Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Counseling
 
chapter
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]
Previous Comment     Next Comment     Back to List of Comments
8/19/24  5:20 pm
Commenter: Anonymous

I fully support this petition & rebut Fabian Kuttner's points
 

First and foremost: People need to accept that Residents are dedicated professionals in their own right and deserve the same dignity and respect that's afforded to Licensed Professional Counselors - and I think that this is a reality that has been completely lost to most people!

Second: The notion being circulated - that allowing Residents to bill clients directly will cause harm - is absolutely ridiculous and completely demeans the dedication, professionalism, and competency that residents already possess. If residents are trusted enough to provide complex and extensive mental health treatment to adults, children, families, and couples (under supervision), then why is there such a lack of trust when it comes to simply billing a client (while under supervision)? This is a completely upside-down bonkers ideology that has yet to be logically and factually explained and defended successfully.

Rebuttal to Fabian's statements: It sounds like you have a great relationship with your supervisor and that's a wonderful thing! It also sounds like you're happy with where you've landed (including the manner in which your employer has structured their business - employing almost entirely residents and students). You, of course, have a right to choose what's best for you and it sounds like you have done just that. On the other hand, not everyone is as lucky as you. You may be content and satisfied with your supervisor and the business model you're employed under, but that doesn't mean that ALL residents should be forced to take the same path that you have - especially if it's not what's right for THEM. Why prevent others from being able to choose what's best for them, just as you have?

You stated: "I have a lot of respect for the tradition" = As someone who supports this petition, I also have a lot of respect for the "tradition" of the supervisory experience. However, I also have a lot of respect for progression, growth, and change - tradition doesn't automatically mean that it's the best option for everything and everyone forever and always. Things change, people change, professions change, technology changes, economies change, business changes, and yes, laws and regulations change. Which is why, those in support of this petition, are requesting this change.

You stated: "I believe we need to develop excellence in our residency and EARN the independence of such a private, powerful relationship" = If by "private, powerful relationship" you mean "billing clients directly," please define how you feel that billing clients directly is "earned" and why you feel that residents - dedicated professionals holding advanced degrees - have not "earned" this already. Also, consider the fact that U.S. consumers pay for an astonishing amount of different services in this country every day wherein no "relationship" exists - thus, why is an "earned relationship" required to bill someone directly? Is the simple act of providing a service to someone for which you should be compensated not sufficient enough? What relationship are you referring to, then, that needs to be earned in order for a resident to bill their clients directly for the very services that they have provided? Additionally, under this "earned relationship" concept, what relationship has a supervisor earned with the resident's client wherein the supervisor can directly bill the client? Please clarify what you mean and explain how it justifies the continued prohibition of residents directly billing their clients. If, however, by "private, powerful relationship" you mean "owning and operating a private practice," then this point is irrelevant given the fact that residents can already own and operate a private practice - which has nothing to do with this petition.

You stated: "competency over power seems more useful to someone learning the practice of psychotherapy" = Why does this have to be one or the other? Residents can be quite competent AND have power over their own salaries simultaneously - one does not have to exist without the other. The points being made in support of this petition are not "give us more power so we can be less competent" - that wouldn't make sense. It's about counseling professionals and those in charge of regulating the profession as a whole understanding that residents ARE competent, and that being a "Resident" doesn't automatically mean that they are incompetent, irresponsible, untrustworthy, negligent, naive, unprofessional people who can't or shouldn't bill their own clients directly. It's also about residents being taken advantage of by supervisors wishing to profit off of them - which is allowed to happen because of this outdated regulation that serves zero purpose (especially considering the multitude of other rules, regulations, and codes that make this regulation obsolete). Regardless, improving one's competency and skillset doesn't automatically go out the window because they have power over their own salary. Otherwise, how are LPC's (who should also continue to improve their competency level and skillset) able to have power over their own salaries?

You stated: "But blind empowerment of us residents is not the way to develop equity, or ethical practices amongst supervisors" = "Blind empowerment" is a bold statement, in my opinion. You're essentially saying that the points being made in support of this petition "lack perception, awareness, and/or discernment" - hence "blind empowerment." I would advise anyone feeling this way or making a statement such as this to carefully read all of the comments listed for this petition and to actually speak with those who are currently suffering as a result of this regulation - then, you can determine whether these points truly "lack perception, awareness, and/or discernment."

CommentID: 227403