It is my opinion that restricting residents from advertising is unnecessary, prohibitive, and detrimental to the needs of the public.        

It is already extremely difficult for graduates to find jobs that provide a living wage.  Often the jobs they do find don’t have supervision because their superiors are unlicensed or they have no need for licensed counselors and don’t support the licensure process.  They may also not want the employee to have an outside supervisor.  And even if supervision is provided, the employee may be required to stay for one to two years and if they leave sooner, must reimburse the company for the supervision.  And if the graduate can’t find a job at all, they are left with the only alternative, private practice.

There are two “kinds” of private practice.  One, is working in an established practice and the other is opening their own practice.  It’s easier to do the first because the office is already established, a supervisor may be available on-site, and although the resident may get clients through the practice’s advertising, they likely are required to bring in their own clients as well. But there are not unlimited practices to join just as there are not unlimited job opportunities.  So, if a graduate is unable to find a practice to join, the only alternative is to open their own practice which takes time, so some residents must work a second job to make ends meet.  Volunteering is an option but also not easy to find, and may not include work in all the core areas required in a residency. 

So, if the only opportunity for some to earn a living is to open a private practice, how would that resident find clients without the ability to advertise?  When a resident advertises, they must state they are a “Resident in Counseling,” under supervision, and by whom.  If a resident doesn’t advertise themselves correctly, that can be reported to the Board of Counseling and the resident and supervisor corrected by the Board.  That should not be a reason that all other residents who are advertising correctly be denied that opportunity. 

It seems that the petition is based on limiting competition, meaning that residents should not be competing with licensed clinicians.  But, I believe that residents-in-counseling meet a public need.  Residents typically charge less than licensed clinicians which means they provide an opportunity for counseling for those who have limited income or no insurance coverage.  Bottom line, shouldn’t it be the client’s choice who they see if given the options, including a resident under supervision? 

There also seems to be an implication that residents may not be as skilled as those who are licensed.  This seems to discount the fact that residents are under supervision. It cannot be overstated that there is diversity in skill levels between residents, between supervisors, but also as well between licensed clinicians (just look at the disciplinary proceedings on the Board website).  I believe making a case that a resident under supervision may not do as good of a job undermines the process of licensure.

I would also like to correct a few items from previous comments: interns are not included in this process as they have not yet graduated; “pre-licensed” is no longer a term used by the Board; residents in counseling are allowed to have a private practice; there is a responsible party – the supervisor; and in my case I require a resident in private practice to carry their own malpractice insurance.   

Thank you to the Board of Counseling for allowing the opportunity to express my concerns and opinions about this petition.