I am opposed to the proposed rule on several grounds. There is no research to support that any number of years' experience, whether two or ten years, can compensate for curricular deficiencies. This is an arbitrary requirement with no data foundation.

Setting a CACREP standard would be a good idea, only if there were provisions for accepting the credentials of counselors who received their education and degrees prior to there even being a CACREP, or in geographic areas where access to CACREP programs was limited or nonexistent. Since there is no such provision, I think it's premature to require this. Most professions when they take this step provide for equivalencies for a set period of time so as not to disenfranchise licensed professionals whose record is exemplary in their current state but who want to re-locate. I see this as a restraint of trade issue.

There is already a shortage of mental health providers across the country. The proposed rule would have the unintended consequence of decreasing the pool even more, at a time when we are experiencing a dire shortage of people qualified to treat the crisis we are in with opioids alone, not to mention school shootings, mass disasters, and rampant child maltreatment.