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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8/7/24  5:32 pm
Commenter: Anonymous

In favor - too many uninformed or biased supervisors
 

As many others (including the petitioner) have repeatedly stated, residents can already own a private practice in Virginia. Yet, many LPCs/supervisors are saying (in the comments and in professional practice) that if residents can bill clients directly, it would allow them to own a private practice. So, what we have here are supervisors, in particular, who are uninformed and aren't being responsible enough (as mentors guiding new counselors into the profession) to simply read what's in front of them or take the time to be informed of the rules and regulations they're supposed to be teaching residents - OR we have supervisors who are informed of the current regulations, realizing that residents can own a private practice, but their bias on that issue won't allow them to be open-minded, critical thinkers on the separate issue that is this petition - "allowing residents to bill clients directly."


What it shows, however, is that it's (mostly) these supervisors that are for the continuation of supervisor control over the income of residents (by being against residents directly billing their clients), citing "harm to the public." What's harmful to the public is uninformed, biased, and inattentive "stewards of the profession" AND supervisors who want to profit off of residents.


Some say that not allowing residents to directly bill clients protects the public because it forces the resident to inform the client of their residency status (even though there are currently numerous regulations in place that require residents to do this in various ways). Preventing residents from directly billing clients isn't adding protection for the public, it's allowing supervisors to be able to rely on their control over the resident's income so that they can be more "hands-off" supervisors. Saying that this regulation is in place to oversee resident misrepresentation also means that this regulation is clearly in place to relieve supervisor oversight of resident misrepresentation. Meaning that if this regulation wasn't in place and residents didn't have to funnel their income through their supervisors, then supervisors would have to be more attentive to their residents and make sure that clients are being informed properly. But shouldn't this be happening anyway? Regardless of how the money exchanges hands, supervisors should be involved enough to teach residents how to use the proper titles/credentials and cite the name of their supervisor in all public and client materials (i.e., business cards, websites, informed consent forms, etc.), as well as actively reviewing their materials to make sure that misrepresentation isn't occurring. If the supervisor isn't doing this, then they're just as responsible as the resident, if not more so. Yet, only the resident is punished (including all other residents) via supervisor control over their money - and for this privilege, mind you, many residents pay their supervisors.


Some also claim that there are currently too many residents who are not informing their clients of their residency status (thus Residents should not be allowed to bill their clients directly). If this is true, then it just goes to show that this regulation is not effective in it's supposed purpose of forcing residents to inform their clients. So, what's the point of having it? The only real purpose it serves is to increase profits for supervisors who are taking advantage of a system that is supposed to help residents.


There's an overwhelming amount of research that shows that:

1) "Failure to adequately attend to issues of power in supervision can result in ineffective or even harmful supervision."

2) "The supervisory alliance [between supervisor and supervisee] has come to be increasingly regarded as the crucial and pivotal component in the successful prosecution of the supervision relationship."

Approving this petition would help to rectify a clearly imbalanced power dynamic and help restore supervisory alliance throughout Virginia.


Furthermore, it has to be noted that weak supervision is not the resident's fault and residents should not be punished because of uninformed, biased, or inattentive supervisors. "There's no such thing as bad students, only bad teachers" - if supervisors do their jobs well, then residents will most likely do theirs well - and this happens quite often actually! There are fantastic supervisors who mentor fantastic residents!


In my experience, supervisors choose to become supervisors either 1) to teach/mentor the next generation of counselors because they genuinely care about and love this profession, or 2) to make money - (sometimes both). Regardless of the reason, supervisors choose to become supervisors knowing that they are responsible for the residents they take on - that's the job. So, why then is the issue at hand solely on the shoulders of residents?


At the end of the day, if the Board denies this petition, they should, at the very least, seriously investigate the current state of the supervision experience in Virginia - including all of the claims being made in the comments from both sides. No matter where you stand on this particular issue, it's clear that some very serious and potentially harmful problems exist within the supervisory experience in this state.

 


1) Cook, R. M., McKibben, W. B., & Wind, S. A. (2018). Supervisee perception of power in clinical supervision: The Power Dynamics in Supervision Scale. Training and Education in Professional Psychology, 12(3), 188–195.
2) Watkins, C. E. (2014). The Supervisory Alliance: A Half Century of theory, practice, and research in Critical Perspective. American Journal of Psychotherapy, 68(1), 19–55.

CommentID: 227311