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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12/12/18  3:48 pm
Commenter: Megan MacCutcheon, LPC

Experience for residents, not website SEO
 

I am strongly opposed to this amendment and don’t think restricting the ability to advertise serves any benefit for anyone in our profession.  Restricting a resident’s ability to advertise hinders their ability to gain clients and, thus, the experience they need to work toward licensure.   As the regulations currently read and are commonly interpreted, Residents are expected to identify themselves as such, using the title Resident in Counseling, and state that they are under the supervision of a licensed professional. 

Most residents I know (and supervise) provide the supervisor’s contact and licensing information on their websites and in their policies documents, making it very clear that they are not practicing independently.  The ability to advertise services clearly stated as being part of a residency/under supervision does not seem to be an ethical issue, so I don’t follow the rational that only licensed practitioners can have Psychology Today profiles, nor do I understand how being a resident equates to being unable to “provide the service [the person seeking counseling] wants” (per Mr. Vaugh’s comment and rationale).  True, the general population may not understand the differences between “Licensed” and “Resident;” however, difference in title and years of experience does not necessarily equate to ability to effectively provide counseling. 

Misrepresenting yourself/false advertising is a separate ethical issue that anyone, licensed or not, can violate…i.e. advertising and/or practicing services outside of your scope of practice or area of expertise.  Simply advertising your services and having online profiles does not, in and of itself, cross in to this area. 

Rather than focus on creating more restrictions for residents, time would be better spent ensuring that residents are getting the training, supervision, direction, and practice necessary to become successful and ethical practitioners so they are ready to take on the role of practicing independently upon becoming licensed.  Part of being a successful practitioner (and thus representing our profession in the best possible light) involves knowing your target audience and effectively making resources available to them, and I feel this is worth exploring during residency, while under supervision and guidance of somebody with years of experience. 

I’m not really sure that competing with residents for backlinks for website search engine optimization is a logical factor in this petition.  It seems like the solution to that is to invest more in your own advertising and SEO rather than look to change regulations that ultimately create unnecessary restrictions.

CommentID: 68882