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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10/25/19  3:24 pm
Commenter: Amy Clay, Sunstone Counseling

Not in Favor

Not in favor. 

It is my understanding that the restriction regarding Counselors in Residence not being able to directly accept client payment is in place to ensure that a Counselor in Residence can not create or operate an independent entity until fully licensed. 

A Resident in Counseling should be working for an agency/ mental health organization or pre-established private practice business that employs the Resident in Counseling. All payments should be going to said business/agency.  If this payment restriction is removed, Residents in Counseling could theoretically “hang their own shingle” or create their own private practice if they find a supervisor willing to agree to this model. I agree with another respondent, “This rule requires that some overarching entity provide protection against such 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... Absent of intensive and frequent, quality supervision, this change would be ripe for abuse.” 

Furthermore, if a Resident in Counseling can start accepting payment and create a “private practice entity” to work with clients creating the perception to the public that the “practice”, especially when the Resident in Counseling is the only therapist on staff, is on  the same level of experience, support, and credibility as other private practices. I think this puts a burden on the clients seeking services to distinguish who they are engaging in services with and causes confusion for the public.  

This change would put a lot at risk for Counselors in Residence, Supervisors and the Clients looking for services if the above-mentioned example could be permitted. 

Finally, the Board of Social Work and Psychology do not allow residents to accept payment.  Why would Counselors be an exception? 

Amy Clay, LPC

CommentID: 76652