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  2:23 pm
Commenter: Sandra K. Molle LPC, Integrative Counseling Services PLLC

In Favor

I am in favor of allowing residents to bill and collect payments for their services through their established businesses (LLCs).  There are some residents who are quite capable of establishing a private counseling practice.  It is, therefore, incumbent on supervisors to assess whether they are prepared to supervise a particular resident wanting to start a private practice. 

Like all residents, those who establish a private practice are still required to inform clients "in writing of the resident's status and the supervisor's name, professional address, and phone number."  They are not allowed to ". . . represent themselves as independent, autonomous practitioners or professional counselors.  During the residency, residents shall use their names and the initials of their degree, and the title "Resident in Counseling" in all written communications."

However, requiring the supervisor to collect payments on behalf of the resident's business not only creates a redundant exercise in creative accounting, but it puts an undue legal responsibility for the resident's business on the supervisor.  This only serves to discourage supervisors from accepting any responsibility for helping those very capable residents.

CommentID: 76575