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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10/14/19  8:56 am
Commenter: Elizabeth Sloan

Do not agree
I have supervised residents for more than 10 years. I disagree with allowing residents to accept payment. 1--If residents accept payment directly, they will seem like licensed professionals no matter how hard they try to fight that perception. Making payment to the resident's supervisor makes it crystal clear to the client that the resident is unlicensed. 2--If residents accept payment, it is more difficult for supervisors to have checks and balances on their activities. Residents are busy people. Logging their hours is cumbersome and when residents must report their hours in order to be paid, it keeps the supervision process transparent and timely. 3--Supervisors are busy people and the same applies to them. 4--I agree with the comment that if we allow residents to accept payment, Virginia will be less stringent than other jurisdictions. We are standard-bearers and should remain so. 5--I agree with the comment that residents face barriers because of few opportunities for jobs in the public sector. Virginia should address those barriers through systemic changes and changing this reg will not solve the problem. 6--Supervisors accept a lot of responsibility when admitting residents to their practices. It is part of the service we do for the profession and the public. It is inconvenient to accept payments for residents and handle disbursement to them. But there is nothing particularly convenient about supervising a resident! Respectfully, Elizabeth Sloan, LPC
CommentID: 76572