The proposal incorrectly implies that counselors from CACREP accredited programs may be more highly qualified than those from non-CACREP accredited programs. There is no empirical evidence to support this (see the following research results: https://pdfs.semanticscholar.org/c39d/d6d5a4b812687fdca134b5e73d6cd9761732.pdf). The state of Virginia should follow the portability guidelines proposed by the American Counseling Association (ACA). Any alternative restrictions regarding license portability will only serve to reduce the number of qualified mental health counselors who are able to practice in the state, further limiting the availability of mental health services to its citizens.