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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8/4/24  8:23 pm
Commenter: Anonymous

I fully support this - other states allow supervisees to bill clients directly!
 

I fully support this proposal for a multitude of reasons. First, it's time that we all understand what "operate independently" really means. "Operating independently" means practicing without supervision, not that "Residents can't own and operate their own practice." There's a clear difference between "operating independently" and being self-employed (with supervision) and many other states recognize this and allow their supervisees to have their own private practices - as does Virginia! Fact: Virginia Residents CAN legally (and DO) own and operate private practices. This provision alone, has no bearing on the issue at hand (Residents not being able to bill clients directly).

 

Second, others' have commented that if this bill is passed, then the "experience" that Residents are supposed to be receiving will be compromised. Billing clients directly should not equate to professional "experience." Such claims completely demean and disparage the the work and dedication that Residents give in order to maximize all of the benefits surrounding said experience. If a Resident is able to bill their clients directly, the quality of their experience won't change - because they'll still be under supervision. It's supervision that perpetuates the quality of the Residents "experience," not the money.

 

Some people who are opposed to this proposal think that if LPC's aren't monitoring (aka controlling) the money, then Residents can do whatever they want. I find this this frame of thought to be extremely concerning for multiple reasons. One is because it conveys that Residents are ONLY being monitored in one way. If this is the case, then supervisors need to be held accountable for their lack of supervision. Perhaps Supervisors also need be monitored more closely - and maybe revoking their ability to bill Residents directly will achieve this?

 

Furthermore, Residents being in charge of their own billing/money should not be threatening to LPCS/Supervisors. The simple fact that many people in higher positions than Residents are threatened by this should be of great concern to those in charge of regulating the profession. It's no secret that there are numerous "puppy mill" style practices in Virginia wherein LPCs/Supervisors hire Residents (some of them ONLY hiring Residents) because they can make more of a profit this way. I personal know of at least one practice in Virginia that has made over $1 million per year because of this "business model." So, if this proposal goes through, these places fear losing their "golden goose" (i.e., Residents). Personally, I think that this is the real reason why many people oppose this proposal. Other states (such as Texas, Oregon, Colorado, and Ohio) allow their counseling supervisees to bill clients directly. This proposal is not an unprecedented concept in our profession. It is happening in other states and it's happening successfully. These supervisees are still getting the experience they need and they aren't operating independently - because they're still being supervised. Furthermore, the fully-licensed counselors in these states are not of lesser quality or have less competence because their supervision experience is different than ours. So, it's clear that the problem many people have with this proposal just comes down to money.

 

Lastly, many people opposing this proposal also state that prohibiting Residents from billing their clients directly actually helps clients because it shows that Residents are not LPCs and are under supervision. They still seem to say this despite the multiple regulations in place that require Residents to show/explain/document/discuss/brandish (to the point of extreme overkill) that they are not licensed professional counselors and are indeed under supervision. Changing how the client is billed does not change this requirement. As a matter of fact, I have personally witnessed clients being even more confused and essentially turned off from starting therapy due to the Resident not being able to bill them directly. We're constantly being told that there is a severe therapist shortage in Virginia; so, why are we refusing to make changes that could actually make the process easier for Virginians to get help?

 

At the end of the day, Residents in Counseling should be supported, encouraged, and nurtured - not held back by archaic ideals that only benefit those wishing to profit off of Residents. Rules and regulations should evolve along with an evolving profession, as ours does. Other states recognize the importance of what is being proposed here and have updated their rules and regulations. Virginia should too!

CommentID: 227264