I have some reservations about allowing provisionally licensed clinician to bill for services, but overall my position is neutral for the reason's below.  

First, just because the board makes it okay for this to happen does not meant that insurance companies will comply.  There would have to be a change in legislation, which may make this decision beyond the scope of the board.

Secondly, I do echo my other peer's comments that state that this would allow provisionally licensed counselors to open their own practice.  The alternative to this would be to have every private practice licensed by the board or DBHDS to ensure that someone qualified is in charge.  Having gone through the licensure process, I do not think this is something that a private provider would want, nor do I think that DBHDS or the Board would understand or want such a workload.  Without agency licensure, then the resident's actions would put tremenduous liability on a supervisor, which would lead to fewer supervisory relationships, and do nothing to ease the shortage of counselors we are currently experiencing.  Alternatively, it would also allow residents to be exploited, particularly by larger companies such as BetterHelp who would pay them very little and offer no oversight.  

So, while I am all for systemic change and modernization, I think that there would have to be other things to follow such a change that could be problematic for private practices and supervisors.