Public Comments for Events Organized by the FTC's Economic Liberty Task Force #00009

Submission Number:
David Bergman
National Board for Certified Counselors (NBCC)
Initiative Name:
Public Comments for Events Organized by the FTC's Economic Liberty Task Force
Joint Statement on a National Counselor Licensure Endorsement Process April 2017 During the last year, representatives of the American Association of State Counseling Boards (AASCB), the Association for Counselor Education and Supervision (ACES), the American Mental Health Counselors Association (AMHCA) and the National Board for Certified Counselors (NBCC) worked together to create a Portability Task Force with one goal: a safe, clear, reasonable portability process for all current and future counselors. The task force agreed upon five (5) key tenets, which informed each decision by the task force. Specifically, a uniform licensure endorsement process must: I. Significantly increase public access to qualified care; II. Establish minimum standards for safe practice; III. Reduce administrative burdens for both state regulatory boards and licensees; IV. Create consistency in licensure standards across state lines; and V. Ensure protection of the public and the continued development of the profession. The Portability Task Force agreed on the importance of honoring the work and practices already adopted by state regulatory boards while developing a portability process. Consequently, the task force conducted a thorough analysis of all state regulatory practices related to reciprocity, portability and licensure endorsement. This state-by-state analysis revealed the need for a more refined goal for portability-that of achieving a balance between establishing minimum licensure endorsement standards for public protection and moving the profession toward the future goal of unified education standards, examination requirements and years of postgraduate experience. Throughout our research, analysis and collaborative efforts, the Portability Task Force prioritized public protection and the future of the counseling profession over any one organization's previously established portability policy or organizational agenda. This deep commitment to unity is reflected in a portability process that represents meaningful compromises by AASCB, ACES, AMHCA and NBCC. By capitalizing on the historical knowledge of all organizations involved in the Portability Task Force and the history of state regulatory standards, AASCB, ACES, AMHCA and NBCC agreed upon a unified portability process that is as much a recognition of our shared past as it is a step forward into our shared future. In an era of a mobile workforce, which is increasingly receptive to innovative service delivery such as tele-mental health services and military-friendly licensure processes, a national portability process is more vital than ever. To be a counselor must hold the same meaning to a citizen as it does to a policymaker from state to state. After 30+ years of wrangling with the issue of portability, the time has come to pave a path forward for highly qualified current and future counselors to improve client access to services. We recognize that no portability process is a "silver bullet" that resolves all concerns related to portability. However, we strongly believe that our portability process will significantly benefit mental health consumers by increasing access to needed care and services and helping create a vibrant workforce of licensed counselors both in terms of changing regulatory standards and the increasing need for united advocacy efforts. In addition, for a secure counselor portability licensure process with ensured consumer protections to be in place, a careful vetting of counselors seeking portability should include background checks to strengthen public protection. Enhancing the ability of states to share investigative and disciplinary information will help assure the public that key protections are in place. AASCB, ACES, AMHCA and NBCC present the counseling profession's historic, united, collaborative portability process for all counselors licensed at the highest level of licensure for independent practice.