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Re: Opposition to SB 709 which would allow individuals licensed as a Licensed Specialist in School Psychology (LSSP) and who hold the NCSP (National Certified School Psychologist) credential to call themselves 'School Psychologists".
Dear Senate Health and Human Services Committee,
I am writing to express my very strong opposition to SB 709 that would allow individuals licensed as a Licensed Specialist in School Psychology (LSSP) and who hold the NCSP (National Certified School Psychologist) credential to call themselves School Psychologists". If adopted, Masters level specialists in school psychology would be able to use the term Psychologist in their title/signature block.
Psychologist is a protected title. "Psychologist is a title that infers a professional has been educated at the doctoral level. The purpose of the current Title Act is protection of the public. Protection of the public includes assurances of competence and also avoiding confusion when possible. When people seek out a Psychologist, just as when they seek out a Physician, they are seeking out a professional with an assumed level of education and competence. The protection of the title allows the public to rely on the title as an assurance of education and competence versus having to review the individual provider's resume and particular training. When vastly different levels of training and expertise are contained within the same title, the purpose of the "protected title" to aid the public with selection of professionals and also its assurance of a level of training and expertise is significantly diminished. In this specific instance, the education and training of a master's level professional and a doctoral level professional are very different. As an analogy, persons holding a masters degree in public health do not hold themselves out to be physicians and we see no reason why the title psychologist should be diluted. Indeed, we see no valuable function in someone with a masters degree as holding themselves out to be a psychologist, other than potentially misleading self-representation.
The title "School Psychologists" is defined in Texas law as someone who has a doctoral degree. The Licensed Specialist in School Psychology and National Certified School Psychologist do not require a doctoral degree. If passed, SB 709 would lead to confusion of the public. Your constituents would be lead to believe they were receiving services from someone with a certain level of training (doctoral level) when seeing a Psychologist, however, that would not always be the case. This could function to decrease the publics confidence in the legal system that allowed two conflicting laws and also decrease confidence in medical and psychological providers that over time could potential lead to individuals not seeking treatment when needed. When your constituents see a psychologist, they should be able to be confident that they are seeing a doctoral-level practitioner. A certificate is not equivalent to a doctoral degree.
In sum, different levels of training and expertise should be designated. Titles are protected for the benefit of the public. Allowing the term "Psychologist" to be utilized by non doctoral level practitioners will be misleading to the public and it will dilute the significance of the term. A change in the rule will lead to direct harm to your constituents.
We very much appreciate the role you are playing to ensure the protection of the public and avoidance of any misrepresentation of educational or skill attainment.
Sincerely,
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Re: Opposition to SB 709 which would allow individuals licensed as a Licensed Specialist in School Psychology (LSSP) and who hold the NCSP (National Certified School Psychologist) credential to call themselves 'School Psychologists".
Dear Senate Health and Human Services Committee,
I am writing to express my very strong opposition to SB 709 that would allow individuals licensed as a Licensed Specialist in School Psychology (LSSP) and who hold the NCSP (National Certified School Psychologist) credential to call themselves School Psychologists". If adopted, Masters level specialists in school psychology would be able to use the term Psychologist in their title/signature block.
Psychologist is a protected title. "Psychologist is a title that infers a professional has been educated at the doctoral level. The purpose of the current Title Act is protection of the public. Protection of the public includes assurances of competence and also avoiding confusion when possible. When people seek out a Psychologist, just as when they seek out a Physician, they are seeking out a professional with an assumed level of education and competence. The protection of the title allows the public to rely on the title as an assurance of education and competence versus having to review the individual provider's resume and particular training. When vastly different levels of training and expertise are contained within the same title, the purpose of the "protected title" to aid the public with selection of professionals and also its assurance of a level of training and expertise is significantly diminished. In this specific instance, the education and training of a master's level professional and a doctoral level professional are very different. As an analogy, persons holding a masters degree in public health do not hold themselves out to be physicians and we see no reason why the title psychologist should be diluted. Indeed, we see no valuable function in someone with a masters degree as holding themselves out to be a psychologist, other than potentially misleading self-representation.
The title "School Psychologists" is defined in Texas law as someone who has a doctoral degree. The Licensed Specialist in School Psychology and National Certified School Psychologist do not require a doctoral degree. If passed, SB 709 would lead to confusion of the public. Your constituents would be lead to believe they were receiving services from someone with a certain level of training (doctoral level) when seeing a Psychologist, however, that would not always be the case. This could function to decrease the publics confidence in the legal system that allowed two conflicting laws and also decrease confidence in medical and psychological providers that over time could potential lead to individuals not seeking treatment when needed. When your constituents see a psychologist, they should be able to be confident that they are seeing a doctoral-level practitioner. A certificate is not equivalent to a doctoral degree.
In sum, different levels of training and expertise should be designated. Titles are protected for the benefit of the public. Allowing the term "Psychologist" to be utilized by non doctoral level practitioners will be misleading to the public and it will dilute the significance of the term. A change in the rule will lead to direct harm to your constituents.
We very much appreciate the role you are playing to ensure the protection of the public and avoidance of any misrepresentation of educational or skill attainment.
Sincerely,
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