I can certainly see how allowing residents to bill clients directly for their services and receive payments directly could simplify some things.  However, I think that if that leads to residents opening up their own practice independent of their supervisor and operating the practice with only clinical (but not operational) oversight from the supervisor things start to get legally sticky quickly.

Supervisors are currently liable, through the concept of respondeat superior, for EVERY action or inaction their supervisees take.  That responsibility means that the supervisor needs broad access to a supervisee's sessions, notes, reports, and correspondence to determine if the supervisee is engaging in sound practice.  If allowing residents to bill clients directly opens the door for residents to open their own practice independent of their supervisor  and then see clients separately from the supervisor's office, then a great deal of oversight could get lost.  For example, the supervisee would presumably utilize their own record system - could the supervisor legally have access to those records?  The supervisor is responsible for every case the supervisee is seeing.  Could a supervisee operating their own practice individually end up underreporting or omitting certain cases from their supervision sessions, leaving the supervisor in the dark about the full extent of the caseload?  If the supervisee intentionally or unintentionally engages in fraudulent billing is the supervisor also responsible?  How can a supervisor observe the full scope of the supervisee's skills if the supervisee is operating independently at their own business?  Simply relying on the supervisee's self-report of everything is not enough to be able to adequately assess the supervisee's clinical skills, ethics, professional demeanor, etc.  The amount of liability involved when a supervisee is operating their own practice independently seems to increase dramatically.  I fear that IF adopting this change will open the door for new residents to immediately establish their own businesses then the number of people willing to supervise residents under those conditions and take on the added liability will decrease and exacerbate the shortage of supervisors thereby exacerbating the overall shortage of providers in the training pipeline.  

I would urge the Board to think very carefully about both the potential benefits and the potential drawbacks before adopting this change.