As longtime counselors and counselor educators, committed to professional advocacy and the welfare of those we serve, we speak against the NCLEP model.  We believe that as stated, the model would create unnecessary and undue barriers for qualified licensed counselors wishing or needing to move to another state, without evidence that these barriers would indeed protect the public and members of our communities.  In particular, we oppose the 3-year post licensure requirement indicated by NCLEP.  We do so based on the available data that suggests that new professionals are less likely to commit ethical violations when compared to more seasoned counterparts (Even & Robinson, 2013; HPSO Professional Liability Insurance data via professional communication).  We recognize that new professionals invest tremendously in their training and post-training licensure requirements.  They enter this profession of service, and work very hard to obtain their degrees and training.  These new professionals deserve our advocacy, and the opportunity to use their degrees in practice should they choose or need to relocate to another state.

We recognize that as a profession we do not yet have unified training standards.  However, data indicates that states are becoming increasingly standardized, (AASCB, 2015) in training and post-graduation supervised internship requirements, with many states requiring a 60 hour program, and 3,000 or more hours of supervised internship.  We believe that this, in itself, is a rigorous requirement.  To say to these students and new professionals they must wait an additional three years after completing approximately 5 years of training and supervised licensure sends a message of institutional mistrust of their competency to our new generation of counselors, and runs the risk of depriving some individuals and communities from needed services.

If data were to show that a 3 years post-licensure requirement proposed by NCLEP would protect the public, and that newly minted licensed counselors truly create a threat with respect to their ethical or practice service delivery, we would not oppose a plan with this stipulation.  However, given that data indicates otherwise, we can see no reason to increase the burden for new professionals who have already invested exceedingly into their careers. 

Each of us have longtime practices as counselors and/or counselor educators.  The NCLEP model, as stated, would not interfere in our work or our practices.  However, we so strongly oppose the 3-year post-licensure requirements on behalf of our newer counselors, who bring energy, training, skill, compassion, and a great desire to serve others into their work.  It is not always easy to be a new member of a profession and to know how to advocate for oneself, to make the calls, and participate in advocacy measures such as this one.  We believe it is our responsibility to do so, with them, and on their behalf.  Please vote against this restrictive and unfounded requirement.

Thelma Duffey, Ph.D., LPC, LMFT

     Professor and Chair

Robert L. Smith, Ph.D., NCC, CFT

     Professor, Counselor Education & Supervision

Shane Haberstroh, Ed.D., NCC

     Associate Professor

Judy A. Daniels, Ed.D, CRC

     Professor

Sandra Kakacek, Ed.D., LCPC

     Director of Training, CMHC & MACR