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]
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8/5/24  12:14 am
Commenter: Anonymous

This is a step forward
 

I strongly support the petition. This amendment is essential not only for promoting ethical practice but also for ensuring the financial independence of residents.

The current regulations place residents in a difficult position by requiring their income to be funneled through their supervisors. This setup creates unnecessary complications and opens the door to potential ethical concerns. For example, there could be misunderstandings about the division of payments or delays in residents receiving their rightful earnings. These issues can strain the supervisory relationship and create unnecessary tension between supervisors and residents.

Allowing residents to bill clients directly removes these potential conflicts and promotes transparency. Residents can clearly document the services they provide and the payments they receive, fostering an ethical practice where all parties have a clear understanding of the financial arrangements. This clarity is essential for maintaining the trust and integrity of the supervisory relationship.

Moreover, the current system can discourage talented individuals from pursuing supervision roles. The added responsibility of managing another professional’s income, with all its associated administrative and tax complexities, is a deterrent for many would-be supervisors. By allowing residents to handle their own billing, we remove this barrier, potentially expanding the pool of qualified supervisors and improving the overall quality of supervision available to residents.

Financial independence is a critical component of professional development. Residents are emerging professionals who are working to establish their careers and build their reputations in the field. Allowing them to manage their own income is an important step in this process. It teaches them how to handle the business side of private practice, an essential skill for any successful practitioner.

Additionally, the current regulation is out of step with modern payment practices. In today’s world, digital payments are standard, and the requirement for payments to go through a third party is outdated and unnecessary. Clients expect a streamlined process where they can pay the individual providing the service directly. This not only makes the payment process more efficient but also reinforces the therapeutic relationship between the counselor and the client.

Finally, the concern that allowing residents to bill directly might incentivize unsupervised practice is unfounded. The regulations already require residents to inform clients in writing that they are under supervision and not practicing independently. This amendment would not change the supervision requirements; it would simply make the financial aspect of their practice more transparent and manageable.

In conclusion, the proposed amendment to allow residents to bill clients directly is a necessary step forward for the counseling profession in Virginia. It promotes ethical practice, financial independence, and aligns our regulations with modern payment systems. By supporting this change, the Board will be fostering a healthier, more sustainable environment for residents, supervisors, and clients alike. I urge the Board to approve this petition.

CommentID: 227273