I oppose the current proposed portability rule for professional counseling in Virginia. This proposed model is not supported by the largest professional association of counselors, the American Counseling Association (ACA). The model is unnecessarily restrictive, will disenfranchise counselors who have held professional licenses for many years from moving to another state, and does not protect the public becase it will remove professionally competent counselors from service if they need to move for any reason. Here is the model supported by ACA: “A counselor who is licensed at the independent practice level in their home state and who has no disciplinary record shall be eligible for licensure at the independent practice level in any state or U.S. jurisdiction in which they are seeking residence. The state to which the licensed counselor is moving may require a jurisprudence examination based on the rules and procedures of that state."