The proposed regulation amounts to restraint of trade. Licensed counselors who'd bring knowledge and skill to VA in order to serve the public would be restricted from professional practice for 10 years post-license at a time when there are public health and labor force crises. Qualified applicants would be unable to practice, earn a living, and pay taxes in VA based upon an unproven implication that CACREP trained counselors are competent in 3 years, but others are not competent for 10 years.  Most importantly, the public would be harmed by limited access to competent counselors at a time of crisis and by limited competition. The legislature in Florida recently passed legislation to eliminate a similarly restrictive law involving the educational requirements of counselors (see FLA SB 566: Mental Health Professional Licensure).  The regulation is also unnecessary.  There is a national legislative initiative underway (with the support of the ACA and AMHCA) to establish interstate compacts with the reasonable universal license portability standard of 3-years post-license practice.  The Dept of Defense offered support for such interstate compacts to protect the spouses of active duty personnel who are harmed by restrictive trade practices.  The FTC issued a 2018 report (which cited the DoD) that is also in favor of the interstate compact as the most efficient and effective way to resolve this issue. In sum, the proposed regulation amounts to restraint of trade and is unnecessary.