Though I disagree that allowing residents to directly bill for services would "incentize residents to engage in independent practice without supervision," I do believe removal of this requirement would further contribute to the unintended deception of the general public as to what constitutes "independent practice." Regardless of the disclaimers on a website, in consent forms, etc. regarding someone being a "resident" and "supervised by...", most people do not understand the nuances that exist between graduate and professional licenses. Further, they often make the assumption (which is not unreasonable) that someone who owns a private practice is working independently. Residents directly billing for services would further complicate this matter.