There are serious problems with this proposed ammendment because it only increases the portability of those counselors who come from CACREP programs. It would limit the portability of the majority of counselors who graduated from or are currently enrolled in programs that are not CACREP affiliated. With mental health demand so high, it does not make sense to throw up barriers to qualified counselors who wish to practice in Virginia.

It is also notable that the largest professional organization in the country for counselors, the American Counseling Association, opposes the NCLEP plan and had already endorsed a Portability plan in 2016. That plan is more flexible and inclusive, and would not limit options for qualified counselors to practice in Virginia the way the NCLEP would. The Virginia licensing board should consider their model instead.

As a mental health professional myself who has at times been a part of both CACREP and non-CACREP affliated programs, and finding no difference in quality between them (nor has research compelling demonstrated any difference in client care or outcomes between them) - it seems that it would be counterproductive to the needs of the citizens of Virginia to further limit their mental health care options.

Sincerely,

Sally D. Stabb, Ph.D.