Denying this petition on the basis "that it might incentivize residents to engage in independent practice without appropriate supervision" is completely illogical.

1) Stating that this proposal "might" incentivize Residents to engage in independent practice without appropriate supervision is not a valid reason to deny it. Otherwise, it could also be approved based on a "might." "Might" should not be the stance that we hang our hats on - everything in life is a "might." Instead, let's think logically about the issue at hand.

• Residents are not children, and they're not criminals. They've successfully completed the grueling educational requirements to get to this point in their careers (many of them while also working full-time jobs), they're required to abide by numerous rules, laws, codes, and regulations, and every aspect of their work is, not only monitored by Board-approved Supervisors, but also by other counseling professionals and clients. Residents are fully capable of managing their own money and billing clients directly; as well as being fully capable of doing so within the legal regulations of the profession - as they do with all of the regulations.
• Numerous states allow "pre-licensed" counselors to bill clients directly - I found 4 within a 10-minute search of various state counseling board websites. There is obviously a need for this change across the country and other states are changing their regulations for a reason. Furthermore, there is no indication anywhere that this change has been disastrous for these states or that it has caused any harm to clients or the counseling profession. So, denying this proposal on a "might," when fact shows the opposite, is absurd and renders the process of petitioning for change pointless.   

2) "Residents" as per Virginia law "means an individual who has submitted a supervisory contract to the Board and has received Board approval to provide clinical services in professional counseling under supervision." Therefore, saying that a "Resident" might engage in independent practice without appropriate supervision is impossible. To be considered a "Resident," one must have a supervisory contract with an approved supervisor. Thus, if you don't have a supervisory contract with an approved supervisor, you're not a Resident. A supervisory contract with an approved supervisor is required to obtain, and to renew, a temporary Resident in Counseling license. This requirement alone specifically exists to prevent "independent practice without appropriate supervision" - allowing Residents to bill their clients directly does not change the integrity of this requirement. 

3) Providing clinical services without a license or an approved supervisor is illegal. People who engage in this criminal activity are not Residents - NOR are they Licensed Professional Counselors. Yet, Residents are the ones being punished. If someone can illegally claim to be a Resident, they can also illegally claim to be an LPC (and do). Prohibiting Residents from billing clients directly does nothing to prevent BOTH Residents and LPCs from being professionally impersonated.

Life coaches in Virginia, who are not as vigorously educated or trained as those in the counseling profession, and whose field is 100% unregulated, are able to directly bill their clients for services and are charging literally hundreds, and even thousands, of dollars PER session (seriously, look it up)! No, they can't call themselves counselors, but many people have abandoned the long, time-consuming treacherous journey of becoming a fully licensed counselor for the instant benefits that come with helping people as a life coach. So, for the simple fact alone that the counseling profession needs to be more forward-thinking in order to survive, let's not give those who actually want to join and add to this profession more reasons to go elsewhere.