I wish to express my strong opposition to the endorsement proposal requiring graduates from non-CACREP programs to provide evidence of an additional seven years of training beyond what is required of their CACREP peers. This is an absolutely absurd regulation, there is no reason to require additional supervision that is more than twice the length of masters level graduate counseling programs.

1. There is no evidence that is not provided by CACREP which indicates that non-CACREP programs (and MPCAC or APA programs specifically) are inferior and do not appropriately train their graduates to work in the field. Evidence that is provided by CACREP has to be viewed through an appropriate lens of skepticism. 
2. I cannot think of an elected public service official who has not acknowledged the increased need for mental health and substance use professionals within their community. This proposal disincentivizes and creates a barrier for those who would provide those services. There are limitations to the places that non-licensed mental healthcare professionals can work, limitations to the amount of money they can earn, and limitations to the populations they can work with. These limitations are appropriate as part of our training, however it is completely unreasonable to expect someone to spend the better part of a decade in that position. When the number of people in the mental healthcare field already have extremely high rates of burn out, why would we put in place regulations to make the job more inaccessible? There will be less people to provide the services that are needed, which leads to an overwhelmed system and higher rates of suicide, overdose, incarceration, and CPS involvement.
3. CACREP requires that the colleges and universities core faculty (all the professors) have a PhD from a CACREP-accredited program. I can understand reading this and going, "Yes, that's fine," however, if we consider that this endorsement would essentially require every counseling student to attend a CACREP institution or start out at a disadvantage to all their peers, this acts as a barrier for completely qualified educational counseling professionals. An APA accredited Counseling Psychology program likely has a number of experienced, talented, and qualified staff who also graduated from APA accredited programs. CACREP will freeze out faculty that may be very good educators and great clinicians with a lot of relevant expertise and they do so to advance CACREP as an organization NOT because someone with a PhD in Counseling Psych is unqualified to teach Masters Counseling students (they are absolutely are).

I realize I have written a lot for you to read, however I sincerely hope you take the time to consider the information provided here. While this may seem a small matter to you, this would negatively impact potential future counselors, current counseling students who had the misfortune to pick a university that is fully accredited but does not have lobbyists, counseling professionals who provide education and supervision to the next generation, and, most importantly, the people who need the healthcare services that are provided by licensed counselors.

Please, I urge you with all sincerity to reconsider this proposal. There are so many barriers to access of healthcare and none of these will be better addressed by what is being suggested. I thank you for your consideration of what I have written.