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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12/2/18  5:40 pm
Commenter: Willard Vaughn

Further comment
 

The Commonwealth of Virginia is satisfied that I have met the requirements to bestow upon me the title of Licensed Professional Counselor, so that gives me the green light to market myself anyway I want (within ethical guidelines) since I can practice independently, own my own practice, bill insurance, and have my own overly priced liability insurance.  This license also grants me the clinical judgement to make the best decision for how to treat my client and I am accountable to that decision by my license and the insurance that I have to carry.  

An intern, resident, or "pre-licensed" individual legally cannot practice independently, have their own practice, bill insurance (in some cases), or have overly priced insurance (though it does exist).  They are not accountable for their decisions as I am by a license or provisional license, and so if harm comes to a client or a bad decision is made, it falls to the supervisor.  A good supervisor is looking over their shoulder to make sure this doesn't happen, but rarely are regulations put in place as a result of a good decision being made.  

No one (well, I"m not) saying that interns are incapable of being providers, but the law says that they cannot present themselves as practicing independently until they have satisfied the requirements of the board. If they cannot practice independently, then they should not be able to advertise themselves independently because that makes the public believe that they have the same accountability to them that I have, which is not the case.  You can argue informed consent all you want, but if I want to talk to a counselor, and I get to my appointment and find that I'm only getting an intern when I wanted a counselor, then I have been mislead.  Many have said it is a personal issue and to a certain extent that is true because I have been that person, and its mildly frustrating.  

 

CommentID: 68822