Santa Barbara’s Community Counseling and Engagement Center is a popular and well-respected training site for prelicensed therapists. And they’re doing something I’ve never heard of any community agency doing: They charge prospective volunteers just to apply to work there.
Their application lists a $35 application fee, due at the time of an initial interview. Applicants who are not interviewed are not charged the fee. There does not appear to be any process by which candidates in need could have the fee waived.
Can they do that?
As is the case with issues surrounding sites charging fees to trainees and associates, much depends on how these workplaces are classified. If they are “commercial enterprises,” then under California law, they have to pay their workers at least minimum wage, and cannot charge application or interview fees. But if they are not commercial entities, those same rules may not apply.
The simple fact that an agency is nonprofit actually doesn’t answer that question [paywalled]. Some nonprofits are commercial entities, and some are not. The fact that an agency is selling a health care service (therapy, in this case) for money — not a “suggested donation,” but an actual fee — would suggest commercial activity. On the other hand, the fact that the agency considers itself to be primarily a training program (and that they do offer meaningful training) suggests that it may not be a commercial entity. The question has to be tested through a complaint, or in court. And so until someone who has been impacted by the fee files such a complaint, the answer to “Can they do that?” is yes. No one in a position to stop them is taking the steps necessary to do so.
I emailed CCEC staff to inquire about the history of this fee, its unusual nature, and whether they had sought legal consult before instituting it. They responded to say that the fee has been in place since before the current leadership team was in place, and that they weren’t aware of the potential labor law issue. They emphasized that theirs is a training program, and not employment — I point that I think is arguable, particularly for associates. But it’s an argument they have every right to make. They also noted that the fee covers the costs of having licensed therapists conduct candidate evaluations.
Why $35 matters
You might wonder why a $35 fee is worth a post here. It’s truly not that much money. But it does send a message, especially when there’s no process to waive that fee: Poor people, regardless of skill level, need not apply. That’s the same message sent by training sites that charge you to work there, even as they collect fees for your services.
I made the case in Saving Psychotherapy that as it is currently structured, the barrier to entry as a mental health professional isn’t your skill set, it’s your wallet. Prospective therapists entering graduate school are often unaware of the significant financial burden they will be taking on after graduation, when their student loans will enter repayment but they will not be licensed yet, so they’ll still be toiling in low-pay or no-pay jobs.
I don’t think employers like CCEC, or those I noted previously that charge trainees to volunteer there, are bad places. They provide valuable and necessary services for their communities. I also don’t think that they’re run by bad people; CCEC responded quickly and openly when I asked about this, and that’s meaningful. I do, however, think that the business model used by CCEC and organizations like it involves exploiting one vulnerable population (prelicensed therapists) to serve another (clients who need low-fee services). I think that is morally wrong, even if the muddy legality were to be determined in the site’s favor.
Therapy is work. Workers deserve pay. Some prelicensed therapists are in a financial position where they can work for free for an organization whose mission they want to support, and that’s wonderful. Unfortunately, many prelicensed therapists wind up working for free not because they want to, but because they have to. Volunteering should be genuinely optional, not an act of desperation. And no one in this field should be charged a fee for applying to volunteer.