8.6 Gatekeeping

Gatekeepers play a crucial role in training incoming counselors in the profession and protecting the public from harmful practices and professionals who cannot practice effectively. With regards to establishing counselor competence, as previously discussed, gatekeepers play an especially crucial role in eliminating self-evaluation bias common within most professions (Mabe & West, 1982; Walfish et al., 2012) by providing a more objective evaluation of counselor performance. Gatekeeping is a critical ethical responsibility for counselor educators and supervisors, ensuring that individuals entering the counseling profession are adequately prepared to serve a typically vulnerable population. This responsibility underscores the importance of formative and summative evaluation processes within counseling education programs, designed to assess students’ readiness and competence to practice independently (Homrich et al., 2014). Gatekeeping is a multifaceted process that, at times, may lead to the dismissal of students who are unable or unwilling to meet professional standards despite remediation efforts (Ziomek-Daigle & Christensen, 2010).

The Gatekeeping Process: Evaluation and Remediation

Counselor educators and supervisors incorporate systematic checkpoints to evaluate students’ knowledge, skills, and professional disposition. When students demonstrate insufficient mastery of required competencies, remediation efforts are employed to foster growth and improvement. However, if counselors cannot meet competency benchmarks or fail to respond to remediation, further action, including dismissal from training programs or complaints to licensure boards, may become necessary (McAdams et al., 2007).

Remediation and Due Process

Ethical gatekeeping necessitates adherence to due process to ensure fairness and transparency. Counselors must have clear expectations, opportunities to address deficiencies, and support throughout the remediation process (Kress & Protivnak, 2009). A comprehensive remediation plan includes:

• Clearly defined areas of deficiency.
• Specific, measurable steps for improvement.
• Established criteria for evaluating progress.
• A timeline for reassessment.
• All parties’ signatures signify agreement and accountability (McAdams et al., 2007).

Counselors who demonstrate improvement within the agreed-upon timeframe may continue in the program. Conversely, if insufficient progress is observed, dismissal from the program may be warranted, with documentation of the remediation process as evidence of ethical and procedural integrity.

Challenges in Gatekeeping: Ethical and Legal Considerations

Referring a counselor for licensure board intervention or dismissing a student from a training program has significant implications.  While necessary to uphold professional standards, this decision carries the potential for legal repercussions, such as lawsuits against the institution or individual (McAdams et al., 2007). To mitigate this risk, counselor educators and supervisors must prioritize self-protection by following established protocols, engaging in ongoing professional development, and seeking mentorship from experienced colleagues.

Ethical Implications of Gatekeeping Decisions

Gatekeeping serves the dual purpose of protecting the counseling profession’s integrity and safeguarding future clients’ welfare. Counselor educators and supervisors who engage in this process with diligence and transparency help ensure that only competent, ethical practitioners enter the field. By adhering to due process, maintaining thorough documentation, and fostering a supportive yet accountable learning environment, educators fulfill their ethical obligation to uphold the profession’s standards. While remediation and  intervention may be emotionally and professionally challenging, it is an essential component of gatekeeping. When conducted ethically, it reflects a commitment to the counseling profession and the broader societal trust placed in its practitioners.

Vicarious Liability

Supervisors hold legal and ethical responsibility for the actions of their supervisees, a concept known as vicarious liability. If a supervisee violates professional or ethical standards—such as engaging in a dual relationship despite warnings—the supervisor could be held accountable for failing to intervene appropriately (Remley & Herlihy, 2016). This underscores the need for supervisors to actively monitor, address, and document competence problems to protect clients, the supervisee, and their professional standing.

Structured Remediation Plans

To address competence issues effectively, supervisors must implement structured remediation plans that outline clear expectations, timelines, and criteria for success (McAdams et al., 2007).

These plans should include:

• Targeted steps to address identified deficiencies (i.e., re-taking an ethics course or participating in intensified supervision sessions).
• Clear indicators of improved performance, such as mastery of ethical principles or demonstration of appropriate boundaries.
• Collaboration with faculty, clinical supervisors, and institutional leadership to ensure a transparent and supportive process.
• Comprehensive records of the plan and agreements signed by all parties to demonstrate due process.

In cases where the supervisee fails to meet the goals outlined in the remediation plan, supervisors must be confident that they have acted ethically and legally in recommending dismissal.

Preparing for Difficult Conversations

Addressing performance concerns often involves difficult conversations. Jacobs et al. (2011) emphasize the importance of preparation, which includes:

• Empathy: Understanding the counselor’s perspective while maintaining professional standards.
• Mentorship: Seeking guidance and support from colleagues with experience in gatekeeping.
• Proactive Communication: Anticipating and addressing potential resistance or resentment from counselors.

Self-Protection

Supervisors must also consider self-protection as they navigate gatekeeping and remediation. Preparation for challenging conversations, mentorship from experienced professionals, and thorough documentation of the remediation process are essential for safeguarding against potential legal or professional consequences (Jacobs et al., 2011). Supervisors should engage in reflective practice and seek support to mitigate the emotional and professional toll that difficult decisions may entail.

Final Steps in the Remediation Process

Once the remediation plan is completed, supervisors should convene all stakeholders to review the supervisee’s progress. If the supervisee demonstrates significant improvement and can engage ethically and competently in practice, they can continue their professional development. However, if progress remains insufficient, supervisors must recommend dismissal, confident that all appropriate steps were taken to address the supervisee’s deficiencies.