As a licensed and nationally certified counselor I stand in strong opposition to these regulations, if enacted will greatly reduce an otherwise eligible workforce in a time when the need for qualified counselors is greater than ever before.  These regulations would eliminate highly experienced and well-qualified counselors from the ability to practice counseling in the state of Virginia. That eliminates current counselor's ability to have gainful employment and make a living. The proposed change does not raise the standard of quality in the field of counseling, rather it creates an unecessary barrier to the current licensed counseling profession and creates a direct financial benefit to schools of higher education that have achieved CACREP accreditation, where current counselors would need to return to continue their career.  Such a change will create an out-migration of licensed counselors from the state of Virginia into surrounding states, leaving the citizens in greatest need of counseling help with less access to timely care.