Residents in Counseling should continue to be allowed to advertise services with the caveat that they are required to list their supervisor’s name and contact information on any advertisement. Residents are trained and need clients in order to become licensed eventually. Limiting all advertisement is an unnecessary burden on our residents in counseling. 

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. 

For clarification purposes is this a marketing concern or an ethical? The purpose of having supervision during residency is to ensure that new counselors are guided properly in the field, yet in order to grow one must obtain clients. If the board already requires that the resident informs the public that they are a resident then there is no ethical issue. Especially since notification of residency is documented in the consent to services forms and disclosure statements.  In order for residents to gain experience and become licensed is by gaining clientele, Psychology Today and other internet marketing spaces provides a space for residents to meet such requirements. Putting the onus of marketing on the supervisor could increase the supervisor’s responsibility which may decrease the amount of interested supervisors. This could be a disadvantage for residents and interns.  If residents are initially informing clients and throughout the entire counseling process then there is no harm to the public. 

I do not think this is an appropriate petition for the board at this time. As residents, we agree to abide by the regulations which instruct us to always identify ourselves as residents and provide our supervisor’s information to our clients. Additionally, supervisors are responsible for ensuring their supervisees are following those regulations. It is difficult enough for residents to obtain positions where they can accrue their supervision hours. If this petition were to be passed into the regulations, it may make it even more difficult for residents to complete those hours and does not appear as if it would directly benefit our clients in a significant way. I think the issue at hand is more of a marketing issue for certain advertising platforms versus a regulation issue. 

In my opinion this petition is a waste of the boards time and resources. The board has already implemented how Residents of Counseling should and can market themself. The petition writter claryifed that part of the reason is that Residents may be listed in a search engine before him. That statement is a personal grievence, and not one that should effect the whole state of Virginia. Residents of Counseling have been trained and have a Masters agree to attest to the fact that they are knowledgable. Mental Health Providers also educate clients and consumers on the differences, and it's clearly stated when working as well as advertising. Petitioner also stated that if calling he would expect the person to be able to help him. On the other side of this there are indepedently licensed professionals that have to refer out due to not having the training in certain areas. That is why we have a network and make referrals so that the client can have their needs met. In this country we talk about how there is a shortage of mental health professionals and how there is a need. There will be more of a need if Residents of Counseling are not able to be visable in this day and age where you need to market yourself as well as have an online presence. 

I worked in a private practice under supervision as a resident in a completely ethical manner and I had to do all of my own advertising and networking to obtain clients. It was hard and in no way do I believe I impeded on licensed clincians’ ability to obtain clients. Many people needed to use insurance and I referred more clients than I kept for that reason. I worked hard and learned the business side of private practice which was invaluable to me as a licensed clinician now. It is already very challenging to obtain an LPC in Va. so I do not believe we should make it any harder for residents. Please vote no. 

This petition appears to more of a personal grievance with market share of clientele vs. resident's promoting and advertising and/or independently soliciting business from the public, per the petitioner's comments regarding his rationale (see comment section for public comment on 11/29/18 9:56 p.m.) for the petition.

Per 18VAC115-20-52. Residents may not call themselves professional counselors, directly bill for services rendered, or in any way represent themselves as independent, autonomous practitioners or professional counselors. During the residency, residents shall use their names and the initials of their degree, and the title "Resident in Counseling" in all written communications. Clients shall be informed in writing of the resident's status and the supervisor's name, professional address, and phone number. 

18VAC115-20-52. The supervisor of a resident shall assume full responsibility for the clinical activities of that resident specified within the supervisory contract for the duration of the residency.

Limiting advertisement is an unnecessary burden that may limit access to residency training in private practice for Residents in Counseling in the Commonwealth of Virginia. I would like the thank the Board of Counseling and the petitioner for offering the opportunity to voice my strong opposition to the proposed petition. 

Respectfully,

Kimberly J. Nichols, M.A., Resident in Counseling

I strongly oppose the above petition as it puts even more restrictions on residents in counseling.  I believe the as long as an individual who is practicing under the title of a resident in counseling abides by the regulations set in place by the Board of Counseling, there should be no further limitations restricting the possibility of work.  As a current resident in counseling I can attest to the level of difficulty in finding a secure worksite who is comfortable hiring a resident in counseling, so with this petition it can make this journey even harder for us to gain the hands on experience which is the main purpose of the residency period.  From reading the petition it appears that the concern is marketing not regulations.

D. Peterson-Lewis, M.S, Resident in Counseling

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.  

Residents are already having difficulty in finding appropriate reasidency sites to fulfill requirements set forth by the board. This would be another way to complicate the course of experience that residents will need to become fully rounded and ready LPCs. I see it as another way of stifling a vital growth process that should really be the opposite of our focus in developing competent clinicians in the field.

Like many others, I believe this is a marketing issue, not an ethical one. Residents (and their supervisors) are aware of the limitations surrounding how they gain new clients and being listed on an agency's website does not violate those regulations. Residents have a challenging time getting clients as it is and restricting where they may be advertised creates even more challenge. Overall, it seems unfair to penalize residents simply because they work for an agency and that somehow disadvantages other agencies in search listings.

I am a Licensed Professional Counselor with approximately 20 years of private practice experience. Over much of this time, I have supervised multiple Residents and celebrated with them as they achieved their licensure goals.  Over the years, I have learned that to be a competent supervisor, one must have an excellent working knowledge of the rules, regulations, and laws governing counseling and to know how to apply them effectively in work with Residents.  The Board of counseling requires that Residents receive a full spectrum Residency experience to include patients from all walks of life.  They must have the opportunity and experience of conducting comprehensive assessments, making accurate diagnoses, planning appropriate and effective treatment, implementing treatment plans, then repeatedly assessing progress until termination.  The Resident must repeatedly accomplish each of these requirements in their work with a broad variety of DSM 5 disorders and syndromes using multiple treatment modalities and orientations. This can be a daunting task.  If this proposal is adopted, Residents will continue to be required to recur it their own patients.  But, they will have no tools to do so. Looking at all this as a whole clearly demonstrates the significant adversity this proposal would add to the already heavy (and necessary) burdens of Residency.

In the past, Residents sought out Residencies at sites that rarely met all of these requirements.  So, Residents are now required to find other options to ensure their experience met Board requirements.  This means finding sites that support the provision of this full spectrum experience.  The most likely sites for this are in Private practice settings. 

Supervisors take on considerable responsibility and risk for low pay to help Residents earn their chops.  We provide significant assistance with all aspects of this experience. However, we simply cannot provide the kind of client load necessary to provide the experience required by the Board.  For that reason, it is absolutely necessary for Residents to have the ability to advertise their services to recruit patients.  In doing so, they must not only identify themselves as a Resident to their patients, they must do so on all documentation, business cards, websites, etc. They can in no way represent themselves as independent clinicians. So, finding patients to build a caseload is a critical component to establishing and completing Residency in accord with the regulations.  

This kind of advertisement has little impact on other clinicians. There are always enough hurting people available to fill our offices.  Likewise, Residents provide services at a discounted price to meet the needs of their patients, including some who would not be able to seek services otherwise.   Since they are unable to accept payments from insurers, they in no way will compete with licensed clinicians who do.  And because all of their patients must pay out of pocket and pay at reduced rate below what most licensed clinicians would accept, they are not true competition for licensed clinicians whose patients pay put of pocket.  As for clicks per website, my Residents create their own sites. I do not receive any benefit from their "clicks."

In closing, I can see no benefit from this restriction, But, I can see many pitfalls if it is enacted.   Residents already face challenges in their efforts to meet the critically needed Board requirements that currently exist.  This proposal would hobble most Residents and prevent them from achieving their goals.  That seems a significantly onerous consequence to inflict upon new clinicians when the benefit is likely negligible. Therefore, I am opposed to this proposed change.

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

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.

I am serving my community as a resident counselor and go out of my way to make sure my clients know that I am not licensed and am receiving supervision. All of my marketing materials clearly state my resident status and I provide all clients with my supervisors' contact info in case they have any issue. This petition seems like a continued attempt at making it impossible for pre-licensed clinicians to go into private practice. There are already significant barriers to entry when it comes to working out a system for payment through a supervisor rather than taking payment ourselves. Beyond these issues, how on Earth would this petition be implemented? The staff it would take to scour the internet looking for all the residents who advertise and having to create standards for what it means to be independent...seems like an impossible task. Let's not waste our time and resources on an issue that is causing no harm.

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.

I will not likely add anything new to this discussion but simply mention that I supervise residents. In the group practice where I do this (besides seeing my own clients) the PRACTICE "advertises" the residents by letting the front desk weave into the first conversation with potential clients who call requesting help - information about who is available to address their needs. That would INCLUDE the residents who are available working in the practice.

The potential clients who call are informed about the difference between residents and licensed counselors; the financial costs the potential client must bear to do the counseling is distinguished from the costs of the licensed counselors, and other issues that are relevant.

Then the potential clients makes their own choices.

In essence the group PRACTICE does the work of advertising its services, puts its own web site on the web with the residents listed, and the supervision which the residents work under is clearly stated.

There is more I could say, but generally, this is what happens.

Depending on whether the residents wish to "specialize" in certain issues, or age groups, etc. - this can make a difference in the choices the potential clients will make.

Hope this helps clarify some pieces of how this can be useful.

Dan Towery MA ThM LPC CSOTP, Supervisor for Residents in Counseling

Riverside Counseling Center

703-724-0200

I agree with a prior comment, "Residents in Counseling should continue to be allowed to advertise services with the caveat that they are required to list their supervisor’s name and contact information on any advertisement."  This does not appear to be an ethical issue, but a business/marketing one.  The public is not harmed nor mis-informed if the above is followed and appropriately explained.  As one of the states with the largest amount of required hours to complete residency, if this were to be passed, it would be yet another hardship on those entering in the field as well as those clients that are faced with offices with no immediate openings from licensed clinicians.

In order to become licensed professional counselor a resident in counseling in the state of Virginia must complete total of 3,400 hours, 2,000 of those direct hours with clients, and 200 supervision hours.  That is only after one completes 60 semester hours of graduate school which must include 13 core content areas, one of which is “professional counseling identity, function, and ethics” and 600 or more hours of internship (Virginia Board of Counseling). Therefore it is inaccurate to equate the level of experience of “interns”, “pre-licensed counselors”, and “residents” as all one group.  Additionally, some residents in counseling have obtained National Certified Counselor certification by having “voluntarily met high national standards for the practice of counseling” (NBCC).  As ethically competent residents in counseling, we are obliged to accurately describe our status as residents and provide our supervisor’s information to any prospective clients.  Forbidding advertising to residents in counseling would narrow down the choices available to the public seeking help and place yet another significant burden on the residents to complete the required hours and gain needed experience towards the license.  Please vote “no” on this petition.  Thank you for your time and consideration. 

The Residency process is an important transition period prior to becoming a Licensed Professional Counselor. During my own residency, I sometimes found it difficult to get clients because of the limitations, mostly in the form of insurance, placed on Residents.  While it is critical for Residents to operate under supervision, I see no reason to impose a barrier to growing their case load by prohibiting advertising. A Resident advertising their services can clearly state their position as a Resident, and include information about their supervisor, as well as expanding on the limitations of working with a Resident anything else relevant in the informed consent. Allowing Residents to adverrtise their services can result in greater access to those seeking care and unable to pay the higher fees typically associated with an LPC. Allowing Residents to advertise is a win-win.

I am against the petition filed with the Virginia Board of Counseling prohibiting Residents in Counseling from advertising on placed like psychologytoday or other online, social media platforms.

http://www.townhall.virginia.gov/l/Comments.cfm?petitionid=285

I fully support Residents in Counseling ability to advertise and promote their services as long as Residents in Counseling CLEARLY indicate their residency status, supervisors name and company they work for on all marketing / promotional materials (including social media).

I am against the petition filed with the Virginia Board of Counseling prohibiting Residents in Counseling from advertising on placed like psychologytoday or other online, social media platforms.

http://www.townhall.virginia.gov/l/Comments.cfm?petitionid=285

As a supervisor, I fully support Residents in Counseling and their ability to advertise and promote their services as long as Residents in Counseling indicate their residency status, supervisors name and company they work for on all marketing / promotional materials, as currently outlined in the licensure regulations.

Implementing this filed petition would make it nearly impossible for Residents to meet the residency requirements to get hours to work toward licensure, and ultimately harm the growth of the profession.

No.  Residents deserve to be able to make a living while they work toward licensure. Advertising and marketing are necessary to get clients.  This process is hard enough. Let’s support them, not make it more difficult for them. 

I am in favor of allowing appropriate advertising by residents, providing the ads are clear about their status and includes the name and contact information of their supervisor. Residents frequently struggle to see enough clients to meet the required 3400+ hours,  especially because clients often prefer to see a licensed clinician for the cost of a small copay while residents in Virginia do not yet have a temporary license number needed to be credentialed by managed care. It frequently requires 2-3 years to see enough clients to accumulate the required hours and residents deserve the ability to make a living during this time.  Respectfully submitted, Joan Normandy-Dolberg, Licensed Professional Counselor and resident supervisor 

I am an LPC in private practice in Northern Virginia. I strongly oppose the petition to restrict the ability of residents to advertise their services. Residents already face a significant barrier by not being able to accept insurance payments. Further limits on their efforts to secure clients is counter-productive to our profession’s goal of expanding the number of clinicians in the field.

Upon learning of this proposed regulation change, I was perplexed at best, and dumbfounded at worst. The proposal appears short-sighted, and ignoring already enforced regulations in place that allow Residents to only advertise their services as being unlicensed individuals, under supervision from an approved supervisor, and only practicing with clients that they have a level of competence in treating, as guided by their supervisor. Prohibiting Residents from advertising their services, either on a paid site like Psychology Today (with all appropriate and required references to their clinical supervisor) or within an organization's web page is only a means to make it harder for Residents to become Licensed Clinicians. This appears to be an attack on Residents from a person worried about their own ability to earn an income through their chosen route of service delivery, and not one that is aiming to "alert" the public about Residents being unlicensed counselors. If my own small private practice can attest, we have more than enough folks who are seeking out counseling services, and many who continue to remain without insurance, or who choose to not utilize insurance for mental health services, and Residents can still provide needed services under supervision in a way that enables the potential client to not experience an undue financial burden in seeking treatment.

While we may all differ in our theoretical orientation, methods of service delivery, niche populations, and levels of experience, we need to continue to support Residents on their taxing journey of becoming well-rounded, competent clinicians. If we don't provide them with the skills and knowledge to market their individual qualities in a private practice setting, they will not know how to do so, and would potentially lead to less clinicians practicing to meet the enormous needs of folks today. The proposed regulation only aims to diminish the confidence and practice ability of Residents, which is the antithesis of our profession, and hurts all of us. Please do not change any regulations for Residents to remove their ability to advertise appropriately.

I am adamantly opposed to this petition.   Although I am not adding anything new to what has already been said, I want to reiterate that this proposal is unnecessary and an undue burden.  It is solely a marketing and competition issue and I believe the petitioner is simply trying to reduce competition for himself.  Residents in counseling have been well trained and are supervised by Board approved clinicians who have had been trained to supervise.  In addition, residents are required by Virginia law/statute, the regulations, and professional ethics to state their un-licensed status, explain what resident in counseling means, and give their supervisor’s information to the client.  I personally have had potential clients who have contacted me and expressed frustration because they were unable to find a clinician who was taking new clients or finding that the clinicians they had contacted never returned their calls or emails.  I also have had potential clients not chose me as their counselor because I am still working toward my LPC.  Lastly, advertising by a resident does not harm clients.  Clients will decide who is right for them, irrespective of advertisement.  In my view, prohibiting residents in counseling from “promoting or advertising their services independently to solicit business from the public” is unnecessary because residents actually provide a needed option to the public.

I have provided group and individual supervision to Residents in Counseling in Virginia for twenty years.  Many hours have been spent with supervisees insuring that all the rules are adhered to, ethics met and paperwork appropriately completed. Completing the required hours is a strenuous, yet valuable process and I know supervisees learn and develop. Regulating a supervisees opportunity to market and solicit business seems to hinder growth, and serves little purpose, especially in this time of mental health need. Since it is a requirement that a supervisor's information is on all literature and marketing material, it is clear that there is not "independent" practice. Rather, the opportunity to solicit and market one's training and clinical skills, serves a purpose for the public and the Resident. Thank you.     

It is already difficult for Residents to keep up with living expenses.  Please don't take away their ability to honestly advertise their services. 

I am against the implementation of this unnecessary restriction, as it does not seem to provide more protection to the public nor further the counseling profession in any way.  So long as residents in counseling are following all Board regulations, including using the title Resident in Counseling, not calling themselves professional counselors, and advising all clients in writing (and verbally) that they are supervised by licensed professionals and are thus not practicing independently, I see no reason why advertising the availability of their counseling services would result in harm to the public.  Residents in counseling need clients so that they can become licensed professionals.  They are trained counseling clinicians with a master's degree, working toward licensure through the process of gaining clinical hours with clients and passing a licensure exam.

I am opposed to this petition. I feel that the original poster has petitioned for this change based on marketing issues in his own practice and not because of an ethical issue in regards to residents advertising.

As I am building my clientele, I work multiple jobs. It is a slow process. It is difficult to build clients when insurance cannot bevaccepted. I have a Psychology Today page, where I state that I am a resident in counseling and list my office location, supervisor, and supervisor’s license number. When clients contact me, I explain my status as a resident. When clients come into the practice, I reiterate my status as resident and what that means and have them complete an informed consent stating the same. I am competent enough to know when I am unqualified to work with someone. I also receive regular supervision, where my clients are discussed and any concerns are addressed.

I also provide a service to people who cannot afford a licensed clinician, due to income or or insurance issues. I provide a low cost solution to people who have limited options. There are plenty of people who choose to use insurance, and plenty of people who can and will pay more and want a licensed clinician.

For the clients I do see, I see change and progress. I have rapport and a solid relationship. These clients would not have found me without advertising.

Don’t take this away from the residents in Virginia. We are learning, we are competent, and we know our limitations. Advertising and seeing clients allows us to develop our counseling identity.