I see that LOINC does not provide a definition for either of these so I’m going to give you my personal opinion. How other systems choose to implement the use of these may be different so your mileage my vary. An Education Note would be for content that is information that pertains to clinical or administrative care or patient interactions with the system/caregiver. So pretty general but with the intent of providing new information about something the receiver is interacting with/about. A Counseling Note would be specifically about an interaction where the patient has received something explicitly identified as a “counseling event” and should contain information pertinent to that direct encounter (or planned encounter.)