I strongly support the petition to amend 18VAC115-20-52(B)(10) and 18VAC115-50-60(B)(8) to allow residents in counseling to directly bill for services and receive payments from clients. This change is crucial for promoting professional development and financial stability for new practitioners in the field.

The current regulation creates unnecessary hurdles for residents who are already under strict supervision requirements. By allowing residents to directly bill clients, we empower them to take ownership of their practice while still under the mentorship and guidance of experienced supervisors. This fosters a learning environment where residents can develop their business acumen alongside their clinical skills, better preparing them for independent practice.

Moreover, this amendment would reduce the administrative burden on supervisors, who currently have to manage the complex process of passing through client payments. The existing system not only complicates the financial aspects of supervision but also potentially dissuades qualified professionals from taking on supervisory roles due to the perceived risks and inconveniences.

It is also important to recognize that the cost of living continues to rise, and residents in counseling often face low wages and limited employment opportunities in the Commonwealth. Allowing residents to directly bill clients could alleviate some of the financial stress they experience, making the profession more sustainable and attractive to future practitioners. This change would not incentivize unethical practice but rather support residents in adhering to ethical guidelines while gaining the experience they need to become licensed professionals.

In exempt settings, graduates practice without the same level of oversight, often dealing with complex cases without adequate support. By contrast, allowing residents in private practice to bill directly while still under supervision ensures they receive the guidance they need to develop into competent, ethical practitioners.

In conclusion, this amendment is not only a step toward modernizing our regulatory framework to match current technology and payment systems but also a move to support the next generation of counselors. It acknowledges the reality of the field and offers a practical solution that benefits both residents and their supervisors, ultimately leading to better outcomes for clients. I urge the Board to reconsider this petition and allow residents to directly bill for their services.