This petition appears to more of a personal grievance with market share of clientele vs. resident's promoting and advertising and/or independently soliciting business from the public, per the petitioner's comments regarding his rationale (see comment section for public comment on 11/29/18 9:56 p.m.) for the petition.

Per 18VAC115-20-52. Residents may not call themselves professional counselors, directly bill for services rendered, or in any way represent themselves as independent, autonomous practitioners or professional counselors. During the residency, residents shall use their names and the initials of their degree, and the title "Resident in Counseling" in all written communications. Clients shall be informed in writing of the resident's status and the supervisor's name, professional address, and phone number. 

18VAC115-20-52. The supervisor of a resident shall assume full responsibility for the clinical activities of that resident specified within the supervisory contract for the duration of the residency.

Limiting advertisement is an unnecessary burden that may limit access to residency training in private practice for Residents in Counseling in the Commonwealth of Virginia. I would like the thank the Board of Counseling and the petitioner for offering the opportunity to voice my strong opposition to the proposed petition. 

Respectfully,

Kimberly J. Nichols, M.A., Resident in Counseling