Supervision: Administrative and Clinical

Nothing is simple when it comes to licensure anyway. Colorado is one of the more flexible states regarding licensure, but we still need to follow a few rules. Of course, as counselors, we also need to follow the ethical guidelines of the American Counseling Association as best we can. The two issues that arise the most frequently with those guidelines are: multiple relationships and fee splitting.

Fee Splitting

According to our ethical guidelines, we’re never supposed to engage in fee-splittng. Okay. How is that even possible? I want to be clear that I don’t charge or accept referral fees. I understand that’s a huge issue for lots of reasons, but in practical terms, LPCCs can’t enter into contracts with insurance companies on their own and need to bill under a fully licensed therapist’s contract. Since that therapist had to do the legwork of securing that contract and is responsible for fielding audit requests, etc. of course they should charge for that. A flat fee seems to be the easiest way to meet this requirement, but since insurance payments vary so widely, a percentage usually makes more sense. Of course that ends up looking more like a split.

Multiple Relationships

Regardless of the situation you have with your supervisor, a supervisor plays multiple roles with their supervisee: teacher, counselor, mentor, the list goes on. On top of all that, we are gatekeepers. Gatekeeping and Remediation are covered under F.6.b. in the ACA code of ethics. Your supervisor is in your corner . . . as much as someone who eventually has to evaluate you can be. In a state like Colorado where LPCCs can work with multiple supervisors, what often happens is an LPCC will goof up with one supervisor and move on to another one without any communication bridge between the two supervisors. Please understand that I am not trying to disparage counselors in our state. This is just a loophole that makes me uncomfortable. I think best practice should be supervisors have a handoff so that the LPCC’s training is consistent and continues, and any outstanding issues are remediated. I know remediation stinks. We have probably all been on annoying performance review plans that may or may not be valid. I do think that making good faith efforts to remedy deficiencies is essential to the integrity of our profession. If an LPCC leaves one supervisor and goes to another, and the new supervisor thinks that the previous supervisor’s concern was silly, fine. Document it and move on.

What I see all too often is a supervisee will send an inappropriate email to me or (worse yet) a state agency, cause a big to-do, and decide it’s better to just quit and move on. We work in an incredibly unforgiving profession when it comes to stuff like that. It’s worse to send a nastygram to someone than it is to sleep with a client. The Board in Iowa might not openly advertise it, but I know it’s true of them. Since pre-licensure training is the last stop before the desert for therapists, it’s important to learn the nuances of mending these rifts before anyone goes out on their own. I am not suggesting staying with a supervisor who isn’t right for you, but it is important to repair the rupture.

Two Supervisors

I recommend having two supervisors: one for administrative and one for clinical.

An administrative supervisor can allow you to bill under their license for insurance and pay you out on a schedule. They can audit your notes to ensure your documentation will survive an audit. They tend to be pretty hands-off, but they don’t want clawbacks or other unpleasantness with insurance so they’ll let you know if anything is off.

A clinical supervisor will work with you on case conceptualization, self-care, and professional identity.

By having one person in one role and a different person in the other, there’s less of a chance of a conflict of interest, even if it’s an imaginary one.

I do want to be clear though that as of this date, you are not required to split supervision this way regardless of what the internet forums might tell you. It’s a recommendation.