I am writing to urge you to reject the proposed new rule for counselor licensure, requiring graduates of programs that are accredited by organizations other than CACREP to have an additional 7 years of experience. I would like to remind the Virginia Board of Counseling that their role is to protect the public. There is no evidence to support this requirement, and it will seriously limit the availability of mental health services to Virginia residents, at a time when the need for mental health support has greatly increased. As an educator in a program that has been training counselors for responsible professional practice for decades, I cannot see this proposal as anything other than an effort by a large guild to provide its own graduates with a privileged position, at the expense of graduates of equally rigorous training programs. Please reconsider this ill-advised and clearly self-serving proposal.

Thank you.