Virginia Regulatory Town Hall
Department of Health Professions
Board of Counseling
Regulations Governing the Practice of Professional Counseling [18 VAC 115 ‑ 20]
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10/4/19  1:16 pm
Commenter: Sharon Watson, LPC, LMFT, LSATP, NCC, ACS

ABSOLUTELY IN FAVOR of allowing Residents in Counseling to directly accept client payments

The regulation that Residents in Counseling may  not "directly bill for services" is an antiquated concept and places a tremendous strain on both residents and supervisors.

It's often difficult for a master's level graduate to find a job in our field because of: a lack of job openings (due to increasingly diminished funding for public mental health treatment), low paying jobs that don't provide a living wage (let alone repayment of student debt), or limited opportunities to contract in an established private practice.  So, unable to find a job after months of searching, some graduates turn to the only option left, even if it isn't their first choice, of starting a private practice.  Unfortunately they are often stopped in the process because they can't find a supervisor who will take client payments.

But supervisors took client payments in the past, so what's changed?  Why are supervisors more reluctant to take their residents' client payments?  The possibilities are: 1. Depositing someone else's income into their account increases their own income (even though all the payment is returned to the resident); 2. Split payments, which were typical in the past (splitting the client payment between supervisor and resident) would not increase the supervisor's income, but were deemed illegal and no longer an option; 3. In the past a supervisor could accept the residents' client payments by check and simply endorse the check and return it to the resident, but with new technology based banking that's no longer an easy option; 4. It's extremely time-consuming to take residents' multiple client payments and electronically transfer the funds back to the resident especially if a supervisor has more than one resident in private practice; and 5. Many supervisors don't understand or are afraid of the process.

So this regulation is incredibly unnecessary when the entire amount of the client payment must be given to the resident in it's entirety.  It's likely that clients don't understand this behind the scenes process and may be confused by why their payment goes to the supervisor when it's the resident that provided the counseling.  What message does this send to clients about the value of the resident's work?

It's understandable that the intent of the regulation was to assure that clients understood that the resident in counseling is not an independently practicing clinician and is under supervision during residency.  However, this requirement is incredibly redundant when residents must have their supervisor's name and information on everything they give to a client (practice forms, business cards, advertising, etc.) as well as verbally inform their clients they are under supervision and by whom.  Doing that already makes it crystal clear that a resident is NOT working independently and whether or not a resident takes payment seems superfluous.  It would be more important to spend the energy to  confirm that a resident is, in fact, informing their clients they are in a residency under supervision. 

Becoming licensed as an LPC is already a lengthy, costly, and time-consuming process.  Let's support our residents and their supervisors by removing this truly unnecessary impediment for both.


CommentID: 76525