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).

According to the current proposal, licensed counselors from other jurisdictions would be qualified for licensure by endorsement in Virginia if they either 1) meet all requirements for initial licensure in Virginia including specific coursework, supervised experience, and residency, or 2)  have 2 years post-licensure clinical practice in counseling in the last 5 years, which includes teaching graduate courses in counseling,  or 3) hold NBCC’s Certified Clinical Mental Health Counselor (CCMHC) for which the NCC and therefore, effective 2024, graduation from programs accredited by CACREP, are prerequisites, or 4) have held an active license in the other jurisdiction for ten years, or 5) have held an active license in another jurisdiction for 3 years and have either graduated from a program accredited by CACREP or hold the NCC credential (which, as above, will be limited to graduates of programs accredited by CACREP effective 2024).

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 (see above) is a significantly better option than this proposal.