In response to Cynthia millers lengthy commentary about this opening up issues between clinical supervisor not having access to records, etc because a resident could would now, under direct billing, be allowed to open up their own independent practice— the rules as they stand allow residents to have a contract filed with the Board for supervision with their residency supervisor and work at an agency or private practice elsewhere. This would be no difference. So that argument is mute. Respondant Superior is a legal concept that would be applicable to one’s clinical supervisor from a legal perspective, but quite frankly would likely come into play in an agency setting as well even if a resident was being supervised from outside because some day to day supervision in an agency setting is expected. In the case of an independent private practice owned solely by a resident, then respondant superior would only relate to the outside clinical supervisor. Please don’t throw around fancy legal terms of art to intimidate. It isn’t necessary or helpful.