Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Counseling
 
chapter
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]
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11/29/18  9:56 pm
Commenter: Willard Vaughn

Rationale
 

I was the one that created this rule petition, and wanted to explain why I think it is necessary.

Hypothetically, let us say you have a private practice with three licenesed clinicians and three "residents" or "pre-licensed" people.  Ethically speaking only the three licensed clinicians should be able to advertise, but since there is this loophole in the board's wording, that is not the case.  So now instead of three clinicians listed on a particular website (i.e. Psychology Today), you now have six.  What this does is create backlinks to your website and those backlinks is one of the determining factors for what order your website appears in search engines.  So in other words, the more mentions you get, the higher your return when someone Googles something such as "counselors in...".  This creates an unfair advantage in advertising.

Secondly, if I see an ad for someone and I call them to schedule an appointment, I'm going to assume that that person can provide the service I want.  An average person is not going to know or care what a "resident" is, and what that means.  So when you advertise yourself even with the designation, it is, in my opinion, misrepresenting what you are to the general public and creating harm. 

CommentID: 68803