Upon learning of this proposed regulation change, I was perplexed at best, and dumbfounded at worst. The proposal appears short-sighted, and ignoring already enforced regulations in place that allow Residents to only advertise their services as being unlicensed individuals, under supervision from an approved supervisor, and only practicing with clients that they have a level of competence in treating, as guided by their supervisor. Prohibiting Residents from advertising their services, either on a paid site like Psychology Today (with all appropriate and required references to their clinical supervisor) or within an organization's web page is only a means to make it harder for Residents to become Licensed Clinicians. This appears to be an attack on Residents from a person worried about their own ability to earn an income through their chosen route of service delivery, and not one that is aiming to "alert" the public about Residents being unlicensed counselors. If my own small private practice can attest, we have more than enough folks who are seeking out counseling services, and many who continue to remain without insurance, or who choose to not utilize insurance for mental health services, and Residents can still provide needed services under supervision in a way that enables the potential client to not experience an undue financial burden in seeking treatment.

While we may all differ in our theoretical orientation, methods of service delivery, niche populations, and levels of experience, we need to continue to support Residents on their taxing journey of becoming well-rounded, competent clinicians. If we don't provide them with the skills and knowledge to market their individual qualities in a private practice setting, they will not know how to do so, and would potentially lead to less clinicians practicing to meet the enormous needs of folks today. The proposed regulation only aims to diminish the confidence and practice ability of Residents, which is the antithesis of our profession, and hurts all of us. Please do not change any regulations for Residents to remove their ability to advertise appropriately.