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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8/9/24  12:19 pm
Commenter: Kaylie Groenhout, MEd, NCC, Resident in Counseling

Strong Support for Petition
 

I strongly support removing the restriction that prohibits residents from directly billing for services. Changing the policy would support a more streamlined, transparent administrative process, removing an unnecessary burden on both residents and supervisors. This hurdle appears to have little, if any, benefit. It does not protect clients or ensure quality of care. Requiring the supervisor to bill/manage payments may be confusing to clients. It may also impede therapeutic conversations between clinicians (residents) and clients about finances/financial arrangements, as well as remove practical opportunities for residents to grow as competent, future fully independent, professionals in the field. 

Because residents in Virginia are allowed to operate within their own private practices, largely because they are under supervision, it’s especially important for them to clearly understand their income, expenses, and financial responsibilities. 

The purpose of residency is for pre-licensed counselors to gain experience working with different populations, theoretical approaches, and clinical issues, as well as develop their professional identity and functioning. Residents are responsible for telling their clients, in writing, that they aren’t flying solo and are under supervision. Residents are required to use their designated credentials every time they sign their name. They’re also required to be evaluated every three months by their supervisor, which serves as a competency and quantitative (hours) checkpoint. This all seems sufficient in making sure residents are not practicing independently and without oversight. 

TL;DR: Residency is the zone where residents are empowered with growing independence. Handling their own payments gives them an appropriate level of ownership and responsibility that corresponds to their professional competency level. The other gatekeeping checks in place, which are numerous, are sound and sufficient. Supervisors should be able to focus on nurturing clinical competency - not collecting payments and handing them back to residents, suggesting residents don’t have the power to manage themselves in the name of client welfare. 

CommentID: 227324