The Virginia Association of Community Services Boards (VACSB) appreciates the opportunity to comment on these proposed regulatory changes related to billing practices for residents in counseling.  The VACSB is generally supportive of efforts to reduce administrative burdens and streamline processes to allow for the efficient and effective delivery of behavioral health services and understands the basic reasoning behind this petition, but please note the below concerns:

• While this proposal would certainly save time for the supervisor, CSBs believe it is more important to maintain the integrity of supervision in the clinical environment as well as recognize the value of an individual’s “time in residence,” which is expressly designed to provide opportunities for growth and guidance from seasoned professionals.
• CSBs are concerned about liability issues with direct billing that does not include co-signature supervision because a resident is still learning skills and competency in their profession.  Inappropriate billing could create a financial liability in a CSB.
• If the proposed changes were to be implemented, it could change the incentive structure for attaining licensure.  In other words, if a resident in counseling can directly bill and be directly reimbursed for service delivery without a supervisory review, there may not be the same incentive to move forward with licensure.
• If notes do not need to be reviewed for billing purposes, it is possible that they would not be reviewed at all, thus diluting the supervision experience.