I strongly oppose the proposed regulations for portability of license in VA.  I support the ACA and Alliance for Professional Counselors fair and inclusive plan.  There is simply no data to support the VA proposed regulations requiring professionals from non-CACREP programs to have 7 more years of work experience than professionals from CACREP programs to make their license portable --- there is absolutely no evidence that CACREP-accredited training programs are better than non-CACREP.