Yes. If you are eligible without waiver you must be counseled.
IAW 600-8-19 para 3-11 c-d states:
For Soldiers fully qualified but not recommended, the battalion HR specialist will prepare the DA Form 3355 and forward it to the first-line leader for appropriate counseling. Once the counseling is completed, the CDR will forward DA Form 3355 and counseling documents to the promotion authority for final decision.
d. Once a Soldier has been counseled for not being recommended for promotion, the BN human resource specialist will not continue to provide a new DA Form 3355 to the CDR. Copies of the Soldiers periodic counseling (at least quarterly) will be provided to the promotion authority until the Soldier is recommended for promotion or is no longer eligible.
