Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Counseling
 
chapter
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]
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10/10/18  12:28 pm
Commenter: Cynthia Miller

Oppose adoption of NCLEP as it currently reads
 

I OPPOSE the adoption of NCLEP.  I am completely in favor of making it easier for counselors to transfer their licenses from one state to another but I believe the NCLEP proposal makes the process of portability overly restrictive.  The proposal states that a counselor who is fully licensed for independent practice in one state would be eligible for licensure by endorsement in another state only after that counselor has acquired at least 3 years of post-licensure experience.  I see no reason for a 3-year timeframe.  It essentially forces a counselor to remain in the state they are licensed for at least three years after licensing before they can move somewhere else and have their license be recognized.  I know of no other profession that requires someone to practice for three years in the state they are licensed before becoming eligible to move.

 

If the Board of Counseling wants to make portability easier I would encourage it to adopt the American Counseling Association's which states:  A counselor who is licensed at the independent practice level in their home state and who has no disciplinary record shall be eligible for licensure at the independent practice level in any state or U.S. jurisdiction in which they are seeking residence. The state to which the licensed counselor is moving may require a jurisprudence examination based on the rules and procedures of that state.”
—Approved by the ACA Governing Council, June 2016

CommentID: 67507