This proposal is discriminatory for qualified professionals who obtained high quality degrees from universities that do not have CACREP accreditation. This proposal not only harms professionals who need to relocate to the state of Virginia but also the abundant amount of clients who are unable to locate professionals to obtain services. This proposal simply further exempts highly qualified professionals from other states and jurisdictions in assisting with the high demand for mental health an substance abuse services in Virginia.

Virginia should adopt the fair and simple Portability Model of the American Counseling Association in which 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.