I am currently seeking licensure in VA (my family is interested in relocation) as a professional with over 25 years in the profession in various roles but recent licensure. My education was complete in 1992 at a time when standards were different. I completed additional courses at the Graduate Level to qualify to take the NCE and completed the supervision hours required in my state. I am highly regarded in the field and yet may have great difficulty with your current process despite being fully licensed in two states and having the NCC credential. I am not able to see who this serves. The proposed regulation does not seem to improve the issues at hand. There is no reason that Counselors should not have a license that is portable in the same way that of a Medical Doctor would be. The existence of so many different standards does not elevate the profession nor protect the public, it serves to add to the already serious issue of poor access to care in so many areas. Please consider the portability language suggested by the ACA.

Thank you