Entail – verb – inˈtāl, enˈtāl/

  1. involve (something) as a necessary or inevitable part or consequence.
    “a situation that entails considerable risks”

Rule 64B4-3.008(1) requires that a Registered Interns “…continue in supervision …until until he or she is in receipt of a license to practice the profession for which he or she has applied or a letter from the Department stating he or she is licensed, even if the two (2) year post-masters supervision requirement has been satisfied.”

That rule seems clear, right?  But, what about someone who has a Qualified Supervisor and who fails to report other clinical services he/she provides?  What are the additional (unspecified) risks entailed?

Rule 64B4-3.008(1) was recently used in a disciplinary action against a Registered Marriage and Family Therapy Intern following a complaint to the Board.  The infraction was the provision of couple’s counseling outside of her work for her employer to the parents of children that were being seen as a part of her employment.  The Registered Intern appears to have had regular supervisory sessions with her Qualified Supervisor.  However, the Administrative Complaint suggests that she didn’t disclose this outside work to her Qualified Supervisor and was, therefore, providing clinical services without proper supervision.  It isn’t clear whether or not the Registered Intern billed and received payment from the couple for their counseling services above and beyond her salary as an employee.

Registered Interns should notify their Qualified Supervisor(s) about any additional clinical services that they provide or desire to provide.  In this process of disclosure they protect themselves, their clients, the supervisory relationship and probably their employment.  Qualified Supervisors would do well to ask their supervisees about their interest in providing outside services and determine whether or not there are conflicts of interest involved.  The Qualified Supervisor can determine whether or not he/she wants to assume responsibility for ‘extra work’ and advise the Registered Intern to secure additional supervision from an additional Qualified Supervisor whenever outside/extra services are deemed appropriate and properly provided and documented according to the law.

– Catherine L. Waltz, PhD, is an adjunct professor in the graduate program of the School of Social Work, Barry University.  She is a continuing education provider in the state of Florida providing courses on professional ethics, laws and rules, supervision, mental health error prevention and a specialist in domestic violence. https://drwaltz.com/courses/workshops-at-a-glance

The educational commentaries provided by Dr. Waltz do not constitute a legal opinion.  If legal advice is needed, it is recommended that contact be made with an attorney qualified in the jurisdiction in which you practice or is applicable to your case.  We recommend that you use your knowledge of the law and your code of ethics in conjunction with this and any other information when deciding upon your course of action.