Hello, I am a licensed professional counselor in DC (and have been for 7 years).  As my career, I work for a national association advising students and recent graduate, and many of our conversations concern about their options for mobility and licensure. I am well aware of the challenges of portability and believe these recommended changes will restrict Virginia residents' access to qualified counselors. In recognition of the number of areas of Virginia that are federally designiated as medically under-served, creating a pathway fro NCLEP that segrates the options from other licensed or license-eligible providers is very problematic. It worsens the crisis of limited access to healthcare. Instead, I fully support the ACA's portability plan as outlined at

https://www.counseling.org/knowledge-center/licensure-requirements/licensure-portability-model-fact-sheet.

Thank you for your attention.