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I have referenced my 2019 Church and Clergy Tax Guide and it may provide the answers you seek. There is just too much for me to write here but my browsing inclines me to believer that, without a relationship to a church and/or performing sacerdotal functions, he is not permitted an excludable housing allowance. In the section titled Counselors, all examples were as employees. Only one was allowed a housing allowance exclusion as he was employed by a nonprofit religious organization not associated with a particular church but spent a majority of his time 'in performing service in the conduct of religious worship or the ministration of sacerdotal functions, such service in the exercise of his ministry...' The other two examples of counselors, both employees (nonprofit pastoral counseling center and organization the promoted recovery through spiritual ministration and counseling) provided indicated that only about 5% of the 'taxpayer's working hours are spent performing duties such as the conduct of religious worship or the performance of sacerdotal functions...' IRS rejected excludable housing allowances for the latter two. I don't know if this helps or totally confuses you. I would not attempt to justify a housing exclusion given your description. I also suggest that you reread the Exempt earnings portion of the instructions for Form 4361. If this counselor is not performing sacerdotal functions and is filing Sch. C, he may well be subject to SE tax. You might want to contact, for example, churchlawandtax.com and maybe get a copy of this tax guide or other similar organizations. If you expect to have clergy clients of any type, I suggest good resources to be educated and support your decisions. Good luck!