Most boards are a bunch of dummies.
Realistically, that’s not your problem. Your state and counselors board has some rules about that. Look them up. I’m guessing it’s a “see something , say something” scenario, like every other mandated reporter scenario. You are reporting a concern, not reporting an impairment. The board and its agents (including the professional doing the ffd) are responsible for determine if there is impairment.
Do the Nancy Grace, “I’m asking if this reportedly suicidal counselor might be impaired!” I’m not saying he/she is! I’m just asking questions!”.
it’s stupid, but that technique has been vetted by many many many Ivy League attorneys.