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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10/10/19  5:15 pm
Commenter: Crystal Hamling, Resident in Counseling, NCC, CCMHC

In favor of residents in counseling directly accepting payment

I am in favor of removing the restriction regarding residents directly accepting payment for their services, in agreement with Sharon Watson and many other commenters here.  I fully support the idea of residents needing to make it clear to their clients that they are working under clinical supervision and are not practicing independently, and residents are required to communicate this to the public in a number of ways.  But residents not being able to directly accept payment for their services is an unnecessary hurtle that makes things more complicated for residents and supervisors and does not increase public safety, and in fact often confuses the public.  The amount of increased administrative difficulty that this regulation imposes is not proportional to the amount of benefit that it intends to provide to the public, and in fact seems to confuse the public rather than benefit it.  Let’s remove this unnecessary impediment in order to streamline things for residents, supervisors, and clients alike.

CommentID: 76539