that doctoral students assume, including investigations into a doctoral student’s researcher identity (Lambie & Vaccaro, 2011), supervisor identity (Nelson, Oliver, & Capps, 2006), doctoral professional identity transition (Dollarhide, Gibson, & Moss, 2013), and co-teaching experiences (Baltrinic, Jencius, & McGlothlin, 2016). Studies investigating the various elements of these roles are both timely and necessary (Fernando, 2013; Lambie & Vaccaro, 2011; Nelson et al., 2006); yet, there is a dearth of research examining the complex development of emergent gatekeeper identity. In order to empower counseling programs in training the next generation of competent and ethical professional counselors, the development of doctoral students’ gatekeeping skills and identity must be more fully understood.


The Complexity of Gatekeeping in Counselor Education

Gatekeeping is defined as a process to determine suitability for entry into the counseling profession (Brown-Rice & Furr, 2015). When assessing this professional suitability, academic training programs and clinical supervisors actively evaluate CITs during their training as a means to safeguard the integrity of the profession and protect client welfare (Brear, Dorrian, & Luscri, 2008; Homrich et al., 2014). Evaluators who question a CIT’s clinical, academic, and dispositional fitness but fail to intervene with problematic behavior run the risk of endorsing a student who is not ready for the profession. This concept is referred to as gateslipping (Gaubatz & Vera, 2002). Brown-Rice and Furr (2014) found that consequences of gateslipping can impact client care, other CITs, and the entire counseling profession.

Gatekeeping for counselor educators and supervisors is understood as an especially demanding and complex responsibility (Brear & Dorrian, 2010). Potential complications include personal and professional confrontations (Kerl & Eichler, 2005), working through the emotional toll of dismissing a student (Gizara & Forrest, 2004), lack of preparation with facilitating difficult conversations (Jacobs et al., 2011), and fear of legal reprisal when assuming the role of gatekeeper (Homrich et al., 2014). Homrich (2009) found that although counselor educators feel comfortable in evaluating academic and clinical competencies, they often experience difficulty evaluating dispositional competencies that are nebulously and abstractly defined. To complicate the gatekeeping process further, counselor educators are often hesitant to engage in gatekeeping practices, as discerning developmentally appropriate CIT experiences from problematic behavior (Homrich et al., 2014) may be difficult at times. Thus, more clearly defined dispositional competencies and more thorough training in counselor development models may be necessary to assist counselor educators’ self-efficacy in gatekeeping decisions. The proceeding section examines doctoral students in counselor education preparation programs and their involvement in gatekeeping responsibilities and practices.


Doctoral Students’ Role in Gatekeeping

Doctoral students pursuing counselor education and supervision degrees are frequently assigned the responsibility of supervisor and co-instructor of master’s-level students. Consequently, doctoral students serve in an evaluative role (Dollarhide et al., 2013; Fernando, 2013) in which they often have specific power and authority (Brown-Rice & Furr, 2015). Power and positional authority inherent in the role of supervisor (Bernard & Goodyear, 2014) and instructor permit doctoral students ample opportunity to appraise CITs’ development and professional disposition during classroom and supervision interaction (Scarborough, Bernard, & Morse, 2006). Doctoral students frequently consult with faculty through the many tasks, roles, and responsibilities they are expected to carry out (Dollarhide et al., 2013). However, relying solely on consultation during gatekeeping responsibilities rather than acquiring formal training can present considerable risks and complications. The gatekeeping process is complex and leaves room for error in following appropriate protocol, understanding CIT behavior and development, supporting CITs, and potentially endorsing CITs with problematic behavior that may have been overlooked.

Despite the importance of doctoral student education in the counseling profession and a substantial body of research on gatekeeping over the past two decades (Brown-Rice & Furr, 2013, 2015, 2016; V. A. Foster & McAdams, 2009; Gaubatz & Vera, 2002; Lumadue & Duffey, 1999; Parker et al., 2014; Rapisarda & Britton, 2007; Ziomek-Daigle & Christensen, 2010), there is an absence in the professional discourse examining the identity, development, practice, and training of doctoral students for their role of gatekeeper. No counseling literature to date has explored how counselor education programs are supporting doctoral students’ transition into the role of gatekeeper, despite the latest accreditation standards calling for doctoral preparation programs to graduate students who are competent in gatekeeping functions relevant to teaching and clinical supervision (CACREP, 2015, Standard 6.B). A lack of specific literature is particularly problematic, as the process of gatekeeping can be difficult for faculty members. It is reasonable to assume that if faculty members struggle to navigate the responsibilities of a gatekeeper, then less experienced doctoral students would struggle in this role as well. Furthermore, most incoming doctoral students have not had an opportunity to formally engage in gatekeeping practices in academic settings as an evaluator (DeDiego & Burgin, 2016).

Although doctoral students have been introduced to the concept of gatekeeping as master’s-level students (e.g., gatekeeping policies), many counselors do not retain or understand gatekeeping information (V. A. Foster & McAdams, 2009; Parker et al., 2014; Rust et al., 2013). These research findings were further examined through an exploratory study in August of 2016. The first two authors of this article assessed beginning doctoral students’ gatekeeping knowledge and self-efficacy prior to doctoral training or formal curricula. Areas of knowledge assessed included general information on the function of gatekeeping, standard practices, and program-specific policies and procedures. Preliminary findings of six participants indicated that incoming doctoral students lacked understanding for their role in gatekeeping. This supports existing research (V. A. Foster & McAdams, 2009; Parker et al., 2014; Rust et al., 2013) and aligns with DeDeigo and Burgin’s (2016) assertion that doctoral students are often unsure of what the role of gatekeeper “even means, let alone how to carry it out” (p. 182). Consequently, attention must be given to preparing doctoral students for their gatekeeping role to meet CACREP standards and, most importantly, prepare them to gatekeep effectively in an effort to prevent gateslippage.

DeDiego and Burgin’s (2016) recommended counselor education programs support doctoral students’ development through specific programmatic training. Despite the established importance of specific training (Brear & Dorrian, 2010), no corresponding guidelines exist for content of material. To address this gap, we provide recommendations of content areas that may assist doctoral students in becoming acquainted with the complex role of gatekeeper. We derived our recommendations from a thorough review of professional literature. Recommendations compiled include current trends related to gatekeeping within the counseling profession, findings from various studies that state what information is deemed important in the realm of gatekeeping, and considerations for educational and professional standards that guide best practices as a counselor educator.



Recommendations contain general areas of knowledge that should accompany program-specific material for introductory gatekeeping role information. Providing doctoral students with program-specific policies and procedures related to gatekeeping practices, such as remedial and dismissal procedures, is of utmost importance. This information can be dispersed in a variety of methods such as orientation, gatekeeping-specific training, coursework, and advising. We view these areas of content as foundational in acquainting doctoral students with the role of gatekeeper. We included four general content areas of knowledge pertaining to gatekeeping practices and the role of gatekeeper: current variation of language espoused by the counselor education community; ethics related to gatekeeping; cultural considerations; and legal and due process considerations. Each of these recommended content areas will be briefly discussed with relevant literature supporting the importance of their inclusion.


Adopted Language

Current terminology in the field of counselor education describing CITs who struggle to meet professional standards and expectations is broad and lacks a universal language that has been adopted by counselor educators (Brown-Rice & Furr, 2015). Consequently, a plethora of terms and definitions exists in the literature describing CITs who are struggling to meet clinical, academic, and dispositional competencies. As described earlier, the lack of consensus regarding gatekeeping and remediation language may contribute to the lack of clarity, which many counselor educators perceive as a gatekeeping challenge. Terms appearing in gatekeeping literature that describe students of concern include: deficient trainees (Gaubatz & Vera, 2002), problems of professional competence (Elman & Forrest, 2007; Rust et al., 2013), impaired, unsuitable, unqualified, and incompetent (J. M. Foster, Leppma, & Hutchinson, 2014), with varying definitions describing these terms. Duba, Paez, and Kindsvatter (2010) defined counselor impairment as any “emotional, physical, or educational condition that interferes with the quality of one’s professional performance” (p. 155) and defined its counterpart, counselor competency, as an individual demonstrating both clinical skills and psychological health. It is important to emphasize potential complications and implications associated with the term impairment, which can have close association with disability services, rendering a much different meaning for the student, supervisee, or colleague (McAdams & Foster, 2007).

Introducing these terms to doctoral students not only familiarizes them with the definitions, history, and relevance of terms present in the counseling community, it also provides a foundation in which to begin to conceptualize the difference between clinical “impairment” versus emotional distress or developmentally appropriate academic struggle. In upholding responsibilities of gatekeeping, one must be aware of the differentiating aspects of emotional distress and impairment in order to be able to distinguish the two in professionals and students. In further support of this assertion, Rust et al. (2013) stated that counseling programs must be able to distinguish between problems of professional competence and problematic behavior related to normal CIT development. Including a review of relevant terms existing in the counseling literature in the program’s training will allow doctoral students to begin to understand and contextualize the language relevant to their new roles as gatekeepers.

Although it is essential to educate doctoral students on language common to the counseling community, familiarity with language adopted by the department and institution with which they are serving as gatekeepers is vital to training well-informed gatekeepers (Brear & Dorrian, 2010). Having a clear understanding of the terminology surrounding gatekeeping ensures that doctoral students and faculty are able to have an open and consistent dialogue when enforcing gatekeeping practices. Homrich (2009) described consistent implementation of gatekeeping protocol as a best practice for counseling programs and faculty. Additional best practices include the establishment of expectations and communicating them clearly and widely. In the recommendations offered by Homrich (2009), a common language is needed within the department in order to successfully implement these practices to improve and sustain gatekeeping procedures. After doctoral students are situated in the current climate of gatekeeping-related terms and language, an exploration of professional and educational ethics can ensue.


Ethics Related to Gatekeeping

Professional and ethical mandates should be identified and discussed to familiarize doctoral students with the corresponding ethical codes that they are expected to uphold. Three sources that guide ethical behavior and educational standards for counselor educators that must be integrated in curricula and training include the American Counseling Association Code of Ethics (2014), the 2016 CACREP Standards (2015), and the National Board for Certified Counselors Code of Ethics (2012). Doctoral preparation programs should draw specific attention to codes related to the function of gatekeeping. These ethical codes and professional standards can be introduced in an orientation and discussed in more depth during advising and formal courses.

Doctoral preparation programs have flexibility in introducing standards and ethical codes during doctoral students’ academic journey. We recommend relevant standards and ethics be introduced early and mentioned often during doctoral training, specifically in terms of gatekeeping. Doctoral students should have prior knowledge of the ethical codes before engaging in gatekeeping or remedial functions with CITs. Moreover, if doctoral students have an understanding of the educational standards that are required of them, they can strive to meet specific standards in a personalized, meaningful manner during their training. Referencing CACREP standards addressed in a course syllabus is required for accreditation and helpful for students; yet, educational standards should be incorporated in training to foster deeper meaning and applicability of standards. As doctoral students are being trained to take leadership positions in the counselor education field, a more thorough understanding of educational principles and ethical codes is vital, particularly in the area of gatekeeping. Faculty members leading doctoral courses are encouraged to speak to standards related to gatekeeping throughout the duration of a course. Faculty intentionally dialoguing about how these standards are being met may allow for doctoral students to provide informal feedback to whether they believe they understand the multifaceted role of gatekeeper. During the review of codes and standards, focused attention should be given to “cultural and developmental sensitivity in interpreting and applying codes and standards” (p. 207) in gatekeeping-related situations (Letourneau, 2016). One option for attending to such sensitivity is the introduction of a case study in which doctoral students participate in open dialogue facilitated by a trainer. The inclusion of a case study aims to engage doctoral students in critical thinking surrounding cultural and diversity implications for gatekeeping practices. The following section will draw further attention to the importance of cultural awareness in gatekeeping practices and responsibilities.


Cultural Considerations

It is vital for doctoral students to have an understanding and awareness of the cultural sensitivity that is required of them in making sound gatekeeping-related decisions. Not only do ethical codes and educational mandates expect counselor educators to possess a level of multicultural competency (American Counseling Association, 2014; CACREP, 2015), but recent literature draws attention to cultural considerations in the gatekeeping process (Goodrich & Shin, 2013; Letourneau, 2016). These cultural considerations provide doctoral students with valuable information on conceptualizing and interacting with gatekeeping practices in a more culturally sensitive manner.

Letourneau (2016) described the critical nature of taking into account students’ cultural influences and differences when evaluating their assessment of fitness for the profession, while Goodrich and Shin (2013) called attention to “how cultural values and norms may intersect” (p. 43) with appraisal of CIT counseling competencies. For example, when assessing a CIT’s behavior or performance to determine whether it may be defined as problematic, evaluators may have difficulty establishing if the identified behavior is truly problematic or rather deviating from the cultural norm (Letourneau, 2016). This consideration is essential as culture, diversity, and differing values and beliefs can influence and impact how perceived problematic behaviors emerge and consequently how observed deficiencies in performance are viewed (Goodrich & Shin, 2013; Letourneau, 2016). Examining the cultural values of the counseling profession, counselor education programs, and the community in which the program is embedded can shed light on what behaviors, attitudes, and beliefs are valued and considered norms. This examination can prompt critical awareness of how CITs differing from cultural norms may be assessed and evaluated differently, and even unfairly.

Jacobs et al. (2011) described insufficient support for evaluators in how to facilitate difficult discussions in gatekeeping-related issues, specifically when the issues included attention to diversity components. Doctoral students must be given ample opportunity to identify cultural facets of case examples and talk through their course of action as a means to raise awareness and practice looking through a multicultural lens in gatekeeping-related decisions and processes. Of equal importance is familiarity with legal and due process considerations, which are addressed in the section below.


Legal and Due Process Considerations

Three governing regulations that are often discussed in the literature, but left to the reader’s imagination in how faculty members actually understand them, include the Family Educational Rights and Privacy Act (FERPA) of 2000, the Americans with Disabilities Act (ADA) of 1990, and a student’s rights and due process policy within an institution. Presenting these three concepts and their implications to the gatekeeping process is warranted, as doctoral students are assumed only to have the understanding of these concepts from a student perspective. Although FERPA, the ADA, and the due process clause may be covered in new faculty orientation, how these regulations interface with gatekeeping and remediation are generally not reviewed during standard university orientations. It is recommended that training and curricula include general knowledge and institution-specific information related to the regulations. Institution-specific material can include university notification of rights; handbook material directly addressing student rights; remediation policy and procedures; and resources and specific location of campus services such as the disability office. Inclusion of general and program-specific information will help future faculty members in possessing a rounded and well-grounded understanding of how legal considerations will apply to students and inform their gatekeeping practices. Lastly, doctoral students should be informed that the regulations detailed below may limit their access of information due to master’s-level student privacy. To begin, doctoral students should intimately understand FERPA and its application to the CITs they often supervise, teach, and evaluate.

FERPA. General information may consist of the history and evolution of FERPA in higher education and its purpose in protecting students’ confidentiality in relation to educational records. Doctoral students must be introduced to the protocol for ensuring confidentiality in program files. Program files include communication about CIT performance and may be directly related to gatekeeping issues. Doctoral students must recognize that, as evaluators communicating CIT assessment of fitness, including dispositional competencies, they must abide by FERPA regulations, because dispositional competencies are considered educational records.

Educational programs often utilize off-site practicum and internship programs that are independent from the respective university (Gilfoyle, 2008), and this is indeed the case with many CACREP-accredited counselor training programs. Doctoral students must have an understanding of the protocols in place to communicate with site supervisors who are unaffiliated with the university, such as student written-consent forms that are a routine part of paperwork for off-site training placement (Gilfoyle, 2008). Although doctoral students may not be directly corresponding with off-site evaluators, their training should consist of familiarizing them with FERPA regulations that address the disclosure of student records in order to prepare them in serving CITs in a faculty capacity. Understanding how to communicate with entities outside of the university is crucial in the event that they are acting as university supervisors and correspondence is necessary for gatekeeping-related concerns. An additional governmental regulation they are expected to be familiar and interact with is the ADA.

The ADA. Introducing doctoral students to the ADA serves multiple functions. First, similar to FERPA, it would be helpful for doctoral students to be grounded in the history of how the ADA developed and its purpose in protecting students’ rights concerning discrimination. Second, general disability service information, such as physical location on their respective campus, contact information for disability representatives, and protocols for referring a student, provides doctoral students the necessary knowledge in the event that a CIT would inquire about accommodations. If a CIT were to inquire about ADA services during a class in which a doctoral student co-teaches or during a supervision session, it would be appropriate for the doctoral student to disseminate information rather than keeping the CIT waiting until after consultation with a faculty member. Lacking general information relevant to student services may place the doctoral student in a vulnerable position in which the supervisory alliance is undermined, as the doctoral student serving in an evaluative role is not equipped with the information or knowledge to assist the CIT. Finally, presentation of the ADA and its implications for gatekeeping will inform students of the protocols that are necessary when evaluating a CIT who has a record of impairment. For example, if a CIT has registered a disability through the university’s ADA office, appropriate accommodations must be made and their disability must be considered during the gatekeeping process.

 Due Process. The introduction of students’ fundamental right to basic fairness is essential, as many doctoral students may not understand this concept outside of a student perspective because of a lack of experience in instructor and supervisor positions. Examples of such basic fairness can be illustrated for doctoral students through highlighting various components in a counselor training program that should be in place to honor students’ right to fair procedures and protect against arbitrary decision-making. These include but are not limited to access to program requirements, expectations, policies, and practices; opportunity to respond and be heard in a meaningful time in a meaningful way; decisions by faculty members, advisors, or programs to be supported by substantial evidence; option to appeal a decision and to be notified of judicial proceedings; and realistic time to complete remediation (Gilfoyle, 2008; Homrich, 2009). McAdams and Foster (2007) developed a framework to address CIT due process and fundamental fairness considerations in remediation procedures to help guide counselor educators’ implementation of remediation. It is recommended that these guidelines (McAdams & Foster, 2007) be introduced in doctoral student training to generate discussion and included as a resource for future reference. In educating doctoral students about considerations of due process through a faculty lens, formal procedures to address student complaints, concerns, and appeals also should be included in training.


Implications for Counselor Education

Doctoral preparation programs are charged with graduating students who will be prepared and competent for the various roles they will assume as a counselor educator and clinical supervisor. The lack of professional literature exploring the development and training of gatekeepers indicates a clear call to the counseling profession to investigate the emergence of counselor educators into their role of gatekeepers. This call is fueled by the need to understand how doctoral preparation programs can support students and ensure competency upon graduation. Generating dialogue related to doctoral student gatekeeper development may consequently continue the conversation of standardization in gatekeeping protocol. Accordingly, this sustained dialogue also would keep the need for more universal gatekeeping nomenclature in the forefront. Continued emphasis on a common gatekeeping language will only strengthen gatekeeping protocol and practices and in return provide an opportunity for training developments that have the potential to be standardized across programs.

The recommended content areas we have offered are intended to prepare doctoral students for their role of gatekeeper and aim to enhance the transition into faculty positions. These recommendations may be limited in their generalizability because gatekeeping practices vary across programs and department cultures, indicating that information and trainings will need to be tailored individually to fit the expectations of each counseling department. These differences hinder the ability to create a standardized training that could be utilized by all departments. As gatekeeping practices continue to receive research attention and the call for more universal language and standardization is answered, standardization of training can be revisited. Nonetheless, general recommendations in training content can serve as groundwork for programs to ensure that students are receiving a foundation of basic knowledge that will allow doctoral students to feel more confident in their role of gatekeeper. The recommended content areas also serve to help incoming doctoral students begin to conceptualize and see through an academic—rather than only a clinical—lens.

Implementation and delivery of recommended content areas may be applied in a flexible manner that meets doctoral preparation programs’ specific needs. The recommendations offered in this article can be applied to enhance existing curricula, infused throughout coursework, or disseminated in a gatekeeping training or general orientation. Faculty creating doctoral curricula should be cognizant of when doctoral students are receiving foundational gatekeeping information. If doctoral students are expected to have interaction with and evaluative power over master’s-level students, recommended gatekeeping content areas should be introduced prior to this interaction.

There are several avenues for future research, as the proposed recommendations for content areas are rich in potential for future scholarly pursuit. The first is the call to the profession for investigations examining training efforts and their effectiveness in preparing future faculty members for the multifaceted role of gatekeeper. The complexity and import of gatekeeping responsibilities and identity development may be a possible reason for the lack of studies to date on this role. Nevertheless, both qualitative and quantitative inquiry could lend insight to gaps in training that lead to potential gateslippage. Quantitative research would be helpful in examining how many programs are currently utilizing trainings and the content of such trainings. In consideration of the number of CACREP-accredited doctoral programs within the United States, a large sample size is feasible to explore trends and capture a full picture. Conducting qualitative analysis would expand and deepen the understanding of how faculty and doctoral students have been trained and their processes and experience in becoming gatekeepers.

In conclusion, doctoral preparation programs can be cognizant to infuse the aforementioned recommended content areas into doctoral curricula to meet CACREP standards and prepare doctoral students for the complex role of gatekeeper. Counselor education and supervision literature indicates that more focused attention on training could be beneficial in improving gatekeeping knowledge for doctoral students. Training recommendations derived from existing literature can be utilized as guidelines to enhance program curriculum and be investigated in future research endeavors. With a scarcity of empirical studies examining gatekeeping training and gatekeeper development, both quantitative and qualitative studies would be beneficial to better understand the role of gatekeeper and strengthen the overall professional identity of counselor educators and clinical supervisors.


Conflict of Interest and Funding Disclosure

The authors reported no conflict of interest or funding contributions for the development of this manuscript.



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Marisa C. Rapp, NCC, is an assistant professor at the University of Wisconsin–Parkside. Steven J. Moody, NCC, is an associate professor at Idaho State University. Leslie A. Stewart is an assistant professor at Idaho State University. Correspondence can be addressed to Marisa Rapp, 264 Molinaro Hall, 900 Wood Rd., Kenosha, WI 53144-2000, rapp@uwp.edu.

Analyzing CACREP-Accredited Programs’ Utilization of Criminal Background Checks

Maribeth F. Jorgensen, Kathleen Brown-Rice

The use of objective methods in gatekeeping processes has become increasingly more important due to legal and ethical implications and consequences. For example, the medical field has utilized criminal background checks (CBCs) as a gatekeeping assessment of a student’s ability to best serve future patients. This article focuses on the current use of CBCs by master’s-level counselor education programs (N = 83) accredited by the Council for Accreditation of Counseling and Related Educational Programs (CACREP). A significant implication from this study is the need for counselor education to consider best practices and guidelines for the use of CBCs.

Keywords: criminal background, criminal background checks, gatekeeping, counselor education, counseling programs

Counselor educators and supervisors are ethically bound to not endorse any counselor-in-training (CIT) for certification, licensure, employment or completion of an academic program when they believe a CIT is not qualified for the endorsement (American Counseling Association [ACA], 2014). In particular, educators are required to screen all counseling program applicants prior to admission and to continually and thoroughly evaluate and appraise students during their progression through the program (Erwin & Toomey, 2005). It has been suggested that utilizing criminal background checks (CBCs) with students should be part of the gatekeeping process in behavioral health programs (Brodersen, Swick, & Richman, 2009; Cowburn & Nelson, 2008; Erwin & Toomey, 2005). In fact, government agencies and private and public employers are increasing their use of CBCs as a screening mechanism (Sheets & Kappel, 2007). CBCs may be conducted to determine if an individual is a potential threat to clients, vulnerable populations or fellow employees. According to Sheets and Kappel (2007), “Because most consumers are not in the position to run CBCs . . . they depend on professional licensing boards to conduct appropriate screening of applicants” (p. 64). This could be a concern, however, because CITs work with clients while they are in their training program. Counseling programs that do not have access to CBC data may be left without critical information to help best protect vulnerable populations. Therefore, the responsibility of having CBC results might more appropriately fall on counselor educators (ACA, 2014).

All 50 states, the District of Columbia, Guam, Puerto Rico and the Virgin Islands require a CBC for school counselors (American Counseling Association, Office of Public Policy and Legislation, 2011). According to ACA (2010), as of 2010 six states (i.e., Arizona, Maine, Mississippi, Missouri, Montana, Tennessee) required a CBC as part of the licensure application process. North Carolina requires applicants to sign a statement authorizing the licensing board to conduct a full criminal record search, including state and federal records (North Carolina Board of Licensed Professional Counselors 2013). The state of Washington requires applicants to submit fingerprints as a means to perform a professional criminal background check. Given that passing a CBC is a criterion for certification or licensure for professional counselors in some jurisdictions, it seems important to examine if counselor education programs are utilizing CBCs as part of the admission process, student evaluation for CITs, and ultimately as a tool for gatekeeping.

Gatekeeping in the Field

According to Kerl and Eichler (2005), “In the field of counselor education, gatekeepers are the professionals whose responsibility it is to open or close the gates on the path toward becoming a counselor” (p. 74). The Council for Accreditation of Counseling and Related Educational Programs (CACREP) requires counseling programs to start the gatekeeping process at the onset of screening applicants for admission. Unfortunately, there is ambiguity about specific ways to gatekeep during the admission process, which may prompt inconsistencies between those operating as gatekeepers. Several studies have examined barriers to effective gatekeeping (Brear & Dorrian, 2010; Brodersen et al., 2009; Brown-Rice & Furr, 2014). Some of the barriers include a need to meet desired enrollment, inconsistent screening procedures, likability effect, inadequate training on how to be a gatekeeper, social loafing, the leniency effect, and the empathy veil effect (Brear & Dorrian, 2010; Brown-Rice & Furr, 2014). The previous findings support the need to examine the current use of objective measures that may diminish some of these described obstacles.

Swank and Smith-Adcock (2014) examined the screening and gatekeeping methods used by 79 master’s- and doctoral-level CACREP-accredited counseling programs. Specifically, they asked programs about their use and perceived effectiveness of objective (e.g., grade point average [GPA]) and subjective (e.g., interviews) methods of gatekeeping during the admission process. The majority of surveyed programs placed higher weight on GPA and letters of recommendation during the admission process. Participants described their methods as inefficient and stressed the need to use consistent evaluation to reduce the impact of subjectivity. They also described a desire to use reliable assessments such as formal background checks to better assess psychological fit (Swank & Smith-Adcock, 2014).

Brear and Dorian (2010) conducted a study to examine how 63 counseling educators experienced their training and training as gatekeepers. Their respondents indicated a commitment to be effective gatekeepers, but they had difficulties minimizing their subjectivity because of vague guidelines and written policies. Many of their participants stated they observed other faculty being lenient and failing to capitalize on key moments when students were displaying behaviors of concern. Brear and Dorrian suggested that programs use objective procedures for gatekeeping and provide ongoing training to help faculty better understand their gatekeeper roles and related policies.

Brown-Rice and Furr (2014) discussed the role empathy can play in the gatekeeping process. Ultimately, the authors suggested that counselor educators benefit from finding a balance between being empathic and evaluative in their roles. Brown-Rice and Furr described that empathy may impact how counselor educators gatekeep and intervene with problematic behavior. They coined the term empathy veil effect and suggested that it is compounded by factors such as lack of consistent standards across faculty, lack of scholarly sources to refer, and fears of legal retaliation made by students. Although these factors have historically been barriers, the field of counselor education is at a critical point to establish well-documented, researched and supported screening procedures for potential CITs. This study aims to provide a greater description of how counseling programs currently use CBCs in the process of gatekeeping.

Criminal Background Checks

Literature searches revealed only one study that explored the use of CBCs by counseling programs (Erwin & Toomey, 2005). This is concerning given that some states require CBCs of school counselors and licensure candidates. Over 10 years ago, Erwin and Toomey (2005) conducted a study of 50 CACREP-accredited counseling programs to examine use of CBCs. Specifically, they sought to gather data about how counseling programs use criminal background checks and what resources are consulted when deciding how and when to use CBCs. At the time of their study and within their sample, five CACREP-accredited counseling programs were utilizing CBCs. Alarmingly, none of the programs that indicated use of CBCs answered the question about having established criteria to decide how criminal background check results are used.

Scholars within other human services fields have provided commentary or empirically explored the use of CBCs in their related training programs. Burns, Frank-Stromborg, Teytelman, and Herren (2004) wrote about the use of CBCs in the field of nursing. At the time of their commentary, most state nursing licensure boards made CBCs mandatory for nurses in order to practice. In contrast with nursing licensing boards, most nursing training programs had not made CBCs a requirement due to not having sufficient guidance in how to use the results of CBCs.

Farnsworth and Springer (2006) empirically investigated the use of CBCs by nursing programs. They surveyed 258 nursing schools from across the United States and found that fewer than 50% of the surveyed schools required background checks. Only 8% of the schools that conducted CBCs used them as a part of the admission process. For those that did obtain background checks, there was no standard way to process the results and no universal guidelines were available on how to interpret results. Farnsworth and Springer suggested that schools considering CBCs should seek legal counsel and communicate with other programs using CBCs. They also recommended programs require a criminal self-disclosure in addition to a background check to determine consistencies between self-disclosures and the results of CBCs (Farnsworth & Springer, 2006).

According to Kleshinski, Case, Davis, Heinrich, and Witzburg (2011), approximately 113 medical schools used background checks at the time of their commentary. Medical schools have benefitted from using CBCs by detecting patterns of behaviors that may impede a student’s ability to practice and best serve future patients. Kleshinski and colleagues found that common patterns across medical schools using CBCs included: (1) individually considering each situation by factoring in variables such as date and nature of offense; and (2) asking students about past criminal behaviors on admission applications. Importantly, there may be discrepancies between what students report on applications and what their CBCs show; therefore, solely relying on self-report could be problematic.

Within the field of sports science, Weuve, Martin, and White (2008) described many of the same concerns and uncertainties. They suggested that common reasons to conduct CBCs include “promotion of a safe school environment, protection of patients, clients, and student-athletes, because it is required of clinical facilities, and it enhanced student advisement and compliance with state or federal law” (Weuve et al., 2008, p. 28). These authors also speculated that programs may not conduct CBCs because of certain state and federal law, fear of further marginalizing minorities, and due to minimal resources to help the process be informed. Although these suggestions and concerns seem to be well-conceptualized across fields, few studies have taken the next step to empirically examine these issues.

Based on previous literature, there is consistent concern with a lack of universal policies across graduate training programs related to the use of CBCs. Additionally, only one study has empirically investigated how often and in what ways CBCs are being used with counseling graduate school applications (Erwin & Toomey, 2005). Unfortunately, this study is outdated and may leave the field of counseling without adequate evidence-based support to enhance their gatekeeping processes.

Currently, when programs are deciding to use CBCs, they will find minimal information about key aspects such as what company or vendor to use when conducting CBCs; who is financially liable for the CBC; when a CBC should be required; how information from CBCs are used; how students are informed about CBCs; and how to decide if an offense is related to the counseling profession (Weuve et al., 2008). Counseling programs could be held liable for not conducting CBCs, especially if the safety of others is compromised. At the same time, counseling programs also could face liability for using CBCs when guidelines are unclear, applicants are not informed, and policies are not in place about how CBC results may be used.

Given the limited research on this issue, the purpose of this study was to determine how CACREP-accredited master’s programs are utilizing CBCs regarding applicants and current students. Specifi-cally, the following research questions were addressed: (a) Do CACREP-accredited master’s programs require applicants to undergo a CBC? (b) What are the program’s procedures for performing the CBC of applicants? (c) Do programs have established protocols regarding how the results of CBCs affect applicants? ( d) Do CACREP-accredited master’s programs require current students to undergo a CBC? (e) What are the program’s procedures for performing the CBCs of current students? (f) Do programs have established protocols regarding how the results of CBCs affect current students? and (g) What do CACREP program representatives believe are their legal and ethical obligations related to performing CBCs with applicants or current students?


Participants and Procedures
Participants were the program contacts for the 270 CACREP-accredited master’s programs listed on the official CACREP Web site in summer of 2013. Due to the small size of this population, the entire population was sampled to provide the best approximation of the population’s true characteristics (Gay, Mills, & Airasian, 2009). Recruitment of participants was conducted via an e-mail to each program contact inviting them to participate in the study and including a link to an online survey. The sample size decreased due to invalid e-mail addresses, which resulted in the final sample of 261 CACREP-accredited program contacts. A total of 86 participants completed the survey; however, respondents with missing or invalid data (n = 3, less than 2%) were eliminated via listwise deletion, leaving a total number of 83 participants included in this study. Although there are multiple options for dealing with missing data, listwise deletion was used by eliminating participants with missing data on any of the variables in this study (Sterner, 2011). This resulted in a final response rate of 32%, which falls within the acceptable 30% response rate for online surveys (University of Texas at Austin, Division of Instructional Innovation and Assessment, 2011). Of the 86 program contacts who provided usable data, 29 indicated their programs were in the South, 28 defined their program being in the Northeast, 17 stated their program was in the Midwest, and 9 indicated that their program was in the West. The majority of the participants reported that their programs offered degrees in both the clinical mental health/community track (84%) and the school track (83%). Further, 17% offered the marriage, couple, and family track, 13% offered the student affairs/college track, 6% had the addiction track, and 4% reported offering the career track to students. Table 1 provides a breakdown of specialty track programs offered by participants.

The survey for the current study was designed based on the Criminal Background Check Survey developed by Erwin and Toomey (2005) related to admissions and CACREP-accredited programs performing CBCs. The 13 questions from the original Erwin and Toomey survey were used as a foundation for 30 questions that were created for the online survey utilized to gain information from CACREP-accredited program contacts. Participants were asked to identify if their programs required CBCs as part of admission to their program. Participants who responded in the affirmative then responded to six multiple choice items related to which specialty tracks required a CBC, type of CBC, who performs and pays for the CBC, how applicants are notified that the CBC is required, and whether the programs have established procedures for deciding non-admission based upon the results of the CBC. Further, two qualitative questions provided an opportunity to learn how CBC information is obtained and used.

Next, participants were asked to identify if their programs required CBCs of current students. Participants who responded in the affirmative then responded to seven multiple choice items related to which specialty tracks required the CBC, type of CBC, who performs and pays for the CBC, how applicants are notified that a CBC is required, at what time in the program CBCs are performed, and whether the programs have established procedures based upon the results of the CBC. Further, two qualitative questions requested information about how CBC information is used and protocols for removal of students. The final part of the survey consisted of 11 questions regarding ethical and legal issues (i.e., CBC required for certification, licensure, or employment as a professional counselor, privacy issues, client welfare, legal consequences of performing CBC, CACREP-standards, potential for screening out minority applicants and students). This section contained five multiple choice questions and six questions based on a 5-point Likert scale (1 = strongly disagree to 5 = strongly agree).

To establish content validity and reliability, a pilot study of the survey was completed. The pilot study included two former CACREP-accredited program contacts who were asked to look for clarity and conciseness of the survey questions and provide feedback and suggestions for improvement. Based upon the responses of the pilot participants, the survey was edited to provide a more conducive and efficient design.

Data Analysis
The Statistical Package for Social Sciences (SPSS) software (version 21) was utilized to screen and analyze the data. The participants’ responses to the survey questions were subjected to both descriptive and correlational analyses. First, a descriptive analysis of multiple choice responses was conducted to produce a set of summary statistics related to each of the seven research questions. Next, a Fisher’s Exact Test (a variant of a chi-square test for independence for small sample sizes) with an alpha level of .05 was used to determine if there was an association between the region of the country where participants’ programs were located and whether CBCs are required for applicants or current students.


Applicants and Criminal Background Checks
Regarding the first research question, of the 83 participants, 27.7% (n = 23) reported that their programs required applicants to undertake CBCs. Table 1 provides a breakdown of the specialty track that program contacts specified as requiring applicants to undergo CBCs. The Fisher’s Exact Test to determine an association between location of program and requiring applicants to have a CBC was found to be not significant (p = .426).

Table 1

Number and Percentages by Specialty Track and Criminal Background Required

Specialty Track Offered
by Program Criminal Background Required for Program Admission Criminal Background Required for Current Students in Program

Yes No Yes No Yes No
n % N % N % N % n % n %
Clinical Mental Health/
Community 70 84.3 13 15.7 16 22.9 54 77.1 26 37.1 44 62.9
School 69 83.1 14 16.9 15 21.7 54 78.3 33 47.8 36 52.2
Marriage, Couple, Family 14 16.9 69 83.1 2 14.3 12 85.7 9 64.3 5 35.7
Student Affairs/College 11 13.3 72 86.7 3 27.3 8 72.7 5 45.5 6 54.5
Addiction 5 6.0 78 94.0 1 4.5 4 95.5 1 4.5 4 95.5
Career 3 3.6 80 96.4 0 0.0 3 100 0 0.0 3 100

Procedures for applicants. Table 2 provides a breakdown of the type of CBCs performed, who performs the applicants’ CBCs, and who paid for the applicants’ CBCs. All programs that required
CBCs informed students of the CBC through at least one avenue: 45% (n = 10) reported notice was given only via the program’s Web site; 18% (n = 4) said they gave notice via program Web site, verbal discussion (i.e., interview), and written correspondence (i.e., e-mail, letter, handbook); 14% (n = 3) stated they gave notice by written correspondence only; 9% (n = 2) gave notice by verbal discussion only; 9% (n = 2) gave notice by both program Web site and written correspondence; and 5% (n = 1) gave notice via both verbal and written notification. An open-ended format was used to learn about how programs use information from the applicants’ CBCs. Thirty-five percent (n = 8) of the participants shared that they used results in different ways depending on if there was a criminal offense, the level of offense, and the date of offense. One participant reported their program uses the results to determine fit for their program and the counseling profession:

The nature of the crime and the time that has passed since then, and the applicant’s explanation (is it sincere, logical, etc.) will help faculty determine if the person will be considered or not. Also, we think about whether or not this person is likely to get certified as a school counselor or licensed as an LPC, or will be able to obtain liability insurance is all considered.

Established protocols for applicants. Regarding research question three, 59% (n = 13) of the 23 CACREP-accredited programs who reported requiring applicants to undergo CBCs had established procedures for deciding about the non-admission of an applicant in their program based on the CBC results. Twenty-three percent (n = 5) provided that their program had not established procedures and 18% (n = 4) reported that they did not know if their program had a recognized policy. Thirty-nine percent (n = 9) of the participants shared that they used professional standards for deciding about the non-admission of an applicant. One participant described, “We would not accept an applicant who had a background inconsistent with our discipline, and we would not accept an applicant who would not be able to obtain a license.”

Table 2

Number and Percentages by CBC Procedures and Applicants and Current Students

Applicants Current Students
n % n %
Type of CBC Performed
Local (i.e., city, county), state, and federal 10 45 14 37
State 3 14 5 14
Federal 3 14 6 16
State and federal 1 4 3 8
Cities of residency over last 7 years and sex offender data base 2 9 0 0
Did not know 3 14 6 16

Who Performed CBC
Outside private independent agency 8 36 7 19
Program’s university/college 7 32 6 16
Government agency 6 27 19 52
Multiple entities (i.e., state, federal,
private agency) 0 0 2 5
Did not know 1 4 3 8

Who Paid for CBC
Separate fee to applicant/student 17 77 33 89
Applicant paid as part of their
application fee 2 9 0 0
University/college paid 2 9 2 5
No charge, university police
department conducts 0 0 1 3
Did not know 1 4 1 3

Current Students and Criminal Background Checks
Regarding research question four, of the 83 participants, 45% (n = 37) reported that their programs
required current students to undertake CBCs. Table 1 provides a breakdown of the specialty track(s) that program contacts reported requiring students to undergo CBCs. The Fisher’s Exact Tests to determine an association between location of program and requiring applicants to have a CBC was found to be not significant (p = .500).

Procedures for current students. Table 2 provides a breakdown of the type of CBCs performed, who performs the current students’ CBCs, and who paid for the students’ CBCs. Further, two participants (5%) defined specific CBCs for certain specialty tracks: (a) state for all tracks plus federal for school students (3%, n = 1); and (b), state for college and marriage and family tracks, and state and federal for school students (3%, n = 1).

When asked when students’ CBCs are conducted, 35% (n = 13) reported it was before students are enrolled in internship, 27% (n = 10) reported during students’ first year, 19% (n = 7) reported before practicum, 8% (n = 3) reported before practicum and renewed for internship if the initial clearance was more than one year old, 5% (n = 2) reported during students’ second year, 3% (n = 1) reported at admission and then every two years after that, and 3% (n = 1) reported that CBCs are done every semester a student is enrolled in prepracticum, practicum, and internship. Participants reported various ways of letting students know that CBCs are a part of the program requirement. Twenty-seven percent (n = 10) reported that notice is given via the program’s handbook; 24% (n = 9) give it through orientation (i.e., new student, clinical), written correspondence (i.e., e-mail, letter), handbooks (i.e., program, clinical), and program Web site; 19% (n = 7) give it only through a verbal discussion (i.e., orientation, interview); 14% (n = 5) by give it by program’s Web site only; 11% (n = 4) through multiple methods of orientation (i.e., new student, clinical), written correspondence (i.e., e-mail, letter), handbooks (i.e., program, clinical), program Web sites and written correspondence; and 5% (n = 2) only via written correspondence (i.e., e-mail, letter, application).

Established protocols for current students. Sixty-eight percent (n = 25) of the 37 CACREP-accredited programs who reported requiring students to undergo CBCs had established protocols for deciding what action to take toward a student based on the CBC results. Twenty-seven percent
(n = 10) provided that their program had not established a procedure and 5% (n = 2) reported that they did not know if their program had a recognized policy. Although 25 participants reported that their programs had established procedures, a few responses suggested processes might be informal. For example, one participant stated, “Nothing formal. We hold informal conversations amongst faculty.”

Legal and Ethical Obligations
The following information was collected to answer the final research question. Of the 83 participants, the majority (64%, n = 53) reported that licensure or certification was dependent upon a successful CBC for students who graduate from their programs. Twenty percent (n = 17) of the respondents indicated that passing a CBC was not necessary for licensure or certification, leaving 16% (n = 13) who did not know if licensure or certification was contingent on having a successful CBC. The majority (89%, n = 74) believed that it was the program’s obligation to notify students that CBCs can be required as part of certification, licensure or employment as a professional counselor; however 5% (n = 4) believed it was not the program’s responsibility and 6% (n = 5) provided they did not know. Eighty-seven percent (n = 72) reported that their programs notified students that a CBC may be required to obtain certification, licensure or employment, leaving 13% (n = 11) of the programs saying they did not notify their students. When program contacts (n = 72) were asked how students are notified of this, 34% (n = 25) stated during orientation, 25% (n = 18) provided this information during the application process, 14% (n = 10) reported the information is continually given throughout the program (i.e., admission, orientations, before field placements), 10% (n = 7) stated the information was shared sometime during the first year of the program, 3% (n = 2) provided the information during field placement orientation for practicum and internship, 3% (n = 2) indicated information is given via student handbook, and 7% (n = 5) provided information was given via other means (i.e., during field placement discussions, when students apply for licensure due to licensure requirements varying by state).

When program contacts were asked if they believed it is ethical for their programs to perform CBCs on applicants or students, 41% (n = 34) believed it was ethical to perform CBCs on applicants and students, 29% (n = 24) felt it was not ethical for applicants or students, 19% (n = 16) responded it was ethical only for current students, and 4% (n = 2) said it was ethical only for applicants. Eight percent (n = 7) responded to this question by providing an alternate response.

All participants’ (n = 83) responses for strongly agree and agree were combined to report the subsequent findings. Sixty-six percent (n = 55) believed that counseling programs’ use of CBCs on applicants and students is important to ensure future clients’ welfare and safety. When asked if counseling programs completing CBCs on applicants and students violate the privacy rights of applicants and students, 17% (n = 14) either agreed or strongly agreed that it did not. Thirty-six percent (n = 30) believed that counseling programs can face legal consequences if CBCs are not conducted on applicants or students. Further, 24% (n = 20) responded that they believed that counseling programs can face legal consequences by performing CBCs on applicants or students. Thirty-three percent (n = 27) believed that there should be a CACREP standard regarding CBCs of applicants and students to ensure consistency and provide an established protocol. When asked if performing CBCs on applicants and students will result in a disproportionate screening-out of minority applicants and students, only 14% (n = 12) believed it would.


There were two primary aims of this study: (1) to assess the current use of CBCs by CACREP-accredited master’s counseling programs and (2) to offer current information for programs to reference when considering the use of CBCs and creating relevant policies. Within the field of counseling, few studies have explored the use of CBCs and related policies (Erwin & Toomey, 2005; Swank & Smith-Adcock, 2014). As aforementioned, Erwin and Toomey conducted a study in 2005 with only 50 programs that responded. Additionally, only five of the programs that responded used CBCs, which limited the utility of their findings. Swank and Smith-Adcock (2014) surveyed counselor educators about the effectiveness of their current screening procedures for applicants. Their participants reported wanting to use more reliable and objective methods such as background checks, but were unsure how to do so with minimal guidance in the literature.

In the present study, 27.7% (n = 23) of respondents reported requiring applicants to undertake CBCs. Although this may seem like a small portion of the sample, it still offers the field knowledge that can augment findings by Erwin and Toomey (2005). This result is not surprising given that there are so few guidelines for programs to use when considering CBCs as a screening and gatekeeping tool. The use of CBCs also remains underdeveloped in other fields such as nursing, medicine and sports science (Farnsworth & Springer, 2006; Kleshinski et al., 2011; Weuve et al., 2008). In fact, Farnsworth and Springer (2006) reported that fewer than 50% of the medical programs they surveyed reported using CBCs. They found this extremely concerning as the field of nursing requires all graduates to pass a CBC in order to become licensed. This is a related issue for those wanting to become a licensed mental health counselor as 17 states report requiring an applicant to pass a CBC in order to become licensed. All the states that do not require CBCs ask for the applicant to describe any criminal offenses on their application and provide further documentation when necessary.

Although 41% of the participants surveyed in the present study reported the use of CBCs as ethical, this finding did not correspond with actual use of CBCs (26.5%). One factor may be related to fear of potential liability when using CBCs. In a study conducted by Swank and Smith-Adcock (2014), participants, who are educators, stated that they would like to use background checks, but they felt hesitant due to the litigation that can come with such methods. These fears may be exacerbated by the fact that the use of CBCs is not universal across university programs and there may be little knowledge about how to seek out university lawyers when developing these requirements. At this time, most university guidelines around CBCs focus on use with employees (Swank & Smith-Adcock, 2014). Weuve et al. (2008) described that lack of guidance and misuse of results continues to keep graduate programs from using CBCs. In the present study, only 13 of the 23 programs who reported using CBCs had an established procedure for how to use the results. Ultimately, since few resources are available to assist in these decision-making processes, it would be important for programs to seek university counsel. For example, it would be important to seek legal counsel when deciding how requirements and standards should read on program Web sites, how to use the results, and how to inform students about the use of the CBC results.

It also is important to consider other related liability issues such as faculty subjectivity. Previous research indicated faculty subjectivity may interfere with gatekeeping fidelity (Brear & Dorrian, 2010). In the current study, only 13 participants reported their program had an established procedure for deciding about the non-admission of applicants based on CBC results. When procedures are not in place, there may be a greater potential for phenomena such as the empathy veil effect, leniency effect or likability effect. Such phenomena may prompt some faculty to look the other way if not held accountable to exercise a specific policy.

This research also has implications for counseling students. Given that not all programs execute CBCs, students may not understand the consequences of their legal violations until seeking licensure. Currently, 17 state licensing boards require CBCs and all states ask applicants to attest to criminal violations (ACA, 2010). There is potential for a student to get through his or her training program and be ineligible for licensure due to their criminal background. A need exists to consider how CBCs may be used to help students gatekeep themselves and be more conscious of barriers that may ultimately interfere with their professional goals.

Limitations and Areas for Future Research

This study has five basic limitations. First, the sample was obtained from program contacts of CACREP-accredited master’s counselor education programs. This approach omitted programs that were not CACREP-accredited. Therefore, generalizability of the results is limited to CACREP-accredited programs. Further, this study did not delineate whether the programs were housed in private or public institutions. Future research focused on investigating all professional counseling programs would be beneficial. The third limitation is that volunteers may have answered the survey questions differently than those members of the population who did not agree to participate (70%). The fourth limitation is associated with the survey being a self-report measure; some participants may have provided responses considered to be socially desirable. Even though the participants were informed in advance that their responses would be kept anonymous, they may have responded in a manner that was not representative of their true feelings or knowledge. The final limitation is related to instrumentation. The findings could have been expanded upon by including questions on the survey about consequences programs have experienced when using or not using CBCs. For example, have any programs been sued for using or not using CBCs?

Given the minimal amount of research in this area, there are multiple directions for future research. One suggestion is to qualitatively explore programs that have used CBCs for several years to get a more thorough understanding of how their processes have evolved. This may help programs understand the elements to consider when using CBCs as part of the screening and gatekeeping processes. It also may support programs in understanding how to protect themselves from liability concerns related to using CBCs. Another future study may involve surveying doctoral-level counseling programs to examine differences across training levels. Further research could examine student perspectives of the use of CBCs. It might be possible that students would welcome the use of CBCs at the program level so they are aware of legal standards at the start of pursuing a professional counselor license.


Since screening and gatekeeping is such an important role of a training program, the use of CBCs is an important topic for counselor education. The use of CBCs may assist counselor educators in executing their ethics related to not endorsing CITs they believe to be unqualified (ACA, 2014). The consequences of graduating a student with a criminal history could be great and ultimately put future clients at risk for harm. Perhaps CACREP could assist programs in understanding if and how to use CBCs by adding ideas for best practices in their accreditation standards. Previous literature has indicated that the field of counseling may benefit from creating more formalized screening procedures that include objective and reliable measures (Swank & Smith-Adcock, 2014). The current study offers support that programs are using CBCs as a part of the admission process and to continually evaluate their students. Given this is a trend, it may be important to establish best practices and policies around CBCs so that programs are using them in consistent ways.

Conflict of Interest and Funding Disclosure
The authors reported no conflict of interest
or funding contributions for the development
of this manuscript.


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Maribeth F. Jorgensen, NCC, is an Assistant Professor at the University of South Dakota. Kathleen Brown-Rice, NCC, is an Assistant Professor at the University of South Dakota. Correspondence can be addressed to Maribeth Jorgensen, 414 East Clark Street, Vermillion, SD 57069, maribeth.jorgensen@usd.edu.