If this is passed, it essentially renders the independent licensure unnecessary or said differently, it makes the supervision process impossible..  Consumers cannot be expected to understand the difference in nomenclature, so residents can easily operate their own practices.. Additionally it seems incongruous with wage/hour laws — if a supervisor is still being held responsible for services provided by residents, they need to be able to exercise a certain amount of control over their work.  If residents can accept payment independently, they are essentially acting as 1099 independent contractors.  To be in compliance with the IRS definition of a 1099, the supervisor cannot exert control over the work of their resident.  This puts supervisors in an impossible position.  If the Board thinks residents can operate independently, it needs to eliminate the supervision requirement altogether and award independent licensure to graduates of Masters programs.  Moreover if residents  are able to accept payment, the workforce available to serve in community mental health and agencies will be even farther reduced. 

I understand the push for this likely revolves around inadequate pay for residents.  Let’s get to the root of that problem - insurance rates are too low and have not increased with inflation and cost of living.  Rather than reducing the quality of the profession by reducing the supervision and oversight of new clinicians, let’s focus on raising the quality of services provided and demonstrate the ways in which counselors promote the health of the community thus reducing the overall cost of untreated mental health issues.