I am in favor of removing the phrase restricting residents from directly billing for services.

This restriction creates an unnecessary burden on residents and supervisors. Further, it leads to discrepancies in how residents in private practice are handling billing, which creates inconsistencies and confusion in the field. There is no guidance on a standard as to what IS acceptable, thus I have heard several methods of how Residents/Supervisors handle this issue over the years - and it ultimately comes down to individual risk aversions and creative work-arounds that ultimately don’t serve much purpose. 

The “money pass through” seems to be superfluous, especially when the focus of supervision ought to be on client care rather than on the details of how money is collected and redistributed. 

Residents are not to represent themselves as sole practitioners in that they cannot see clients without being under the supervision of a Licensed Professional Counselor. They must inform clients of their status as a resident, use the title "Resident in Counseling” on all correspondence/platforms, etc., and provide contact and licensure information for their Supervisor. Further, they need supervision and notarized documentation of hours in order to apply for licensure. These regulations seem adequate in ensuring Residents are not practicing independently without guidance. 

Not allowing Residents to directly bill for services may have been an additional layer of indication that a Resident was not fully licensed/independent several decades ago when clients were typically paying for services via checks (written out to a Supervisor versus the Resident, for example). However, in today’s world of electronic health records and credit card payments, whose bank account is tied to the payment processor seems irrelevant and not something clients are even privy to.

A Supervisor’s role is in supporting Residents in case conceptualization and ethical practice, not in bookkeeping. 

In response to opinions that Residents not be allowed to even have private practices: I believe Residency is the ideal time for clinicians to start a private practice if that is their ultimate goal, as Supervisors can be fundamental in mentoring Residents as they embark on this journey, helping them to ensure they have the proper policies, procedures, and documentation in place to protect both themselves and their clients’ rights. While this is not the focus of this petition, the idea of directly billing for services and collecting fees is typically specific to private practice settings, thus it’s worth noting the regulations do not prevent Residents from starting their own practice. 

The idea of not directly billing for services does not seem to serve a purpose and does not equate to Residents practicing independently, given the requirements of full disclosure of Residency status.