I support the petition to amend 18VAC115-20-52(B)(10) and 18VAC115-50-60(B)(8) to allow residents in counseling to directly bill for services and receive payments from clients. It’s important to emphasize that this proposed change is not about reducing or altering the supervision requirements for residents. Instead, it’s about providing clarity and modernizing the process to better reflect the current professional landscape.

The current regulation’s wording has led to confusion and unnecessary complications around the billing process for residents in counseling. This amendment seeks to address that confusion without altering the essential requirements for supervision or the pathway to licensure. Residents will still be under the same rigorous supervision and will still be required to complete all necessary hours and meet all other criteria set by the Board.

This amendment is not about changing the certification of licensure; it’s about clarifying an administrative aspect that impacts the day-to-day functioning of residents in counseling. The ability to directly bill clients simplifies the process for all parties involved. It allows residents to manage their practice more effectively while under supervision, ensuring that their focus remains on providing quality care to clients rather than navigating cumbersome billing procedures.

This clarification also aligns with practices in other states and reflects the shift towards a more streamlined and efficient healthcare environment. By removing the unnecessary complexity of billing through a supervisor, we are not compromising the integrity of the supervision process. Instead, we are allowing residents to operate more independently within the boundaries of their training, supervision, and ethical obligations.

In summary, this change is about clarity and practicality, not about altering the foundational requirements for becoming a licensed counselor. It is a necessary step to ensure that residents can focus on their professional growth and client care without unnecessary administrative burdens.