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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10/13/19  9:35 am
Commenter: Joanne M Moore LPC, BCETS, CCH, Clinical Supervisor

Not in favor

I understand the inconvenience of not having the ability to directly accept payments.  However, much more is at stake.  It is important to recognize and understand the purpose of this rule. 

This rule is in place to ensure that the Resident in no way represents him or herself as an independent practitioner.  This rule requires that some overarching entity provide protection against such a misrepresentation by requiring all payments to go through that entity.  This rule is in place to protect the public from inexperienced clinicians who might attempt to practice independently. As stated by a previous respondent, this change would enable Residents with little experience to practice independently in any  setting including private practice.  Absent intensive and frequent, quality supervision, this change would be ripe for abuse.   

Second, our profession should not differ from related professions in our rigor for preparing  our Residents for independent practice..  No one wants to see an MD open a practice while still in Resdency .  The same holds true for other health professions.  We should not differ in our application of professional rigor to ensure our Residents are fully qualified before enabling them to work on their own.  This change would likely stigmatize our profession in Virginia since it essentially would permit Residents to practice independently before their training in complete.  No other profession allows this.

This rule was created for a purpose-  protection of the public and our profession.  This change would put both at risk.

CommentID: 76561