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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8/27/24  6:12 pm
Commenter: Anonymous

Support - It's about having more OPTIONS, not forcing ALL residents to bill clients directly.
 

This is a much-needed change! No one has given a real, non-vague reason to deny this petition. The most reasonable point that someone has made is that if this petition is approved, there's no guarantee that insurance companies will allow pre-licensed counselors to bill directly. This may or may not be true, and I think that more research needs to be conducted before one can really make this claim. Not all clients use insurance to pay for therapy and residents in private practice can only accept self-pay clients - but they can't bill them directly. Therefore, IF there actually is an issue regarding residents billing insurance, that's no reason to deny this petition. If approved, this petition will allow residents to bill self-pay clients directly. The insurance aspect of things is a separate issue that may or may not warrant separate action.

This petition is about allowing residents to bill clients directly and people keep trying to make it about residents owning a private practice (which is already allowed) and keep making vague claims about safety, "developmental" capabilities, and disruptions to the overall supervision experience. Yet, no one has explained HOW changing this rule will actually cause these things to happen. These claims are especially baffling given that there are numerous states in the US (and numerous countries globally) that allow their supervisees to bill clients directly. How is it possible that all of these other jurisdictions see no problem with supervisees billing clients directly, yet, in Virginia, there are safety, developmental, and supervision issues?

Also, let's not overlook the fact that, if this petition is approved, all it means is that residents will have more options - that's it! Residents will be able to choose to work in an environment where they can bill clients directly or choose to work in an environment where someone else bills clients. If a resident isn't comfortable with billing, they won't HAVE to - nothing changes for them. But for the residents who are comfortable with it, they'll now have that option.

What's mind-blowing is that so many people think that residents are too incompetent and/or irresponsible to bill clients directly. I am a supervised, 38-year-old resident in counseling (yep - because not all residents are inexperienced 20-year-olds) who owns a private practice, and as such, I've been able to obtain a business license from the State of Virginia as an entrepreneur, develop and implement a business model, develop and monitor a business budget and cash flow, hire a Virginia registered agent (as required by the State), file and maintain the appropriate taxes, subscribe to and utilize various business tools, purchase and maintain appropriate liability insurance, create practice policies and procedures, build my own clientele/caseload, and maintain my own client schedule all while keeping a 100% client retention rate. Not to mention that I've achieved all of this while fully maximizing the benefits of the supervision experience. Running my business has had zero negative impact on my supervision experience. In fact, I truly feel like it has enhanced it! Not only have I been able to sharpen my skills, enhance my knowledge, and continue to develop my sense of professional identity, but because of owning my own practice, I feel more competent and responsible than I ever did when I worked at an existing practice. But, according to some people here, somehow I am incapable of billing my clients directly?

CommentID: 227461