I am a Licensed Professional Counselor with approximately 20 years of private practice experience. Over much of this time, I have supervised multiple Residents and celebrated with them as they achieved their licensure goals.  Over the years, I have learned that to be a competent supervisor, one must have an excellent working knowledge of the rules, regulations, and laws governing counseling and to know how to apply them effectively in work with Residents.  The Board of counseling requires that Residents receive a full spectrum Residency experience to include patients from all walks of life.  They must have the opportunity and experience of conducting comprehensive assessments, making accurate diagnoses, planning appropriate and effective treatment, implementing treatment plans, then repeatedly assessing progress until termination.  The Resident must repeatedly accomplish each of these requirements in their work with a broad variety of DSM 5 disorders and syndromes using multiple treatment modalities and orientations. This can be a daunting task.  If this proposal is adopted, Residents will continue to be required to recur it their own patients.  But, they will have no tools to do so. Looking at all this as a whole clearly demonstrates the significant adversity this proposal would add to the already heavy (and necessary) burdens of Residency.

In the past, Residents sought out Residencies at sites that rarely met all of these requirements.  So, Residents are now required to find other options to ensure their experience met Board requirements.  This means finding sites that support the provision of this full spectrum experience.  The most likely sites for this are in Private practice settings. 

Supervisors take on considerable responsibility and risk for low pay to help Residents earn their chops.  We provide significant assistance with all aspects of this experience. However, we simply cannot provide the kind of client load necessary to provide the experience required by the Board.  For that reason, it is absolutely necessary for Residents to have the ability to advertise their services to recruit patients.  In doing so, they must not only identify themselves as a Resident to their patients, they must do so on all documentation, business cards, websites, etc. They can in no way represent themselves as independent clinicians. So, finding patients to build a caseload is a critical component to establishing and completing Residency in accord with the regulations.  

This kind of advertisement has little impact on other clinicians. There are always enough hurting people available to fill our offices.  Likewise, Residents provide services at a discounted price to meet the needs of their patients, including some who would not be able to seek services otherwise.   Since they are unable to accept payments from insurers, they in no way will compete with licensed clinicians who do.  And because all of their patients must pay out of pocket and pay at reduced rate below what most licensed clinicians would accept, they are not true competition for licensed clinicians whose patients pay put of pocket.  As for clicks per website, my Residents create their own sites. I do not receive any benefit from their "clicks."

In closing, I can see no benefit from this restriction, But, I can see many pitfalls if it is enacted.   Residents already face challenges in their efforts to meet the critically needed Board requirements that currently exist.  This proposal would hobble most Residents and prevent them from achieving their goals.  That seems a significantly onerous consequence to inflict upon new clinicians when the benefit is likely negligible. Therefore, I am opposed to this proposed change.