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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10/23/19  8:44 am
Commenter: Megan MacCutcheon, LPC

In favor - Issue of accepting payment vs. starting a practice

I want to add that there is a major difference between whether residents working in private practice can accept payment directly and whether residents should be ALLOWED to work in private practice. As Sharon Watson mentioned, "In Virginia a resident is allowed to have a private practice if they are under Board approved supervision with a Board approved supervisor and if they identify themselves as a Resident in Counseling under supervision and by whom."  Residents are already allowed to run a private practice. The debate here is where they can personally accept their own payment in such a setting. 

I personally think that it is beneficial for therapists who plan to start a private practice to do so DURING residency, when they are under supervision and can get input on how to do it in the most ethical and "best practice" ways.  

Yes, running a business is a separate skill set and it's one that can be learned and fine tuned with the help of an experienced supervisor. Residents would benefit from experience and guidance in terms of navigating renting space, obtaining malpractice insurance, creating forms, writing/enforcing policies, setting fees, etc. I do think it's useful to have a supervisor lay eyes on the more mechanical side of the business, as it is ultimately all important aspects of the clinical work. 

Once a therapist is licensed, there is no oversight regarding whether they choose to get appropriate consultation and guidance in terms of setting up a private practice.  Licensure ensures they have clinical experience, but they may not have the experience of starting up of a business nor the "business-savvy" to navigate all the necessary details of running a successful and ethically-sound practice. Thus, I think there's a major benefit to residents doing it during the period where they are being supervised and can consult about the start-up and ins-and-outs of running a business.  It's not hard to find a balance in terms of focusing on client cases while also discussing the various aspects of setting up/running a business and dealing with various issues that come up regarding the business side that DO impact clients and the clinical work. 

That said, I do think it is case-by-case whether a resident is actually READY to begin a private practice and I believe it is the responsibility of the supervisor to gauge readiness and advise their supervisee as to whether or not they are in favor of them starting a private practice at any given them.  The input and direction about readiness and timing around starting a private practice from an experienced supervisor can be INVALUABLE to a resident who is navigating all that is involved with the start up and considerations regarding work/life balance, impact to current and future clients, etc.  

A supervisor's support or lack thereof is the gate-keeper to the public, not the collection of money.  If a supervisor has agreed to supervise a resident's private practice caseload, whether or not they collect the payment, they have indicated their belief that the supervisee is ready and has enough clinical knowledge to be in private practice.  

If residents are adhering to regulations regarding how they represent themselves and if supervisors are doing their due diligence by responsibly deciding whether residents have the clinical experience and personality/skill set to successful run a practice, then the issue of who payment is made out to is a moot point.

CommentID: 76618