Multiple commenters have stated that this regulation shouldn't be changed because it provides resident oversight by forcing residents to inform clients of their residency status in order to obtain payment/wages. So, let's explore why this regulation no longer serves this purpose.

At most therapy sites, the primary method of collecting payments from clients is electronic/online payment processing platforms (i.e., Square, SimplePractice, Stripe, etc.). Typically, when a client begins therapy, at these sites in particular, their credit/debit card information is electronically stored and payment is processed following each session. At this stage in the process, this is pretty much all the client is aware of when it comes to paying for therapy. Behind the scenes, however, there's more to the process. Once the client's card is charged, the payment is transferred to the bank account that has been linked to the online payment processing platform by the clinician or practice. This is the most important step when it comes to residents not billing clients directly. In order to be in compliance with this regulation, the bank account that is linked to the online payment processor cannot belong to the resident. Therefore, the bank account must belong to the resident's supervisor (or the resident's employer depending on the site) even though nothing is different on the client's end. The client would have no idea that their payments are going to the supervisor/employer's bank account if the resident doesn't inform them of this process - this is especially true when it comes to residents who own a private practice.

So, as it stands, the consensus essentially boils down to this: Residents can't be trusted to inform clients of their residency status, therefore, as a measure of enforcement, we must remove their ability to receive payments directly from clients and trust them to inform their clients of the payment process even though the resident will receive the payment whether the client knows the process or not. It's clear to see that this regulation no longer serves its purpose, and, based on this fact alone, should be removed. It is an unnecessary cog in the machine that doesn't prevent harm as others have stated - it actually creates it.

The implementation of this middleman-style payment process has made clients, residents, and supervisors more vulnerable to a multitude of modern-day risks and problems. For instance, the frequency of cybercriminals exploiting vulnerabilities in digital payment systems leading to financial crimes and exposure of personal data is now more common than ever. As such, having to move client payments through a series of electronic transactions from person to person to person (each transaction having its own risks) exponentially increases the security risks for everyone involved. Furthermore, as income, tax, and financial laws, codes, and policies change at the city, state, and federal levels, having an unnecessary, multi-step financial process increases the potential for unintentional ethical and legal violations for both residents and supervisors. Lastly, this regulation has systemically obstructed the financial growth of residents while fostering a professional culture wherein residents are seen as financial commodities. As others have commented, many licensed professionals are hiring "cheap labor" practitioners (residents) and charging the client a rate that is highly incongruent with what the resident is being paid. Since residents can't bill clients directly, what kind of voice do they have in this arrangement? If you're really paying attention, you'll see that there are countless "supervision horror stories" proving that residents have no voice at all. This regulation does not promote fruitful, effective supervision experiences, nor does it prevent harm. Give residents a voice, help protect residents, supervisors, and clients from unnecessary harm, and let's create a more rewarding supervision experience in Virginia by removing this outdated, ineffective regulation.