I am writing to express my strong support for 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 necessary to alleviate the financial strain on residents and to modernize the regulations in line with current payment practices.

Residents in counseling are often recent graduates who are still building their professional foundation. The financial burden of entering the field can be significant, especially given the low wages that many residents receive in their early years. The current requirement that residents must pass their earnings through their supervisors adds an unnecessary layer of complexity and financial strain. Supervisors, understandably, may be hesitant to take on residents due to concerns about the implications for their own tax liabilities and the administrative burden of managing these payments.

Allowing residents to directly bill clients simplifies this process and provides a clearer financial path for both residents and supervisors. Residents can more easily manage their own income, which is essential for their financial stability and professional growth. Supervisors, in turn, can focus on what they do best—providing guidance and support to the next generation of counselors—without the added stress of handling payments.

The argument that direct billing could incentivize unsupervised practice does not hold when we consider the robust supervision requirements already in place. Residents are required to inform clients in writing that they are under supervision, ensuring transparency and adherence to ethical standards. This amendment would not change the rigorous supervision requirements; it would merely streamline the financial aspect of the supervisory relationship.

Furthermore, in many other states, residents are permitted to bill clients directly, and these states have not reported issues with residents practicing independently without appropriate oversight. This demonstrates that direct billing can be implemented without compromising the integrity of the supervision process.

The current regulation also creates an artificial barrier for residents who wish to start their own private practice under supervision. In a time when employment opportunities may be limited, especially in certain geographic areas, being able to establish a private practice under supervision can be a critical opportunity for residents to gain experience and build their client base. By allowing residents to bill clients directly, we support their entrepreneurial efforts and help ensure that they can sustain themselves financially while continuing their professional development.

In conclusion, the proposed amendment to allow residents in counseling to directly bill clients is a necessary and logical step forward. It supports the financial well-being of residents, reduces administrative burdens on supervisors, and aligns Virginia’s regulations with modern payment practices and the standards of other states. I strongly urge the Board to approve this petition for the benefit of all involved in the counseling profession.