Comment on DOD_FRDOC_0001-3048

In reading the document, I was amazed to find that licensed professional counselors are not listed as being eligible to provide services but unlicensed behavior analyst meet the requirement. Unlicensed professionals do not have the same oversights as professionals who are licensed. This means that impaired professionals could be working with children and has no direct body responsible to ensure that they are not harming the child. I believe this to be a mistake and suggest that the department withdraw these provisions until a study could be conducted to determine if (1) counselors can safely and adequately provide these services and (2) if having unlicensed people places the public in jeopardy.