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In a 2- to 3-page paper:  

Provide a brief description of one ethical decision-making model.
Discuss the steps in the model.
Explain one strength and one limitation of the model.
Explain any insights you gained about ethical decision-making from reviewing the model.
Justify your response with specific references to this week’s Learning Resources and the current      literature (These resources are attached.)

Support your Application Assignment with specific references to all resources used in its preparation. This assignment should be completed using APA formatting.
Module 3 Application Assignment: Ethical Decision Making Models

In a 2- to 3-page paper:  
· Provide a brief description of one ethical decision-making model.
· Discuss the steps in the model.
· Explain one strength and one limitation of the model.
· Explain any insights you gained about ethical decision-making from reviewing the model.
· Justify your response with specific references to this week’s Learning Resources and the current literature (These resources are attached.)

Support your Application Assignment with specific references to all resources used in its preparation. This assignment should be completed using APA formatting. 

A Practitioner’s Guide to Ethical Decision Making
Holly Forester-Miller, Ph.D.
Thomas Davis, Ph.D.

Copyright © 1996, American Counseling Association. A free publication of the
American Counseling Association promoting ethical counseling practice in service to the
public. — Printed and bound copies may be purchased in quantity for a nominal fee from
the Online Resource Catalog or by calling the ACA Distribution Center at 800.422.2648.

ACA grants reproduction rights to libraries, researchers and teachers who wish to copy
all or part of the contents of this document for scholarly purposes provided that no fee for
the use or possession of such copies is charged to the ultimate consumer of the copies.
Proper citation to ACA must be given.

Introduction
Counselors are often faced with situations which require sound ethical decision making
ability. Determining the appropriate course to take when faced with a difficult ethical
dilemma can be a challenge. To assist ACA members in meeting this challenge, the ACA
Ethics Committee has developed A Practitioner’s Guide to Ethical Decision Making. The
intent of this document is to offer professional counselors a framework for sound ethical
decision making. The following will address both guiding principles that are globally
valuable in ethical decision making, and a model that professionals can utilize as they
address ethical questions in their work.

Moral Principles
Kitchener (1984) has identified five moral principles that are viewed as the cornerstone
of our ethical guidelines. Ethical guidelines can not address all situations that a counselor
is forced to confront. Reviewing these ethical principles which are at the foundation of
the guidelines often helps to clarify the issues involved in a given situation. The five
principles, autonomy, justice, beneficence, nonmaleficence, and fidelity are each absolute
truths in and of themselves. By exploring the dilemma in regards to these principles one
may come to a better understanding of the conflicting issues.

1. Autonomy is the principle that addresses the concept of independence. The
essence of this principle is allowing an individual the freedom of choice and
action. It addresses the responsibility of the counselor to encourage clients, when
appropriate, to make their own decisions and to act on their own values. There are
two important considerations in encouraging clients to be autonomous. First,
helping the client to understand how their decisions and their values may or may
not be received within the context of the society in which they live, and how they
may impinge on the rights of others. The second consideration is related to the
client’s ability to make sound and rational decisions. Persons not capable of
making competent choices, such as children, and some individuals with mental
handicaps, should not be allowed to act on decisions that could harm themselves
or others.

2. Nonmaleficence is the concept of not causing harm to others. Often explained as
“above all do no harm”, this principle is considered by some to be the most
critical of all the principles, even though theoretically they are all of equal weight
(Kitchener, 1984; Rosenbaum, 1982; Stadler, 1986). This principle reflects both
the idea of not inflicting intentional harm, and not engaging in actions that risk
harming others (Forester-Miller & Rubenstein, 1992).

3. Beneficence reflects the counselor’s responsibility to contribute to the welfare of
the client. Simply stated it means to do good, to be proactive and also to prevent
harm when possible (Forester-Miller & Rubenstein, 1992).

4. Justice does not mean treating all individuals the same. Kitchener (1984) points
out that the formal meaning of justice is “treating equals equally and unequals
unequally but in proportion to their relevant differences” (p.49). If an individual is
to be treated differently, the counselor needs to be able to offer a rationale that
explains the necessity and appropriateness of treating this individual differently.

5. Fidelity involves the notions of loyalty, faithfulness, and honoring commitments.
Clients must be able to trust the counselor and have faith in the therapeutic
relationship if growth is to occur. Therefore, the counselor must take care not to
threaten the therapeutic relationship nor to leave obligations unfulfilled.

When exploring an ethical dilemma, you need to examine the situation and see how each
of the above principles may relate to that particular case. At times this alone will clarify
the issues enough that the means for resolving the dilemma will become obvious to you.
In more complicated cases it is helpful to be able to work through the steps of an ethical
decision making model, and to assess which of these moral principles may be in conflict.

Ethical Decision Making Model
We have incorporated the work of Van Hoose and Paradise (1979), Kitchener (1984),
Stadler (1986), Haas and Malouf (1989), Forester-Miller and Rubenstein (1992), and
Sileo and Kopala (1993) into a practical, sequential, seven step, ethical decision making
model. A description and discussion of the steps follows.

1. Identify the Problem.
Gather as much information as you can that will illuminate the situation. In doing
so, it is important to be as specific and objective as possible. Writing ideas on
paper may help you gain clarity. Outline the facts, separating out innuendos,
assumptions, hypotheses, or suspicions. There are several questions you can ask
yourself: Is it an ethical, legal, professional, or clinical problem? Is it a
combination of more than one of these? If a legal question exists, seek legal
advice.

Other questions that it may be useful to ask yourself are: Is the issue related to me
and what I am or am not doing? Is it related to a client and/or the client’s
significant others and what they are or are not doing? Is it related to the institution
or agency and their policies and procedures? If the problem can be resolved by
implementing a policy of an institution or agency, you can look to the agency’s
guidelines. It is good to remember that dilemmas you face are often complex, so a

useful guideline is to examine the problem from several perspectives and avoid
searching for a simplistic solution.

2. Apply the ACA Code of Ethics.
After you have clarified the problem, refer to the Code of Ethics (ACA, 2005) to
see if the issue is addressed there. If there is an applicable standard or several
standards and they are specific and clear, following the course of action indicated
should lead to a resolution of the problem. To be able to apply the ethical
standards, it is essential that you have read them carefully and that you understand
their implications.

If the problem is more complex and a resolution does not seem apparent, then you
probably have a true ethical dilemma and need to proceed with further steps in the
ethical decision making process.

3. Determine the nature and dimensions of the dilemma.
There are several avenues to follow in order to ensure that you have examined the
problem in all its various dimensions.

o Consider the moral principles of autonomy, nonmaleficence, beneficence,
justice, and fidelity. Decide which principles apply to the specific
situation, and determine which principle takes priority for you in this case.
In theory, each principle is of equal value, which means that it is your
challenge to determine the priorities when two or more of them are in
conflict.

o Review the relevant professional literature to ensure that you are using the
most current professional thinking in reaching a decision.

o Consult with experienced professional colleagues and/or supervisors. As
they review with you the information you have gathered, they may see
other issues that are relevant or provide a perspective you have not
considered. They may also be able to identify aspects of the dilemma that
you are not viewing objectively.

o Consult your state or national professional associations to see if they can
provide help with the dilemma.

4. Generate potential courses of action.
Brainstorm as many possible courses of action as possible. Be creative and
consider all options. If possible, enlist the assistance of at least one colleague to
help you generate options.

5. Consider the potential consequences of all options and determine a course of
action.
Considering the information you have gathered and the priorities you have set,
evaluate each option and assess the potential consequences for all the parties
involved. Ponder the implications of each course of action for the client, for
others who will be effected, and for yourself as a counselor. Eliminate the options
that clearly do not give the desired results or cause even more problematic
consequences. Review the remaining options to determine which option or

combination of options best fits the situation and addresses the priorities you have
identified.

6. Evaluate the selected course of action.
Review the selected course of action to see if it presents any new ethical
considerations. Stadler (1986) suggests applying three simple tests to the selected
course of action to ensure that it is appropriate. In applying the test of justice,
assess your own sense of fairness by determining whether you would treat others
the same in this situation. For the test of publicity, ask yourself whether you
would want your behavior reported in the press. The test of universality asks you
to assess whether you could recommend the same course of action to another
counselor in the same situation.

If the course of action you have selected seems to present new ethical issues, then
you’ll need to go back to the beginning and reevaluate each step of the process.
Perhaps you have chosen the wrong option or you might have identified the
problem incorrectly.

If you can answer in the affirmative to each of the questions suggested by Stadler
(thus passing the tests of justice, publicity, and universality) and you are satisfied
that you have selected an appropriate course of action, then you are ready to move
on to implementation.

7. Implement the course of action.
Taking the appropriate action in an ethical dilemma is often difficult. The final
step involves strengthening your ego to allow you to carry out your plan. After
implementing your course of action, it is good practice to follow up on the
situation to assess whether your actions had the anticipated effect and
consequences.

The Ethical Decision Making Model at a Glance

1. Identify the problem.
2. Apply the ACA Code of Ethics.
3. Determine the nature and dimensions of the dilemma.
4. Generate potential courses of action.
5. Consider the potential consequences of all options, choose a course of action.
6. Evaluate the selected course of action.
7. Implement the course of action.

It is important to realize that different professionals may implement different courses of
action in the same situation. There is rarely one right answer to a complex ethical
dilemma. However, if you follow a systematic model, you can be assured that you will be
able to give a professional explanation for the course of action you chose. Van Hoose and
Paradise (1979) suggest that a counselor “is probably acting in an ethically responsible
way concerning a client if (1) he or she has maintained personal and professional
honesty, coupled with (2) the best interests of the client, (3) without malice or personal

gain, and (4) can justify his or her actions as the best judgment of what should be done
based upon the current state of the profession” (p.58). Following this model will help to
ensure that all four of these conditions have been met.

References

American Counseling Association (2005). Code of Ethics. Alexandria, VA: Author.

Forester-Miller, H. & Rubenstein, R.L. (1992). Group Counseling: Ethics and
Professional Issues. In D. Capuzzi & D. R. Gross (Eds.) Introduction to Group
Counseling (307-323). Denver, CO: Love Publishing Co.

Haas, L.J. & Malouf, J.L. (1989). Keeping up the good work: A practitioner’s guide to
mental health ethics. Sarasota, FL: Professional Resource Exchange, Inc.

Kitchener, K. S. (1984). Intuition, critical evaluation and ethical principles: The
foundation for ethical decisions in counseling psychology. Counseling Psychologist,
12(3), 43-55.

Rosenbaum, M. (1982). Ethical problems of Group Psychotherapy. In M. Rosenbaum
(Ed.), Ethics and values in psychotherapy: A guidebook (237-257). New York: Free
Press.

Sileo, F. & Kopala, M. (1993). An A-B-C-D-E worksheet for promoting beneficence
when considering ethical issues. Counseling and Values, 37, 89-95.

Stadler, H. A. (1986). Making hard choices: Clarifying controversial ethical issues.
Counseling & Human Development, 19, 1-10.

Van Hoose, W.H. (1980). Ethics and counseling. Counseling & Human Development,
13(1), 1-12.

Van Hoose, W.H. & Paradise, L.V. (1979). Ethics in counseling and psychotherapy:
Perspectives in issues and decision-making. Cranston, RI: Carroll Press.

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R. Rocco Cottone is a professor in the Division of Counseling at the University of Missouri–St. Louis. Ronald E. Claus is a doctoral student in the Counseling
Program at the University of Missouri–St. Louis and is a senior research specialist with the Missouri Institute of Mental Health in St. Louis. The authors thank
Patricia McCallister for her help on earlier drafts of this article. Correspondence regarding this article should be sent to R. Rocco Cottone at the University of
Missouri–St. Louis, Division of Counseling (469 MH), 8001 Natural Bridge Road, St. Louis, MO 63121-4499 (e-mail: [email protected]).

Ethical Decision-Making Models: A Review
of the Literature

R. Rocco Cottone and Ronald E. Claus

A comprehensive review of the literature on ethical decision-making models in counseling is presented, beginning in the fall of
1984 through the summer of 1998. (Materials “in press” were considered.) A general overview of the literature is provided.
Theoretically or philosophically based, practice-based, and specialty-relevant approaches are surveyed. The literature is rich with
publications describing decision-making models, although few models have been assessed empirically, and few models seem
well grounded philosophically or theoretically.

I
n 1984, Kitchener published a seminal work related
to ethical decision making in counseling and counsel-
ing psychology. In her article, Kitchener argued that
in the absence of clear ethical guidelines, relying on
personal value judgments (as some other authors had

proposed) was not adequate because “[i]ndependent of . . .
external considerations, not all value judgments are equally
valid” (p. 44). Kitchener argued that counseling professionals
should “develop a deeper understanding of the basis for ethi-
cal decision making” (p. 44). She then presented a model inte-
grating Hare’s (1981) work on levels of moral thinking (intui-
tive and critical-evaluative) and Beauchamp and Childress’s
(1979) suggested ethical “principles” (autonomy, beneficence,
nonmaleficence, and justice) and the ethical “rule” of fidelity.
Since Kitchener’s 1984 publication, there have been many
publications on ethical issues in counseling. However, to this
date, no formal review of the literature on ethical decision-
making models has been published. There has been no ac-
counting of philosophical, theoretical, practical, or empirical
developments related to ethical decision-making models in
counseling. This article offers such an accounting.

The literature on ethical decision-making models from the
fall of 1984 (the date of Kitchener’s publication) to the sum-
mer of 1998 was systematically reviewed. (“In press” mate-
rials available to the authors were included.) Computer
searches of PsychLit and ERIC were accomplished using
the key terms “ethical/decision making/model”; also com-
plete hand searches of the following journals were made
between those dates: the Journal of Counseling & Develop-
ment, The Counseling Psychologist, Professional Psychology:
Research and Practice, and the American Psychologist. Other
sources known to us were also included. Although an over-
view of the literature on ethical issues is included in this

review, the intent and focus of the review is to address and
to thoroughly review the literature specifically relating to
ethical decision-making models. Therefore, literature ad-
dressing moral reasoning, clinical issues, and specific code-
directed actions is not fully reviewed.

GENERAL OVERVIEW OF THE LITERATURE ON ETHICAL ISSUES

Since Kitchener’s (1984) article was published, Beauchamp
and Childress’s (1979) Principles of Biomedical Ethics has
been revised several times; it is a frequently cited work in
its fourth edition (Beauchamp & Childress, 1994) that has
laid the groundwork for other authors. Although the
Beauchamp and Childress (1994) text is a foundation text
providing guiding principles for ethical decision making, it
fails to address decision-making models or processes in
depth. Instead, the authors provided a thorough analysis of
ethical theory, including criteria of theory construction and
an overview of widely recognized ethical theories (e.g., utili-
tarianism, Kantianism, liberal individualism). In a work
published in the same year, Beauchamp and Walters (1994)
provided a “set of considerations” or “methods” for resolv-
ing moral disagreements as a way “of easing and perhaps
settling controversies” (p. 4). The methods included (a) “ob-
taining objective information”; (b) “providing definitional
clarity”; (c) “adopting a code”; (d) “using examples and
counterexamples”; and (e) “analyzing arguments” (pp. 4–
7). Beauchamp and Walters did not present a review of
decision-making processes, but they took a position and
presented a basic model for judging ethical decisions. As
with the Beauchamp and Childress (1994) and the Beauchamp
and Walters works, there was a lack of in-depth discussion
of ethical decision-making processes in the literature. Rather,

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authors simply listed the act of making a decision as a step, or
they did not list it as a step at all; however, in either case, an
explanatory framework for the decision process itself was not
addressed. There were some exceptions, especially involving
theoretical and philosophical foundations.

THEORETICAL OR PHILOSOPHICALLY BASED MODELS OF ETHICAL
DECISION MAKING

Several authors made an attempt to ground ethical decision
making on some theory or philosophy. Notably, Hare’s
(1991) “The Philosophical Basis of Psychiatric Ethics,” which
in its original 1981 form was used by Kitchener as a guiding
work, argued that absolute thinking (dealing with rights and
duties) and utilitarian thinking (doing the greatest good for
the greatest number; considering the interests of patients)
were both involved in ethical decision making. Hare then
invoked two levels of moral reasoning to address ethical di-
lemmas—the “intuitive” and “critical” levels. Hare (1991) said

[t]hat we have a duty to serve the interests of the patient, and that
we have a duty to respect his rights, can both perhaps be ascer-
tained by consulting our intuitions at the bottom level. But if we
ask which duty or which intuition ought to carry the day, we need
some means other than intuition, some higher kind of thinking (let
us call it “critical moral thinking”) to settle the question between
them. (p. 35)

Although Hare (1991) believed that the “intuitive level,
with its prima facie duties and principles, is the main locus
of everyday moral decisions” (p. 35), he argued that it is
“not sufficient” (p. 36) and must be superceded by critical
(utilitarian) thinking when “no appeal to intuitions” can
“settle the dispute” (p. 38). Although Hare’s work was ap-
plied to psychiatry, it has direct relevance to counseling in
that many have followed the lead of Kitchener and incor-
porated his ideas in their works.

Rest (1984) produced another work that is frequently
cited in the literature. Rest has published extensively on
the topic of developmental issues related to moral reason-
ing (e.g., Rest, Cooper, Coder, Maganz, & Anderson, 1974;
Rest, Davison, & Robbins, 1978). Rest’s (1984) work, writ-
ten specifically for the applied ethics of psychology, drew
heavily on theories of moral development (e.g., Kohlberg,
1969, 1980) and research findings (e.g., Schwartz, 1977) to
present a four-component model of “processes involved in
the production of moral behavior” (p. 19). The components
are (a) “To interpret the situation in terms of how one’s
actions affect the welfare of others”; (b) “To formulate what
a moral course of action would be; to identify the moral
ideal in a specific situation”; (c) “To select among compet-
ing value outcomes of ideals, the one to act upon; deciding
whether or not to try to fulfill one’s moral ideal”; (d) “To
execute and implement what one intends to do” (Rest, 1984,
p. 20). The four components are not temporally linear, and
they are not virtues or traits of individuals. Rather, “they
are major units of analysis in tracing out how a particular
course of action was produced in the context of a particu-

lar situation” (p. 20). Rest (1984) argued that “The four
component model provides a framework for ordering ex-
isting research on moral development, identifying needed
research and deriving implications for moral education.
There are many directives for the moral education of coun-
selors that come from this research” (p. 27). For instance,
he believed an assessment instrument could be developed
for each component in order to assess counseling students
entering training or the outcomes of training programs them-
selves. In a later work, Rest (1994) reviewed the works of
Kohlberg and gave an up-to-date summary of research find-
ings related to Kohlberg’s theory. He also offered a revised
version of the four-component model. Rest (1994) defined
the four components as “the major determinants of moral
behavior” (p. 22), and he summarized the components as
(a) “Moral Sensitivity”; (b) “Moral Judgment”; (c) “Moral
Motivation”; and (d) “Moral Character” (pp. 23–24). Rest
(1994) stated the following:

In summary, moral failure can occur because of deficiency in any
component. All four components are determinants of moral action.
In fact, there are complex interactions among the four components,
and it is not supposed that the four represent a temporal order
such that a person performs one, then two, then three, then four—
rather the four components comprise a logical analysis of what it
takes to behave morally. (p. 24)

Rest’s (1994) model is clearly theoretically linked to cogni-
tive theory through the works of Kohlberg, and he has one
of the most empirically grounded approaches to analyzing
moral behavior.

Gutheil, Bursztajn, Brodsky, and Alexander (1991), in a
text on decision making in psychiatry and law, provided a
chapter titled “Probability, Decision Analysis, and Conscious
Gambling.” The chapter reviewed the mechanistic and
probabilistic paradigms in science and took a stand that
decision making must account for some level of uncertainty
(probability). Gutheil et al. argued in favor of “decision
analysis” as a formal decision-making tool:

Decision analysis is a step-by-step procedure enabling us to break
down a decision into its components, to lay them out in an orderly
fashion, and to trace the sequence of events that might follow from
choosing one course of action or another. This procedure offers
several benefits. It can help us to make the best possible decision in
a given situation. Moreover, it can help us to clarify our values, that
is, the preferences among possible outcomes by which we judge
what the best decision might be. Decision analysis can also be used
to build logic and rationality into our intuitive decision making—
to educate our intuition about probabilities and about the paths of
contingency by which our actions, in combination with chance or
“outside” events, lead to outcomes. (p. 41)

Decision analysis involves several “approaches,” including
(a) acknowledging the decision, (b) listing the pros and cons,
(c) structuring the decision (including development of a
decision “tree” to graph decisional paths and subsequent
decisional branches, (d) estimating probabilities and values,
and (e) calculating expected value. Estimating probabilities
by means of a decision tree may involve calculating “the

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relative frequency with which the event in question occurs
over a large number of trials in similar circumstances”
(Gutheil et al., 1991, p. 46). The authors contrast the pro-
cedure of decision analysis with the notion that the process
of decision making is otherwise little more than gambling,
with actions ruled by chance or outside events. Their model
is clearly linked to nonmechanistic probability theory in
science (e.g., the uncertainty principle).

Two articles integrated Berne’s (1972) transactional analy-
sis therapeutic approach with ethical decision-making pro-
cesses. For example, Chang (1994) identified a five-step
model of making an ethical decision and emphasized three
core values implicit in transactional analysis that affect the
decision-making process: (a) the principle that people are
born acceptable or “OK,” (b) clients are capable of under-
standing their problems and are actively involved in heal-
ing, and (c) people can take charge of their lives. She ad-
dressed the interplay of transactional analysis values and
other ethical standards or directives. McGrath (1994) be-
lieved that Kitchener’s (1988) discussion of roles was rel-
evant to transactional analysis, because it was common to
view transactional analysis supervisors also as therapists. Ac-
cordingly, role theory would have direct relevance to indi-
vidual transactional analysis therapists making decisions.

Based on a theory of feminism, a model for ethical decision
making was proposed by Hill, Glaser, and Harden (1995). They
valued the emotional responses of the counselor and the so-
cial context in which the therapeutic relationship takes place.
In accord with feminist beliefs regarding power, the client is
engaged as fully as possible in the decision-making process. At
each step, the feminist model included a rational-evaluative
procedure with corresponding emotional and intuitive que-
ries to assist the counselor. This model included a review pro-
cess in which the counselor considers the impact of personal
values, the universality of the proposed solution, and the in-
tuitive feel of the proposed solution. Because personal char-
acteristics affect ethical decisions, the authors believed that
integration of this factor into their model improves the de-
cision-making process.

Betan (1997) proposed a hermeneutic perspective to ethi-
cal decision making. Betan stated that “hermeneutics repre-
sents a shift in views of the nature of knowledge and the pro-
cess of how we come to know” since “knowledge is situated in
the context of human relationships in which the interpreter
(as knowledge is interpretation) participates in narrating mean-
ing” (p. 352). He advocated that hermeneutics adds to rather
than replaces the principled approaches of Kitchener (1984)
and Rest (1984): “The context of the therapeutic relationship
and the clinician’s psychological needs and dynamics are fun-
damental considerations in the interpretation and application
of ethical principles” (p. 356). Furthermore, Betan stated

A linear, logical-reductionistic approach to ethics, such as that of-
fered by Kitchener (1984) and Rest (1984), can lead to a false di-
chotomy between the rational and the intuitive, and the universal
and the subjective. The key in this hermeneutic approach is to ac-
knowledge the dialectic of the universal and the subjective of hu-
man relations, in which each informs the other. That is, our sense of

what is universal (in this regard, a standard or principle) is a prod-
uct of shared subjective experiences, which in turn are embedded
in a context of cultural interpretation. (p. 356)

The prima facie obligation of ethical principles asserted by
Kitchener must instead, according to Betan, be applied in
the context of personal and cultural values. That an ethical
truth is constructed in the framework of one’s conception
of self, others, and the world holds implications for counse-
lor training; counselors must work to gain awareness of ethi-
cal dilemmas, their own personal and moral values, and the
interaction between ethical principles and context.

Cottone (in press) took an even more radical relational po-
sition than did Betan (1997). Cottone proposed an ethical
decision-making approach based on social constructivism. He
argued that decision making is not a psychological process.
Rather, decision making is a social process always involving
interaction with other individuals. Building on the works of
Gergen (1985) in social psychology and the works of Maturana
(Maturana, 1978, 1988; Maturana & Varela, 1980) in the biol-
ogy of cognition, Cottone argued that ethical decisions “are
not compelled internally; rather, they are socially compelled.”
Furthermore, he asserted that ethical decision making occurs
in the interactive processes of negotiating, consensualizing, and
arbitrating. An individual’s psychological process is not in-
volved. The social constructivism perspective of ethical deci-
sion making takes the decision out of the “head,” so to speak,
and places it in the interactive process between people.

EMPIRICAL FINDINGS RELATED TO A THEORETICAL OR
PHILOSOPHICALLY BASED MODEL

Two empirical studies in the published literature had di-
rect theoretical linkage. Cottone, Tarvydas, and House
(1994) derived hypotheses about how counseling graduate
students make decisions based on social systems theory.
According to social systems theory, they posited that “all
thinking and decision making would be highly socially and
relationally influenced, and both number and types of rela-
tionships would potentially influence how individuals act
and think” (p. 57). Cottone et al. concluded the following:

The results indicate that interpersonal relations influenced the ethi-
cal decision making of graduate counseling student participants
when they were asked to reconsider a decision. In other words,
relationships seem to influence ethical decision making linearly and
cumulatively. Additionally, there seems to be an interaction be-
tween the number and type of consulted relationships in a way
that eludes simple explanation. Although there was only a small
interaction effect size, the results support a conclusion that ethical
decision making in a reconsideration circumstance is a relatively
complex issue, with at least the number and type of relationships
interacting. (p. 63)

The results supported a conclusion of social influence over
ethical choice. The second study was a test of Janis and Mann’s
(1977) theory of decision making under stress by Hinkeldey
and Spokane (1985). Hinkeldey and Spokane concluded that
“consistent with Janis and Mann’s theory, results showed

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that decision making was affected negatively by pressure
but that participants relied little on legal guidelines in making
responses to ethical conflict dilemmas” (p. 240).

Dinger (1997) presented dissertation findings on a study
that compared the Ethical Justification model of Kitchener
(1984) to the A-B-C-D-E worksheet model of Sileo and
Kopala (1993) and concluded that the Kitchener model
better served participants in identifying the ethical issues
presented in different scenarios. (The Dinger work is dis-
cussed in more detail at the conclusion of this article.)

PRACTICE-BASED MODELS OF ETHICAL DECISION MAKING

Some authors have proposed models based on pragmatic pro-
cedures derived largely from experience or intended prima-
rily as practical guides for counselors. These models tend to be
less theory specific or philosophically pure than those dis-
cussed in the prior sections of this article. Table 1 provides a
summary of steps or stages of decision-making models that
are discussed in this section. Table 1 is organized to reflect
similarities of the models; it does not present a one-to-one or
step-by-step correspondence for every step listed in a row.

Keith-Spiegel and Koocher (1985) pointed out that ethi-
cal decision-making models do not make ethical decisions,
but describe a process for examining a situation. Decisions
made in crisis situations may involve alternate strategies
and criteria. Their process (see Table 1) drew from the work
of Tymchuk (1981). Values, personal characteristics, clini-
cal orientation, ethical training received, and years of expe-
rience are understood to affect the choice of action made
by a counselor. Careful implementation and monitoring of
all actions taken to address the ethical dilemma is favored.

Stadler (1986) presented an ethical decision-making model
(see Table 1) that embraced moral principles as the basis for
action (Kitchener, 1984; Rest, 1984). She believed that the
counselor’s moral beliefs influence the actions taken in re-
sponse to an ethical dilemma, and she viewed the counselor
as a moral agent with special responsibilities to the client. Stress-
ing the principles of autonomy and beneficence, Stadler stated
that counselors should “conscientiously endeavor” to reduce
the impact of their values on their clients by “clarifying” their
own value expectations and “by allowing clients to consider
their own values and freely chosen goals” (p. 3). She encour-
aged counselors to examine “competing nonmoral values”
(p. 8), factors such as potential financial benefits or transfer-
ence issues, that may potentially interfere with ethical re-
sponsibilities. Stadler proposed an ethical test, evaluating the
universality, publicity, and justice of the proposed course of
action. Stadler served as chair of the American Counseling
Association (ACA) Ethics Committee.

Tymchuk (1986) stressed that the goal of ethical deci-
sion making should be one of justice. In addition to laws,
regulations, ethical codes and practical experience, Tymchuk
encouraged reliance on utilitarianism as a guide to decision
making. He called for research-based ethical guidelines and
challenged counselors to go beyond reacting to emerging
ethical issues to anticipate future trends. The Canadian Psy-

chological Association code of ethics incorporates the steps
presented in his model, which are listed in Table 1.

Sileo and Kopala (1993) developed a worksheet to simplify
the counselor’s consideration of ethical issues. With a primary
goal of promoting beneficence, their “A-B-C-D-E” method is
simple and easy to remember: assessment (A), benefit (B),
consequences and consultation (C), duty (D), and education
(E). The components incorporate the moral standards of au-
tonomy, beneficence, nonmaleficence, fidelity, and justice. The
worksheet allows a counselor to systematically join personal
character, virtue, and sound thinking to ensure the best re-
sponse to an ethical dilemma.

Forester-Miller and Davis (1996), also as members of the
ACA Ethics Committee, offered a straightforward model.
They referred to the moral principles of autonomy, justice,
beneficence, nonmaleficence, and fidelity as the touchstones
of the model and as helpful for clarifying the ethical di-
lemma at hand. In Forester-Miller and Davis’s seven-step
method (Table 1), the counselor uses Stadler’s (1986) three-
question test to determine the appropriateness of a course
of action: (a) Is the action fair? (b) Would the counselor
recommend it to a peer? and (c) Would the counselor want
his or her behavior made public?

In developing her “Integrative Decision-Making Model of
Ethical Behavior,” Tarvydas (1998) drew on the work of Rest
(1984), Kitchener (1984), and Tarvydas and Cottone (1991).
The model was designed to illuminate the thinking, feeling,
and contextual aspects of the psychological process of ethical
decision making. Kitchener’s (1984) intuitive and critical-
evaluative levels of thinking provided the lynchpin for this
model’s selection of the best course of action. Tarvydas de-
scribed stages (Table 1) with detailed components that guide
the counselor through each stage. Notably, Tarvydas stressed
the importance of the decision-maker’s self-awareness, atten-
tion to context, and collaboration with all stakeholders.

Steinman, Richardson, and McEnroe (1998) wrote a manual
for helping professionals that proposed and applied an ethical
decision-making model to areas such as confidentiality, client
welfare and client relationships, supervision, research, teach-
ing, and consulting. They sensitized the reader to four ethical
traps, or most common reasons for ethical violations, as part of
learning to identify dilemmas. Furthermore, they established
an ethical hierarchy by ranking the potential beneficiaries of
ethical decisions when interests are in conflict. Nonmaleficence
is considered by many ethicists (cf. Kitchener, 1984) to be the
strongest ethical obligation. However, Steinman et al. believed
that the interests of counselors, then society, then the client
should be considered when making ethical choices. This model
(Table 1) directed the counselor to prepare an ethical resolu-
tion that details the dilemma, the action suggested by relevant
ethical codes and laws, the outcome of consultation about the
dilemma, and the proposed action and perceived consequences
of this action, then to review the resolution with peers and
supervisor.

Welfel (1998) presented a model (Table 1) based on the
two-level decision-making model proposed by Kitchener
(1984). She emphasized that analysis of a dilemma must

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be rooted in a commitment to the virtues of professional
values. According to this system, the counselor gathers in-
formation and consults with others regarding the dilemma
but must deliberate alone before making an informed deci-
sion. Welfel pointed out that counselor preparation through
familiarity with ethical codes and practical experience can
shorten the decision-making process.

Corey, Corey, and Callanan (1998) noted that because ethi-
cal codes cannot be applied in a rote manner, practitioners are
more likely to respond to a dilemma based on their personal
values and practical considerations. They review two decision-

making models in depth—the virtue ethics of Jordan and Meara
(1990) and the critical-evaluation model of Kitchener (1984)—
and stressed the four fundamental principles of autonomy,
beneficence, nonmaleficence, and justice. Corey et al. presented
a series of steps for ethical decision making (Table 1) that blends
practices from different models.

MODELS DEVELOPED FOR SPECIALTY PRACTICE

The literature contains examples of ethical decision-making
models applied to or developed for a specific area of counsel-

TABLE 1

Summary of Steps or Stages of Practice-Based Ethical Decision-Making Models

Corey, Corey,
& Callanan

(1998)
Forester-Miller
& Davis (1996)

Keith-Spiegel &
Koocher (1985)

Rae, Fournier,
& Roberts
(in press)

Stadler
(1986)

Steinman,
Richardson, &

McEnroe (1998)
Tarvydas

(1998)
Tymchuk

(1986)
Welfel
(1998)

1. Identify the
problem

2. Identify
potential issues
involved
3. Review
relevant ethical
guidelines

4. Obtain
consultation

5. Consider
possible and
probable
courses of
action
6. Enumerate
consequences
of various
decisions

7. Decide on
best course of
action

1. Identify the
problem

2. Apply the
ACA Code of
Ethics

3. Determine
nature of
dilemma

4. Generate
potential
courses of
action

5. Consider
potential
consequences,
determine
course of action

6. Evaluate
selected course
of action
7. Implement
course of action

1. Describe the
parameters

2. Define the
potential issues

3. Consult legal
and ethical
guidelines

4. Evaluate
the rights,
responsibilities,
and welfare of all
5. Generate
alternate
decisions

6. Enumerate the
consequences of
each decision

7. Estimate
probability for
outcomes of each
decision
8. Make the
decision

1. Identify
competing
principles
2. Secure
additional
information
3. Consult
with
colleagues

4. Identify
hoped-for
outcomes

5. Brainstorm
actions to
achieve
outcomes

6. Evaluate
effects of
actions

7. Identify
competing
nonmoral
values
8. Choose
a course of
action

9. Test the
course of
action
10. Identify
steps, take
action,
evaluate

1. Identify the
problem

2. Identify the
relevant ethical
standard

3.Determine
possible ethical
traps

4. Frame
preliminary
response

5. Consider
consequences
of that response

6. Prepare an
ethical resolution

7. Get feedback
from peers and
supervisor
8. Take action

1. Interpret
situation

2. Review
problem or
dilemma
3. Determine
standards that
apply to
dilemma

4. Generate
possible and
probable
courses of
action
5. Consider
consequences
for each
course of
action
6. Consult with
supervisor
and peers

7. Select an
action by
weighing
competing
values, given
context

8. Plan and
execute the
selected
action
9. Evaluate
course of
action

1. Determine
stakeholders

2. …

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