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Two Competing Licensure Portability Plans

A curious thing happened late this summer – two competing plans for licensure portability emerged.  This is a long post, but make sure you also get to the 2nd plan below from AASCB.

AMHCA-ACES-NBCC Portability Standards for Counselors
(link to actual plan document)

This first one is bad.  It is a joint plan by AMHCA, ACES, and NBCC which calls for:


• A degree from a clinically focused counselor preparation program accredited by CACREP;
• Certification as a National Certified Counselor;
• Fulfillment of standards adopted by a state counseling licensure board;


• Possession of a counselor license for independent practice for at least two years.

The problem here is that NBCC has indicated that the NCC certification will require a CACREP degree for new applicants after 2022.  So while this plan gives a grandfathering period for all of us non-CACREP counselors to go grab and hold an NCC certification for life,  it very much fits with the CACREP-Only stance.  There does appear to be an exception there for state boards which don’t take their obvious suggestion that CACREP should be involved and instead set their own standards.

This plan also represents a financial bonanza for NBCC.  Non-CACREP counselors – if they ever want to be able to move out-of-state – are going to flock to grab the NCC credential right now while they still can.

Think about the money involved…  Some non-CACREP counselors may need to take another exam.  We are not sure what the original application cost is.  A 2014 newsletter said that annual maintenance fees were $80 per year.  Then of course NBCC sponsors and approves many of the CEU courses necessary for maintaining NCC status, but we won’t count that money…

Let’s do a little bit of back-of-the-envelope calculating although certainly the figures will be off.  Let’s assume:

  • This plan succeeds exactly as written (we’ll see)
  • 56,000 ACA members (although not all counselors are ACA members)
  • 70% are non-CACREP
  • 50% of the non-CACREP folks decide to maintain NCC status in case they ever need to move anywhere in their lifetimes.
  • We magically assume that all of these folks will work another 20 years so they all keep their NCCs for 20 years.

56,000 ACA members X .7 non-CACREP X .5 elect NCC status X $80 X 20 years = $31,360,000

This number is bogus of course, but however you calculate this, NBCC will make a fortune.

On a per person basis (assuming fees never rise) that is:

1 person X $80 X 20 years = $1600

This essentially amounts to extra money these folks would not have had to pay at all, except that NBCC participated in the CACREP-only enterprise of making their non-CACREP degrees second-rate, and then charged this membership fee so that at least these non-CACREP counselors could move around the country.

If they can get a job.  And take insurance and government programs.  And work around TRICARE, the VA, maybe Medicare, etc.  Good luck.

But – if they can make a living – perhaps in time they will appreciate their NCC membership as NBCC continues to offer more and more services that make NBCC nearly indistinguishable from ACA, minus some of the democracy and elected positions.

AASCB (American Association of State Counseling Boards)
(link to actual plan document)

The American Association of State Counseling Boards is what it sounds like – the place where all the state boards in charge of professional counselor licensing get together to hash out high-level issues, such as licensure portability.

Many of the state boards are resistant to the CACREP-Only cry.  Many states have lots of counseling psychology masters programs and/or few CACREP programs.  Others are worried about having enough counselors to serve their population, basic fairness in the profession, or other concerns.

On the other hand, CACREP and NBCC and ACA are all over their annual convention with money, presentations, and officers present.  CACREP and NBCC regularly sponsor events and underwrite costs.  This does not imply undue influence, but does illustrate some of the CACREP-Only pressures this organization is under.

The AASCB has tried to come up with a core set of requirements for years for counselors to be able to port their licenses from state-to-state.  They have finally hit upon an elegantly simple plan:

A fully-licensed counselor, who is licensed at the highest level of licensure available in his or her state, and who is in good standing with his or her licensure board, with no disciplinary record, and who has been in active practice for a minimum of five years post-receipt of licensure, and who has taken and passed the NCE or the NCMHCE, shall be eligible for licensure in a state to which he or she is establishing residence. The state to which the licensed counselor is moving may require a jurisprudence examination based on the rules and statutes of said state. An applicant who meets these criteria will be accepted for licensure without further review of education, supervision and experiential hours.

Furthermore “AASCB is open to research supporting a shorter time period if the research indicates no difference in disciplinary issues with those licensees who have less experience.”

This plan has several benefits, not least of which is that the plan does not mention CACREP by name and is much more inclusive.  Also:

1. It leaves more power to the states to determine what their needs are.

2. It does not tie state governments to the dictates of one outside body (CACREP) with whom they may or may not agree in the future.

3. It places more value and respect with counselor experience than with only the accreditation of the degree obtained.

4. It does not require multiple millions of dollars to be funneled into NBCC by non-CACREP counselors holding onto NCC status in order to have license portability.

In our humble opinion, it suggests that AASCB may not be entirely sold on CACREP and only CACREP as in the best interests of the profession and the public at large.

Please look for every opportunity to support the AASCB plan, including writing letters of support to their Board.

TRICARE CACREP Advocacy Alert – Highest Importance

Click here for a sample letter in Word .doc format

Click here for where to send letters (.xlsx Excel format)

[Posted for Licensed Clinical Professional Counselors of Maryland and all Concerned Counselors everywhere.]

This is a very urgent request. Please distribute this important information to all LCPC members, Counseling Psychology professors, students, and all interested parties. Thank you!

Even if you do not work with TRICARE beneficiaries, please still advocate for those who do. How the TRICARE eligibility language for LCPCs is written could impact how the MEDICARE eligibility language is written; and this could have a vicious trickle down affect into private plans who follow MEDICARE’s policies, if CACREP restrictions are retained.


Dear Colleagues:

I hate to ask you second time in a month for your help, but I really need it. As you may have heard, the American Counseling Association lobbied for more inclusive language in the National Defense Authorization Act that would allow all LCPCs with 5 years of experience to be Independent TRICARE providers. This change would lift the CACREP restrictions until 2027.

I need you to email the staffers of the legislators listed below to tell them why CACREP only language excludes highly qualified providers from serving members of the military and their families.

Even if you do not work with TRICARE beneficiaries, please still advocate for those who do. How the TRICARE eligibility language for LCPCs is written could impact how the MEDICARE eligibility language is written; and this could have a vicious trickle down affect into private plans who follow MEDICARE’s policies, if CACREP restrictions are retained.

I can’t overstate enough how important this request is for protecting our practice rights into the future. I have attached model language for your email, provided by our federal lobbyist, Ellin Nolan. Please tweak it as you need to, or simply send an email from the heart. These are usually the most powerful. I also attached a list of the emails of the staffers of the key legislators.

If you only email a couple of staffers, this will make a big difference.

Thank you for your advocacy. Please take a moment to send an email or two, it will make a world of difference to your profession.

Larry Epp, Ed.D., LCPC

President, Licensed Clinical Professional Counselors of Maryland


Senator John McCain (R-AZ)—Chairman

Senator Jack Reed (D-RI)-  Ranking Democrat

Senator James Inhofe (R-OK)

Senator Kelly Ayotte (R-NH)

Senator Clair McCaskill (D-MO)

Senator Jeanne Shaheen (D-NH)

Senator Kirsten Gillibrand (D-NY)

Senator Mazie Hirono (D-HI)


Congressman Mac Thornberry (R-TX)  Chairman

Congressman Adam Smith (D-WA)

Congressman Rob Bishop (R-UT)

Congressman Jim Langevin (D-RI)

Congresswoman Niki Tsongas (D-MA)

Congressman Seth Moulton (D-MA)

Congressman Donal Norcross (D-NJ)

Congressman Frank Lobiondo (R-NJ)

Click here for a sample letter in Word .doc format

Click here for where to send letters (.xlsx Excel format)

El Paso Newspaper Understands the Problems TRICARE Rules Cause Local Community

El Paso is home to Fort Bliss and quite a number of veterans, service members, and their families.  The El Paso Inc. newspaper ran a story this past Sunday entitled New rules could limit mental health care for soldiers.

In this story reporter Robert Gray interviews a few local clinic owners expecting huge changes as a result of the TRICARE “proposed” rule changes which will only allow CACREP counselors to join the panel as of January 2015.  (As of this time the “proposed” rules are rather imminent and the switch-over is well under way, pending last minute reversals.)  One clinic has 11 therapists scrambling to test into the grandfathering period this Fall.  Another estimates that 40% of their clients will lose services at their clinic.

Mr. Gray also asked the smart question of how many service members and their families were being referred off base to community supports.  The military was unable to comment, making it difficult to know the full extent of the difficulties faced.  He followed up by starting to address the related scandal of the Veteran’s Administration CACREP-only policies.

As one of our staff members interviewed in the article put it, “with the current bright spotlight on veterans’ lack of mental health care and VA wait times, we are amazed that tens of thousands of qualified professional counselors being cut out by CACREP-only policies is not a national scandal.”

We hope this is the first of many stories focusing on how TRICARE and VA CACREP-only policies damage communities nation-wide.


Thank you for coming to our blog.  We intend to post blog updates for military families, veterans, licensed counselors, legislators and public officials, and the general public about problems in certification of counselors.

This topic seems a bit esoteric and boring at first.  Its important to understand that certification can act like a gatekeeper.  When accessing services you want gatekeepers that make sure the services you access are of high quality.  What you don’t want are gatekeepers that arbitrarily restrict services available for obscure or arbitrary reasons, resulting in a shortage of services for your needs.  If you are a counselor (service provider) you want to be able to offer the services you were trained to do without being cut out of your career.

Please visit the main sections of our website at to see what we are about.  While you are at it, you can look in the right-hand column of the website for ways to subscribe to this blog and/or to our periodic newsletters and action alerts.