I find it absolutely ridiculous payments to residents must pass through their supervisor. Especially if that supervisor is not part of the same organization (business/practice, or public health system). This process puts supervisors in an uncomfortable position financially and could have potentially detrimental effects on their taxes, or open them up to fraud.

I have a close friend who is a therapist and a supervisor. She told me she has to collect her residents' income, meaning the income that is earned by her residents, not her.  She said that the income has to pass through her account based on the rules and that she has to return the entire amount of earnings back to the resident, with the resident paying her separately for supervision. I've been concerned for her because of what could be IRS/tax implications of this, meaning that that income could easily be misconstrued as her own income and that she would have to pay taxes on that money which she didn't earn.

She also felt the understandable need to set up a separate account at a different bank in order to collect and disperse these payments for her residents, so that it was separate from her own accounts. She said she has done her best to keep records to prove it's not her income, but who would want to try to explain this convoluted process to the IRS? She mentioned that she saw this petition and that anyone, even those not in the field can post a comment, which has led me to comment on something I've thought for years is a totally unnecessary burden on her and her residents. From what I understand, clients are required to be informed the resident who is providing care is, in fact, under supervision, so having the payments go directly to the resident shouldn't change anything there. It would merely remove the burden from the supervisor to have to process payments.

I am submitting this comment anonymously because I don't want to potentially negatively impact my friend's business.