I strongly oppose the proposed regulations for licensure by endorsement. In essence, this proposal is an attempt by CACREP to restrict trade by clearly favoring counselors to be eligible for licensure if they graduated from a program accredited by CACREP or hold the NCC credential (access to which will be limited to graduates of programs accredited by CACREP effective 2024). The current proposal, while offering several options for all licensed counselors, falsely suggests that licensed counselors who graduated from programs accredited by CACREP (who would need 3 years post-licensure experience) are more qualified than those who graduated from other programs (who would need 10 years post-licensure experience).

There is no documented evidence that licensed counselors who graduated from programs accredited by CACREP are better prepared than their peers who graduated from other programs! Why then, should the majority of licensed counselors (who did not graduate from programs accredited by CACREP) be required to show 7 more years of experience than their peers who graduated from programs accredited by CACREP? 

The ACA Portability Plan is a significantly better option than this proposal!

The Alliance for Professional Counselors fully supports portability for all counselors and the American Counseling Association’s (ACA) 2016 Portability Plan. The ACA Portability Plan would permit counselors licensed at the independent level in one state (who do not have any disciplinary actions against them) to qualify for independent licensure in any other state in which they are seeking residence. Duly licensed counselors would be treated equally across the nation under this plan.

See this link for a brief intro, actual text of the ACA plan and FAQs https://www.counseling.org/knowledge-center/aca-licensure-portability-model-faqs#

Thank you for the opportunity to comment on the proposed legislation.

Sincerely,

Michael Ellis, Ph.D.