Cognitive Biblical
Therapy Coursework
Counseling Through God’s
Transformative Word
Course 6 Chapter 12
Chapter 12 Professional Licensure
a. Supervision for State Licensure
b. Church - Supervisor - Student Agreement
c. Counseling Office Alternatives
Essay Questions: Answering the section questions (red buttons) is a great way to prepare for the end of the Chapter Quiz. Chapter 12 questions will help you review the text material and apply to your present or future counseling setting. The section questions will provide Dr. Wilkinson’s feedback to your answers.
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Chapter 12
Professional Licensure
Supervision for State Licensure
As we continue our discussion of licensure, I would like to talk with you a little bit about what happened when I moved to Missouri. I called the State of Missouri licensing board office shortly before moving here, found out that they didn't really have licensure totally in place, and that there was a religious exemption. After I moved here, though, the laws changed, and it became more apparent to me that I should be licensed for those reasons I spoke to you about. I went back to school to get the required coursework. In the licensure process, I set up a meeting with the licensure committee, and explained for future students of mine, who seek my supervision for licensure, there doesn't seem to be a place for Biblical Christian counselors who use the Scripture to find a place for this two-year practicum. And they knew this was a problem. I asked, “What would allow me to have a counseling practice and provision for students to be supervised?” And they said, “Get your license first, come back and talk to us, and we'll try to negotiate an agreement.” Well, I got the license, went back, and I said, “The state law talks about how you have to have a contractual arrangement between yourself and the student. What's that mean?” They said, “We don't really know. No one has taken the time to write contracts, show them to us, or given us any help with these guidelines.”
The state congress wrote the laws, but didn't write procedures for the law to be implemented, and then had to deal with all the problems the law created. I said, “How about I go to my attorney, and I will try to draft a contract between myself and the student so that I can have an agreement? Another issue I'd like to address is the law that says the student must work under my authority, and the implication is in my office. I don't have an office big enough to hold other staff counselors. I'm in a church. It's a host facility. Is it possible that if I could draw up a contract between a student, myself and a church that would fulfill the state law?” After a short discussion, they finally said, “Yes, that's fine. As long as they're under your supervision, you're licensed, and they're part of your practice, then that's fine.”
As we briefly discussed in the last chapter, a contract that my attorney and I constructed for the state of Missouri. One says, “Contract for Supervisory and Training Services”. Find this contract, that starts this agreement is made this whatever day of whatever month and year, by and between this person or this corporation, a Missouri a Missouri Corporation, hereby referred to as “BCCM, Inc.” and (Name of Student), hereinafter referred to as “Student”. And then it goes on to list all the different things. It's basically the same thing that I put in that contract that you looked at only it's in legalese, and it lists the Biblical Christian Counseling Center as the person that's sponsoring the student in this facility. So that's where I fulfilled the Missouri State law. This person who is my student is an employee of BCCM, which is an extension of my office. This got us around the problem that resulted from the way the state law was written. This opened up every church, anywhere in the state, as an approved site for supervision under the licensure laws, and gave credibility so that Biblical Counseling was acceptable to the state.
That was a phenomenal thing that God did for us, because I was able to extend this methodology through my students who were getting licensed in other parts of the state. We can meet licensure laws and still distribute the methodology of Cognitive Biblical Therapy, and use churches to reach needy people. So, the contract is between BCCM, Inc. (my business) and the students who are in the state licensure process. The person is an employee of the center, what training and supervision entail, and the term of the agreement. The contract lists the parts of the state licensure law that is being fulfilled, and the obligation of the students for the cost of supervision. I put a flat percentage of their income, which is 10% that I receive. You do this to be credible to the state licensure board. Because there is a mandated amount of time the supervisor spends consulting on cases, the 10% is a payment for the counselor’s time and the use of his knowledge and reputation. This allows the student to earn a reasonable income, meets the state law obligations, and gets us established in a church. Additional requirements are listed such as carrying liability and malpractice insurance, like status of the parties, termination, and any support that I give the center. Then the final page of the contract is for signatures.
Note the form for supervisees to complete for their supervision checks is in the Course 6 Required Written Documents under “Supervision Record”. Another supportive document called “Guidelines for Supervision” gives an outline of key items for a student and supervisor to document in order to fulfill state supervision guidelines and contractual agreement.
The Contract for Supervisory and Training Services form has worked well as a way to satisfy the State of Missouri and Illinois licensure laws in a church rather than rental space where the cost will be a burden for the new counselor. If you plan to expand through other locations, you create credibility. You are welcome to use any of these forms, because they have been developed by an attorney, but specifically to Missouri. You may find similar or comparable forms online for a fee. My best advice is to investigate your options, know what is legal, and talk to people about what you need. Don’t be impatient or impulsive with your supervision responsibilities, which will also be a model for your students.
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What does a Supervisor-Student Contract legally allow in the supervision process?
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Dr. Dan's Answer:
The supervisor collects a flat percentage of the student's income -- which is credible and legal, since the supervisor is sharing his or her knowledge and reputation. The contract then allows the student to earn a reasonable income, meet the state law obligations, and get a counseling practice established in a church.
Church - Supervisor - Student Agreement
A second document in the Course 5 Required Written Documents that we briefly discussed in the last chapter, is the “Contract for Biblical Counseling Services” (student) for the Student and Church, with BCCM/Dr. Daniel Wilkinson as supervisor. This additional document actually is another contract that focuses on what is expected primarily out of the student or non-licensed counselor and the supervisor while practicing in a particular church or parachurch setting. This is different from the Proposed Counselor Church Agreement document (previously discussed) that is a practical agreement form between the counselor and the church, which can be used as a “boilerplate” for the student/non-licensed counselor and the church too.
In the “Contract for Biblical Counseling Services” (student) document, starts out saying, THIS AGREEMENT is made this day of , 1992, by and between [NAME OF CHURCH], a Missouri (pro forma, religious) (Not For Profit) Corporation, hereinafter referred to as "Church," and [NAME OF STUDENT], hereinafter referred to as "Student." It is very formal, like the contract between the student and supervisor which provides a professional integrity that gives credibility to the student’s relationship with the church, state licensing board, liability insurance provider and any other stakeholders.
Now a significant concern that State Licensing Boards and churches generally have is the collection of fees, which is a business transaction that requires legal oversight. If you are not licensed or a student practicing in a church or parachurch organization, there is a typical religious exemption for the collection of fees (as previously discussed). For the various types of supervised non licensed therapists and/or students (counselor in training or provisional licensed counselors) their collection of fees that eventually turn into their income has legal statutes for business accountability. Since this type of counselor is not licensed by the state, the counseling licensure laws may restrict the student from collecting the fees directly, but the fees can be paid to the church. As discussed previously, the student is responsible for paying taxes, keeping records in an accounting system of counseling fees, what has been invoiced, and what the church has paid you (when the church deposits your receivables and writes a check back to you). They will not keep accounts or pay taxes.
A second concern in the church and non-licensed providers is who pays the counseling administrative costs. In some of my church agreements, I paid for the copy paper I used, printing brochures, postage and other office supplies. Using clerical support, CPA services, digital online tools and keeping your records confidential are your responsibility, though the supervisor is available to walk you through practical steps.
Next is the question, “What can be expected by a new counselor in training to earn?” Depending upon the year you are taking this coursework and the area of the country or globe you are practicing, a full-time practice and income generally take up to three years to develop. So be realistic, plan accordingly and with wisdom. You may be able to receive an income from averaging 10 clients a week, a gross of $35 – 40,000 a year, based upon $75-100 fee per session. Keep in mind two things: 1) giving 10% of your counseling services as “pro bono”; and 2) using a sliding rate scale since you are practicing in a church, rent and utility free. Consider options to support your first three years of counseling ministry as an initial stipend can help sustain your practice and it builds over time through the grace of God.
Fully answer the following question from the content you just read and submit your answer to find your score and Dr. Dan's answer to the question.
If your state has a licensure law, it may demand that you do not receive direct payment of counseling fees unless you are licensed. Discuss the process that you can utilize in order to enable the church to help you with the proper processing of financial concerns in this matter.
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Dr. Dan's Answer:
Fees can be paid directly to the church itself. This income can then be given back to the counselor without any income or FICA taxes withheld -- this is the counselor's own responsibility. The church can list this income in the same manner as income from a Christian school.
The church also needs to provide free overhead and office space in order to qualify the practice as a ministry of the church, which is not for profit. In effect, the counselor operates under the status of the church, and the church does not violate any stipulations of its not-for-profit status.
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There will also be some issues in regard to finances that the church is not responsible for. List and discuss some of these issues as they relate to your accounting system, taxes, and other items.
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Dr. Dan's Answer:
The counselor is responsible for keeping track of all client payments, personal tax liability -- both federal and state -- and the purchasing and maintenance of whatever accounting system he or she uses. This may entail the purchase of a computer, an accounting software system, or a manual system to keep track of these items.
Fully answer the following question from the content you just read and submit your answer to find your score and Dr. Dan's answer to the question.
What is a realistic level of income that you can expect, depending on whether your practice is part or full time?
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Dr. Dan's Answer:
A realistic level of income for a full-time practice (25 to 30 sessions a week) is between $35,000 and $45,000 a year before expenses and taxes.
Counseling Office Alternatives
As we near the end of Course 6, I want to answer some questions you may have. Such as, “Are there alternatives to a private practice in a church?” One option is a staff position as a director of a counseling ministry in a church which could pay a salary plus benefits that would include housing. That could mean that you are the only counselor, or that you counsel and organize other counseling staff members. Being on staff would mean that you are paid by the church and any fees that are collected go directly to the church. Clients pay the church or make contributions to the church. If the counselor is not licensed, he/she absolutely must have someone to refer clients to when you are not able to help the clients. These would be those in your professional network of medical, mental or legal professionals who have agreed to work with you. Have someone you can call and consult with. Don't wing it if you don't have licensure, credentials, or certification. Don't call yourself a minister of counseling, unless you know and abide by your limits.
Another option is holding a staff position that involves a combination of church duties and part- time counseling, such as being the youth minister and the Minister of counseling (depending upon your credentials). You could earn fees through the church and a salary from the church. A third potential is working in a counseling center which is supported by a denomination or many denominations. You would need to check the legality of such an arrangement. In some situations, people get together with a number of churches, contribute to this center to provide counseling for their people, and then that's how the fees are paid. Any fees you collect will go to your salary, but the denomination will pick up the slack between what you earn and what it takes to run the place. Fourth, the option of joining or setting up a secular practice that allows you to counsel from a Biblical perspective, agreeing with your Biblical method of counseling and your Christian principles.
You have to be careful to check out the costs for being a part of the practice as I have described before. They can range from being fair to being almost a sweat shop by charging for what part of the office you and your clients use, which can add up to about 50% of your income. As I explained before, be sure to have a written agreement. If they have a contract, have an attorney review it for you.
The last section of Course 6 answers the question, “What are the types of business or legal relationships that I can establish from my practice?” And we've gone over these somewhat, but the sole ownership is basically very limited tax liability. You're just taking care of yourself and a one-man operation. The second one is incorporation we've talked about, where you get into FICA, Social Security, Medicare, and matching payments. Corporations can be for profit or not for profit. The non-profit has an extensive application procedure, but it will not stop your liability for taxes. It does give you some exemptions for things you are not taxed for. It also requires things like a board of directors, who meet once per year at least, and oversee the corporation. Then, a last option is to incorporate with supporters, such as a conglomerate of churches that contribute to the Counseling Center's existence, rent, utilities, office supplies and so forth. But some of these other types of organizations, like corporations not for profit, are necessary if you plan on running a clinic with 8 to 12 staff counselors.
In many of these situations, there are business-oriented requirements that you will encounter if you decide to establish your practice outside of the church setting. I've mentioned contractual agreements, work time related demands that may bind you to a clinic or another individual's private practice. They all are not as bad as I have described, but may have partial restrictions on your use of Biblical counseling. In other appropriate settings, you may not encounter any restrictions on your use of Biblical counseling.
You, as a counselor, pastor, student or lay leader have some options here. We've looked at the church as a host facility. We've looked at sole proprietorship or corporations or not for profit. We've talked about clinics and being in another person's practice. Whatever you choose to do, make sure that you're thorough, that you're professional, that you get the professional help you need, like a CPA, and be careful and go slowly. If you use the church as a host facility, use the proposals, the contracts, the letter that I gave you, which seem to work very well. That will help you save money as you set up your practice. It eliminates much of your overhead and allows you to get into that market of people who are looking for good professional Biblical counseling, and haven't been able to find it.
Copyright 1987, 1990, 1993 by Daniel D. Wilkinson. All rights reserved. For more information concerning this material, write to:
The Biblical Christian Counseling Ministries, Inc., 2730 Radcliffe Dr., Florissant, MO 63031.
Any reproduction of this material without the express written consent of the author is prohibited. Printed in the U.S.A..
Fully answer the following question from the content you just read and submit your answer to find your score and Dr. Dan's answer to the question.
What are some alternatives to a private practice either within a church setting or a secular setting?
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Dr. Dan's Answer:
Some alternatives include working in a staff position within a church setting as the director of a counseling ministry; working in a staff position that involves a combination of church-oriented pastoral duties and a part-time counseling ministry; directing or working in a counseling center supported by a denominational or multi-denominational financial structure; or working in a secular practice that will allow the counselor to work from a Biblical perspective.
Fully answer the following question from the content you just read and submit your answer to find your score and Dr. Dan's answer to the question.
What are the types of business or legal opportunities for the establishment of a counseling practice that can be chosen?
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Dr. Dan's Answer:
The practice can be established as a sole ownership or a corporation -- either for profit or not for profit. The practice can also be a not-for-profit organization, either incorporated or not incorporated. Or the practice can incorporate with supporters such as a conglomerate of churches or individuals that contribute to the counseling center's existence by providing rent, utilities, office supplies, wages, etc.
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Course 6 Project Assignments
As discussed in Chapter 1, you will need to complete all three assigned Projects as a part of Course 6. There are two parts for each project, first is to open, read and complete the project assignment. Second is to send each completed assignment to your mentor for review and grading. The mentor will use this checklist: Project Assessment. If you have questions or concerns, please reach out to us at: cbtcoursework@gmail.com