Comment on DOD_FRDOC_0001-3037

I am concerned about the language of the interim final requirements for CMHC's. For example, incorporating the AMHCA supervision requirements is one thing for those seeking licensure and the newly licensed, but for those having licensure for a number of years does not make sense (those who may have acquired supervision hours by counselors, psychologists, and psychiatrists allowed for by their respective State or National certifying associations). Another concern is the strict "NCMHCE" exam rather than a "proctored clinical exam," for instance to allow for those who passed the ECCP or other State allowed exam at the "clinical level." Albeit, the requirements seek standardization, but it seems potentially discriminatory for those previously licensed and certified under alternate examination and supervision. In other words, why not broadening grandfathering consideration as long as the "intent" and "experience hours" are satisfied?