I strongly support this petition, as my personal experience in receiving compensation for the work I do as a Resident in Counseling has been varied and often unpredictable. This petition does not remove the requirement for Supervision, it merely removes the requirement that clients and Residents engage in a payment relationship with a Supervisor that is outside the boundaries of Supervision. Supervision compensation should be, and legally is, totally separate from Resident compensation.

As stated in several previous comments, asking a client to pay a Supervisor for the therapeutic relationship established solely with the Resident is confusing to clients and mechanically cumbersome to Supervisor. It also delays payment to Residents, often for weeks or months at a time, depending on the Supervisor’s ethics. I am aware of Residents whose Supervisors “pay them out” quarterly - for compensation the Supervisor took no part in earning, and should not retain for anything more than a minimum period of time. 

When I was unexpectedly required to open a private practice while still a Resident in Counseling in order to guarantee continuity of care for my clients, the most challenging obstacle to overcome was finding a Supervisor who was willing to process payments on my behalf and return compensation to me in a timely manner. Make no mistake, finding a payment processor to run payments through was still entirely my responsibility, with the added challenge of finding a processor willing to deposit funds into an account that does not have my name on it. As an example, my EHR categorically refused to allow me to use their built-in credit card processing feature if the funds were not deposited into my own (named) business bank account. Many Supervisors I approached were unclear on the legality of processing payments for Residents, or were flat out unwilling to engage in the practice out of concerns for the impact on their own tax reporting. 

This change would not impact Residents who have engaged their services as an independent contractor or employee with a counseling practice, or as an employee of a non-profit or community organization. This change would not impact Supervisors who are already declining to consider the unique arrangement required by Residents trying to earn income through private practice. This change would impact only those Residents who are working in private practice before licensure; those who are entrepreneurial; those who are limited in their employability by outside companies due to personal reasons (family obligations/needs, personal disability, physical location, etc.); or those who want to start a private practice toward the end of their Residency (potentially while being fully employed elsewhere in or out of the counseling field) in order to get a “head start” on building their client base before going out fully on their own. 

Finally, as stated by others, removing this barrier will help align Virginia’s licensing requirements more closely with other states as we move forward with the Counseling Compact. Certainly, Virginia should be proud of our stringent licensing requirements, as it provides the citizens of Virginia with an assurance that any licensed Counselor has been Supervised as a Resident for at least 21 months in addition to the hours required during internship (600 hours, usually over the span of 6-12 months) in a CACREP accredited Master’s program. The added burden of “not accepting payment directly from clients” is unnecessary and provides no additional benefit to clients, the Resident, or the Supervisor.