Virginia Regulatory Town Hall
Department of Health Professions
Board of Counseling
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]
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7/19/22  10:09 am
Commenter: Cynthia Miller, Ph.D., LPC

Purpose needs clarification

This petition, while perhaps well-intentioned, blurs the distinction between what it means to be a resident and what it means to be licensed.  The title "Licensed Professional Counselor" is protected by law and is indicative of a counselor who has a credential to practice independently.  A resident is someone who has permission to practice, but only under the supervision of a Licensed Professional Counselor.  In other words, the resident is not permitted to practice independently.  Creating a designation of "Licensed Professional Counselor - Resident" blurs the very important distinction between who can practice unsupervised and who cannot.  The general public is unlikely to understand how an LPC differs from an LPC-R and that is a problem.  Potential clients should clearly understand whether their counselor is independently licensed or not.  

It does seem possible that a driving force behind this petition is the desire to bill insurance.  Private insurance companies generally do not reimburse services provided by counselors who are not licensed.  This is a problem and definitely creates additional barriers to treatment for people.  If the end result of creating a designation like LPC-R is to open the path to insurance reimbursement I could get behind this, but it should come with clear requirements that anyone with an LPC-R designation must explain their residency status to every client.

CommentID: 122766