The mission of the Board is to protect the public. Part of the way the public is protected is by being fully informed of the status of those counseling them. When Residents start their own private practices (which they can do if if they are able to bill and receive direct payment) there is very little oversight save miniscule supervision. 1 hour to 40 work experience hours leaves quite a bit of time of unsupervised work. Private practice is the most dangerous place for ethical violations and harm to clients. Add in new clinicians and potentially much less oversight we are putting the public at greater risk than necessary or acceptable. Without the clause regarding payment the public will believe that a Resident can practice independently and is on their own. The structure of counseling levels is already confusing enough. Payment through an agency or supervisor is another layer of protection, supervision and clarity for the public.