To speak directly to the rationale stated for this petition;

1) Unfair advantage in advertising- This is not an ethical issue.

2) Counselor’s designation as Resident in Counseling/Pre-Licensed Therapist being a misrepresentation of status and creating harm- You know what they say about “assume”. 

If someone calls me, the first thing I iterate is that I am a resident, meaning unlicensed and completing hours to earn said license under the supervision of two credentialed therapists. I draw the comparison to a doctor completing rotations to “practice” prior to earning their M.D.. for understanding. Most potential clients do not have issues with that (the primary reason a client chooses to work with someone else, from MY experience only, is because they want to use their insurance). Upon starting sessions, they clearly see in my paperwork “Resident in Counseling, supervised by” SEVERAL TIMES; complying with regulation 18VAC115-20-52, and it doesn't’t stop there. As I facilitate sessions, if I come across issues that I do not feel I can address adequately, I TELL MY CLIENTS DIRECTLY that I am going to consult my supervisors, as I want them to receive quality care and I am not an expert. I have not had clients terminate due to this, partly because they were aware from the beginning that I’m still in the learning process.

Mr. Vaughn, I’m sure you were once a Resident in Counseling/Pre-Licensed Therapist. I would hope you felt competent enough to work with clients in a private practice setting and self-aware enough to know when to seek counsel (outside of regular supervision meetings). I am confident my fellow Residents in Counseling are astute when providing services, as ethics are at the core of our profession. It appears to me that your supplication is based on personal objections, therefore, I firmly oppose the proposed petition.

Regards,

Nicole J. Low, M.Ed, NCC, PPS, Resident in Counseling, QMHP-C