There is mounting evidence that school counselors positively affect students' academic and behavioral outcomes. Yet, federal policymakers do not seem to view school counselors as principal agents of school improvement, and state policies vary widely regarding their availability. Thus far, little empirical work documents the distribution of school counselors among and within states and the factors associated with these distributions. In this study, we use national population data and descriptive and multivariate, fixed-effects regression models to examine inter- and intra-state variation in districts' use of school counselors. We reveal significant variation in students' access to school counselors with the preponderance of variation occurring within states. Like many educational resources, school counselors are distributed inadequately and inequitably among districts and students.