Disparate impact to non CACREP counselors, particularly recent graduates considering NCC qualifications would be dependent on CACREP accreditation in 2024. Since NCC is a prerequisite for the (CCMHC), endorsement B & D of section 18VAC115-20-45, Prerequisites for licensure by endorsement, would become invalid.

This would effectively mean within 5 years non CACREP counselors would need 10yrs of experience to be licensed, without supporting evidence CACREP counselors are better prepared than non CACREP counselors.

We advocate for high counseling standards and fair, useful portability. This isn't it.