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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10/18/19  7:46 am
Commenter: Marianne S. Coad, MAMFC, LMFT, LPC Synergy Counseling, LLC


I have been a supervisor for many years as both an LMFT and an LPC in three states. Virginia has always been the standard bearer as one of my colleagues has stated. As a supervisor, I consciously choose to take enormous risk to my license by directly supervising Residents in my practice. Allowing a Resident to take direct payment will only increase malpractice risk to both Supervisor and Resident. A Resident will be able to “Hang a Shingle” and operate independently by receiving direct client payment and I believe many will do just this and be very excited about it and be too young in the profession to clearly comprehend the risk involved. I often receive phone calls from graduating Interns planning on opening their own business in Residency to which I gently help them understand the regulations and the protection provided for them through the regulations. I urge the VA Board of Counseling to NOT APPROVE this petition.

The Residency period is for learning and increasing therapeutic skills and should not be a time for learning how to run a private practice on your own with a minimum of one hour of supervision per 40 hours. As a colleague has stated, no other profession allows for a Resident to accept direct payment as this one act clearly identifies the Resident as an independent practitioner to the public and creates confusion and one might even go so far as to say is deceptive.

Regarding the accounting of Resident’s Client payment records: There are so many software systems that automatically do all of the accounting for you and will determine exactly how much a Resident is due within any time frame a supervisor would create. Accounting should not be an issue in this discussion rather this discussion should focus of increased malpractice risk for both Resident and Supervisor. As a Supervisor who directly hires Residents, my malpractice insurance for each Resident is astronomically high due to the risk. The malpractice insurance will only increase with the approval of this petition. If this happens, the existing shortage of Supervisors in VA will also increase. Supervision of Residents is a method of giving back to the field of counseling, so why would a supervisor want to increase risk?

In summary, The process of becoming a fully licensed counselor is in place for a reason: To do no harm and protect the public specifically our Clients. I understand the desire for this petition to pass. However, the increased risk to both Residents, Supervisors and our Clients does not warrant its approval. 

CommentID: 76591