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Both do, in actuality. As for the professional organizations, that is also fraught with bias and protectionism. Look at the arguments about RxP. Or the fact that many psychiatrists practice therapy after training that most psychologists would laugh at. There is no set of absolute ethical guidelines in healthcare professions. They are all created and shaped by parties with vested interests, oftentimes with little to no actual empirical backing. Now, I am not arguing for the abolishment of ethical guidelines or laws associated with healthcare practice, just the acknowledgement that these are not commandments from up on high from an indisputable source, they are created by people, sometimes with the aim of protecting vested financial interests. E.g., the physician definition issue that the AMA goes and lies to Congress about on a regular basis.

You fleshed it out more than I did with this post, but it sounds like we're on the same page. There's no doubt that professional standards are set with little evidence or by parties with ulterior motives. Going back to the OP though, I would imagine that advertising as a Ph.D. when there's an active standard against it nationally, even if the state wouldn't care, would be unethical.

I took the national counseling exam for my LPC license and I recall a question on this very issue, with the correct answer being that a person advertising as a Ph.D. in something other than counselor education is violating the national ethics code. So, you can at least say at the very least the (1) the ACA thinks it's unethical and publishes its opinion in the standards and (2) every counselor with an LPC should theoretically know better as it is in the test preparation materials, regardless of what a state has to say on the matter.

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Going back to the original post, I don't think it'd fall under the psychology board unless the provider is specifically referring to themselves as a psychologist and/or is using phrases that would directly imply they're practicing psychology.

At the very least, it's misleading. I don't know if it's technically unethical per LPC guidelines, but based on what's been posted, it seems like it would be (since the doctorate is not in counseling).
 
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Going back to the original post, I don't think it'd fall under the psychology board unless the provider is specifically referring to themselves as a psychologist and/or is using phrases that would directly imply they're practicing psychology.

At the very least, it's misleading. I don't know if it's technically unethical per LPC guidelines, but based on what's been posted, it seems like it would be (since the doctorate is not in counseling).
I'll report it to sw board
 
Going back to the original post, I don't think it'd fall under the psychology board unless the provider is specifically referring to themselves as a psychologist and/or is using phrases that would directly imply they're practicing psychology.
It actually may fall under the psychology board, as it would be viewed as practicing (or at least giving a false appearance of practicing) doctoral level therapy (ie psychology) without a license. In my state, the board of psychology published the white paper prohibiting non-licensed psychologist from using a dr level credential in advertising
 
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I guess I was thinking that standards of practice set forth by professional organizations counted as evidence and whether individual jurisdictions chose to follow those guidelines is a completely different matter. Sure, we can both rightly criticize the evidence for the guidelines, but they do exist on the basis of evidence. I mean why have a two year postdoc for neuropsychology if you can bill neuropsychology codes in Ohio without meeting this criteria?
Someone may want to roll the dice, but I wouldn't because you open yourself up to liability and licensing boards tend to not be very understanding when someone is clearly practicing outside of their scope of practice.
 
It actually may fall under the psychology board, as it would be viewed as practicing (or at least giving a false appearance of practicing) doctoral level therapy (ie psychology) without a license. In my state, the board of psychology published the white paper prohibiting non-licensed psychologist from using a dr level credential in advertising

Very possible, and may depend on how some of the legislation (and the provider's marketing materials) are worded. I agree that if it gives the perception of the person attempting to "imitate" a psychologist or practice psychology, it very well could be under that board's purview.

Which brings me to another semi-related point folks mentioned previously--how to address DNPs with patients? Dr. XXX, while clarifying that they're an NP? Ms./Mr. XXX? NP XXX? Wondering how other people approach this.

As another aside that's also been mentioned, I'll typically refer to our clinical pharmacists as "Dr. XXX" with patients.
 
Which brings me to another semi-related point folks mentioned previously--how to address DNPs with patients? Dr. XXX, while clarifying that they're an NP? Ms./Mr. XXX? NP XXX? Wondering how other people approach this.

As another aside that's also been mentioned, I'll typically refer to our clinical pharmacists as "Dr. XXX" with patients.
I’m a clinical pharmacist in the hospital setting, and we refer to NPs as NP then first name with patients. Even the regular nurses are opposed to calling DNPs doctor.

For clinical pharmacists, you can just say the pharmacist then first name. “The pharmacist, Jamie, will be by to go over your meds.” It’s frowned upon in my profession for pharmacists to insist on being called doctor. They come across as a tool. Lol.

It’s confusing for patients when everyone wants to be called doctor in the hospital. A lot of times, they have altered mental status, dementia, or so many other health issues. They’re stressed. We don’t need to cause unnecessary confusion.
 
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I've only met a few DNPs....and all 3 have been administrators. They all went by their first names, similar to what I've seen with most DPT clinicians.

I think it was PsyDr who mentioned going by your professional designation, which is how I've always handled things. At hospitals it seems like everyone from nursing to nutrition wear white coats. I would just say I'm Dr. So-and-So, the neuropsychologist for the (TBI/GenMed/etc) unit. In private practice it's still formal w. patients, but much more laid back the rest of the time.
 
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I've only met a few DNPs....and all 3 have been administrators. They all went by their first names, similar to what I've seen with most DPT clinicians.

I think it was PsyDr who mentioned going by your professional designation, which is how I've always handled things. At hospitals it seems like everyone from nursing to nutrition wear white coats. I would just say I'm Dr. So-and-So, the neuropsychologist for the (TBI/GenMed/etc) unit. In private practice it's still formal w. patients, but much more laid back the rest of the time.
Where do you guys hide out? I’ve never seen a psychologist in the hospital. It’s hard enough to see a psychiatrist on a non-psych unit. They come and go in the flash of an eye.
 
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Where do you guys hide out? I’ve never seen a psychologist in the hospital. It’s hard enough to see a psychiatrist on a non-psych unit. They come and go in the flash of an eye.

I worked out of our MH OP clinic and answered consults on all of our inpaient units, we exist
 
Where do you guys hide out? I’ve never seen a psychologist in the hospital. It’s hard enough to see a psychiatrist on a non-psych unit. They come and go in the flash of an eye.

Like a 4th year medical student, or a cockroach, we scurry away in the face of scrutiny.

But, offer free food and we can be caught. That gets me like 31% of the time. Why do I know about magnetically controlled urethral prosthetic sphincters? Tacos and pasta salad.
 
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I wonder if the hospitals I’ve worked at just didn’t have psychologists. Is it a regional thing? Just at the VA?

I work in ED and ICUs, and I never even saw psychologist notes in the chart. We had a lot of TBI patients.

Do you guys need to see them while they’re inpatient? What can you guys do for them in the hospital?

I think it would be great to have psychologists in the ED at least. People get PTSD from getting medical care. Maybe psychologists can help prevent that?
 
Like a 4th year medical student, or a cockroach, we scurry away in the face of scrutiny.

But, offer free food and we can be caught. That gets me like 31% of the time. Why do I know about magnetically controlled urethral prosthetic sphincters? Tacos and pasta salad.
Lol at 31%. That’s a very specific number.
 
I wonder if the hospitals I’ve worked at just didn’t have psychologists. Is it a regional thing? Just at the VA?

I work in ED and ICUs, and I never even saw psychologist notes in the chart. We had a lot of TBI patients.

Do you guys need to see them while they’re inpatient? What can you guys do for them in the hospital?

I think it would be great to have psychologists in the ED at least. People get PTSD from getting medical care. Maybe psychologists can help prevent that?


It is HIGHLY institution specific. I've been on staff at places where there are no other psychologists. I’ve either worked in, seen, or heard of psychologists working in medical setting like:

1) Emergency Departments, including 1-2 with on call requirements
2) inpatient neuro rehab (gotta love those netted beds!)
3) radiology depts
4) free standing imaging centers
5) neuro depts/ neuro icu/neurosurgery depts. Lots of epilepsy, obvs.
6) transplant inpatient stuff.
7) pain management (either the cleanest or dirtiest bathrooms in town!)
8) one dude that is/was weirdly housed in the dental dept (no idea)
9) Peds (there's even one weirdo that specializes in infant psychology. I suspect he just teaches basic behavioralism and says, "this is a special child" while holding it up like simba.
10) PMR to include amputation/spinal cord injury/burn.

Lots of stuff we can help with. Lots we can't. Although it's probably not PTSD, there's significant literature about treating this type of stuff inpatient, and some ICU psychosis psychology tx.
 
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It is HIGHLY institution specific. I've been on staff at places where there are no other psychologists. I’ve either worked in, seen, or heard of psychologists working in medical setting like:

1) Emergency Departments, including 1-2 with on call requirements
2) inpatient neuro rehab (gotta love those netted beds!)
3) radiology depts
4) free standing imaging centers
5) neuro depts/ neuro icu/neurosurgery depts. Lots of epilepsy, obvs.
6) transplant inpatient stuff.
7) pain management (either the cleanest or dirtiest bathrooms in town!)
8) one dude that is/was weirdly housed in the dental dept (no idea)
9) Peds (there's even one weirdo that specializes in infant psychology. I suspect he just teaches basic behavioralism and says, "this is a special child" while holding it up like simba.
10) PMR to include amputation/spinal cord injury/burn.

Lots of stuff we can help with. Lots we can't. Although it's probably not PTSD, there's significant literature about treating this type of stuff inpatient, and some ICU psychosis psychology tx.

This; it can vary substantially by facility. I've personally trained/worked in inpatient (acute and subacute) and outpatient neuro rehab, inpatient medicine, outpatient HIV, inpatient and outpatient transplant, hospice (briefly), outpatient neurology, inpatient and outpatient PMR, inpatient spinal cord injury, primary care, pain management, epilepsy monitoring unit, long-term care, and blind rehab (in addition to the more traditional inpatient and outpatient mental health, state-run adult homes, etc.). Like PsyDr mentioned, I've worked in places where there were 1 or 2 psychologists for the entire facility, and other places where almost every service had at least 1 embedded psychologist. Many times, hospitals without prior experience with psychologists just don't know what we do and can offer, and we (psychologists) are pretty bad about self-promotion.

Not all psychologists have the opportunity for significant training in medical settings, and so the hospital/clinic environment can be a rude awakening for some. Without that training, and outside of dissertation and thesis defenses, some psychologists aren't used to having to publicly justify/defend their reasoning and succinctly discuss cases.
 
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C.4.d. Implying Doctoral-Level Competence
Counselors clearly state their highest earned degree in counseling or a closely related field. Counselors do not imply doctoral-level competence when posessing a master’s degree in counseling or a related field by referring to themselves as “Dr.” in a counseling context when their doctorate is not in counseling or a related field. Counselors do not use “ABD” (all but dissertation) or other such terms to imply competency.

Highest counseling degree. You asked about someone in sociology. If this person is a counselor educator, that's a different story.

Examples:

(1) A person at my internship last year had a doctorate in education, but was also an LPC. They went by Bob Smith, LPC while working at the clinic and Bob Smith, Ed.D. while working in a university context where no clinical services were performed.

(2) Another person had a LPC and a doctorate in education at another site (private practice) I was at went by John Smith, Ed.D., LPC

(3)A third person has a Ph.D. in Counselor Education and works at a university as an assistant professor in mental health counseling. They go by Sara Smith, Ph.D.

(4) A fourth person has a Ph.D. in Counselor Education and works in a private practice setting exclusively. They go by Jane Smith, Ph.D., LPC.

1 and 3 are ethical. 2 is unethical. 4 is a grey area.
^^THIS^^

To the OP: As the clinician in your example is licensed as an LCP, it definitely falls under the ACA Code of Ethics (2014) rather than the APA. (And, of course, the clinician's state licensure board regulations apply, as well.)

It boils down to whether the ACA and state board consider "sociology" to be "a closely related field" to counseling. I simply do not possess the knowledge to say for sure if they would see it this way or not. But I would think it would be a heck of a stretch to call sociology a closely related field to clinical counseling. As R. Matey rightly points out, the PHD/CES represents a legitimate grey area -- particularly if CACREP accredited as it is often seen as the gold standard in counseling (which is a debate on its own). But most CES programs offer some significant clinical training as an aspect of their overall degree requirement, including a clinical internship.

That said, anything beyond a CES (and possibly the relatively rare Doctorate in Professional Counseling (DPC) degree seems extremely questionable to use as an advertising tool. Still, whether we like it or not, it boils down to whatever the ACA is willing to endorse as "closely related" to counseling. For example, a master's degree holder in clinical counseling might later get a doctorate in ministry degree with an emphasis in pastoral counseling. This person might argue they were ethical in presenting themselves as a doctoral-level trained counselor. (I am NOT saying I personally endorse this, just to be clear.) And, if the ACA is comfortable with this, then they are free (legally) to do it.

That all said, it is also worth noting that, regardless of how a mid-level clinician advertises themselves (MA, PHD, DPC, DMFT, MDIV, DMIN, etc.), they still MUST clearly go over their educational credentials with every client/patient during the initial informed consent process. Personally, I feel concerned that many consumers could still have confusion regarding the clinician's training. We should assume most clients do not arrive with a strong understanding of the difference between psychology or counseling (much less things like sociology or ministry!).

I cannot imagine many (if any) clinicians of any level consider a degree in sociology to be clinically relevant. If this person really feels a need for the title "Dr." with this degree, then they should work in academia, period. I remember I had a vice principal in my middle school years that insisted on all us students calling him "Dr." It must have been quite the ego boost for him. :rolleyes::lol:
 
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Update: During a discussion with some colleagues, this subject came up, and something interesting was brought to my awareness. The ACA Code of Ethics (2014) indeed instructs counselors (LPC's) to list their highest earned degree in counseling or a closely related field. It then instructs counselors with master's degrees in counseling are not to refer to themselves as "Dr." in clinical settings (section C.4.d). (*We can likely presume this includes advertising.) That said, a person could likely advertise themselves as "Bob Smith, Ph.D.", (even if their doctorate was in, say, human services counseling). BUT...they could NOT advertise themselves as "Dr. Counselorperson, Ph.D."

@TikiTorches: I am really curious to learn if the counselor to whom you first referred in this post follows this model on their website? Do they explicitly use the title "Dr." on this site at all, or just the degree (Ph.D.) itself? I know this kinda feels like splitting hairs, but I am most curious if maybe this could clarify the ambiguity in the ACA code of ethics. I did a quick search online for LPC's with doctorates, and thus far, none of them advertise themselves as "Dr." even though they DO list their degrees as Ph.D., Ed.D., D.Min., D.MFT., D.S.W., and so on. (Literally oodles of counselors advertising like this.)

To draw a parallel, consider a medical setting. Would it be inappropriate for an NP to list their degree on their business card as "Bob Smith, DNP," so long as the business card clearly represented this person as an NP? Obviously, it would be inappropriate to advertise as "Dr. Bob Smith, DNP," as the Dr. part implies doctoral-level competence and could lead patients to believe the person was a physician. (But again, what if a card read: "Bob Smith, DNP, Nurse Practitioner?")

Please forgive my ignorance here. I really have no idea how it is done on the medical side. Do physicians generally advertise as "Dr. Soandso, M.D.?" Or just "Soandso, M.D.?" or is there even a standard here at all? Perhaps I am chasing an imaginary dragon here with this theory? I am just really curious to learn why the ACA allows mid-levels to list their highest earned degree, while at the same time, prohibiting their implying of doctoral-level competence. These two things seem contradictory. As others noted already, virtually all therapists outside of the psychiatry or psychologist arenas are all licensed at the mid-level. (Social workers, counselors, MFT's, etc.) So, as we counselors are ALL mid-level clinicians, I am a bit perplexed why the ACA would allow ANY clinicians under their umbrella to list ANY doctoral degree of any kind, as it is irrelevant to licensure. But again, there are countless folks openly advertising a doctorate degree, but licensed as mid-levels. It is just interesting... (Personally, I believe the ACA ought to modify the language in their code of ethics and just be done with this issue once and for all.)



References

American Counseling Association. (2014). 2014 ACA code of ethics. Alexandria, VA: American Counseling Association. https://www.counseling.org/Resources/aca-code-of-ethics.pdf
 
Update: During a discussion with some colleagues, this subject came up, and something interesting was brought to my awareness. The ACA Code of Ethics (2014) indeed instructs counselors (LPC's) to list their highest earned degree in counseling or a closely related field. It then instructs counselors with master's degrees in counseling are not to refer to themselves as "Dr." in clinical settings (section C.4.d). (*We can likely presume this includes advertising.) That said, a person could likely advertise themselves as "Bob Smith, Ph.D.", (even if their doctorate was in, say, human services counseling). BUT...they could NOT advertise themselves as "Dr. Counselorperson, Ph.D."

@TikiTorches: I am really curious to learn if the counselor to whom you first referred in this post follows this model on their website? Do they explicitly use the title "Dr." on this site at all, or just the degree (Ph.D.) itself? I know this kinda feels like splitting hairs, but I am most curious if maybe this could clarify the ambiguity in the ACA code of ethics. I did a quick search online for LPC's with doctorates, and thus far, none of them advertise themselves as "Dr." even though they DO list their degrees as Ph.D., Ed.D., D.Min., D.MFT., D.S.W., and so on. (Literally oodles of counselors advertising like this.)

To draw a parallel, consider a medical setting. Would it be inappropriate for an NP to list their degree on their business card as "Bob Smith, DNP," so long as the business card clearly represented this person as an NP? Obviously, it would be inappropriate to advertise as "Dr. Bob Smith, DNP," as the Dr. part implies doctoral-level competence and could lead patients to believe the person was a physician. (But again, what if a card read: "Bob Smith, DNP, Nurse Practitioner?")

Please forgive my ignorance here. I really have no idea how it is done on the medical side. Do physicians generally advertise as "Dr. Soandso, M.D.?" Or just "Soandso, M.D.?" or is there even a standard here at all? Perhaps I am chasing an imaginary dragon here with this theory? I am just really curious to learn why the ACA allows mid-levels to list their highest earned degree, while at the same time, prohibiting their implying of doctoral-level competence. These two things seem contradictory. As others noted already, virtually all therapists outside of the psychiatry or psychologist arenas are all licensed at the mid-level. (Social workers, counselors, MFT's, etc.) So, as we counselors are ALL mid-level clinicians, I am a bit perplexed why the ACA would allow ANY clinicians under their umbrella to list ANY doctoral degree of any kind, as it is irrelevant to licensure. But again, there are countless folks openly advertising a doctorate degree, but licensed as mid-levels. It is just interesting... (Personally, I believe the ACA ought to modify the language in their code of ethics and just be done with this issue once and for all.)



References

American Counseling Association. (2014). 2014 ACA code of ethics. Alexandria, VA: American Counseling Association. https://www.counseling.org/Resources/aca-code-of-ethics.pdf

I haven't looked at the nursing code of ethics, but I can say that just yesterday I saw a website on which a DNP in the "about us" section was referred to as "Dr. Jane Smith" numerous times. There are also a couple DNPs in my system who are often referred to as "Dr." in meetings, although I honestly don't know if they refer to themselves as such with patients.
 
Update: During a discussion with some colleagues, this subject came up, and something interesting was brought to my awareness. The ACA Code of Ethics (2014) indeed instructs counselors (LPC's) to list their highest earned degree in counseling or a closely related field. It then instructs counselors with master's degrees in counseling are not to refer to themselves as "Dr." in clinical settings (section C.4.d). (*We can likely presume this includes advertising.) That said, a person could likely advertise themselves as "Bob Smith, Ph.D.", (even if their doctorate was in, say, human services counseling). BUT...they could NOT advertise themselves as "Dr. Counselorperson, Ph.D."

@TikiTorches: I am really curious to learn if the counselor to whom you first referred in this post follows this model on their website? Do they explicitly use the title "Dr." on this site at all, or just the degree (Ph.D.) itself? I know this kinda feels like splitting hairs, but I am most curious if maybe this could clarify the ambiguity in the ACA code of ethics. I did a quick search online for LPC's with doctorates, and thus far, none of them advertise themselves as "Dr." even though they DO list their degrees as Ph.D., Ed.D., D.Min., D.MFT., D.S.W., and so on. (Literally oodles of counselors advertising like this.)

To draw a parallel, consider a medical setting. Would it be inappropriate for an NP to list their degree on their business card as "Bob Smith, DNP," so long as the business card clearly represented this person as an NP? Obviously, it would be inappropriate to advertise as "Dr. Bob Smith, DNP," as the Dr. part implies doctoral-level competence and could lead patients to believe the person was a physician. (But again, what if a card read: "Bob Smith, DNP, Nurse Practitioner?")

Please forgive my ignorance here. I really have no idea how it is done on the medical side. Do physicians generally advertise as "Dr. Soandso, M.D.?" Or just "Soandso, M.D.?" or is there even a standard here at all? Perhaps I am chasing an imaginary dragon here with this theory? I am just really curious to learn why the ACA allows mid-levels to list their highest earned degree, while at the same time, prohibiting their implying of doctoral-level competence. These two things seem contradictory. As others noted already, virtually all therapists outside of the psychiatry or psychologist arenas are all licensed at the mid-level. (Social workers, counselors, MFT's, etc.) So, as we counselors are ALL mid-level clinicians, I am a bit perplexed why the ACA would allow ANY clinicians under their umbrella to list ANY doctoral degree of any kind, as it is irrelevant to licensure. But again, there are countless folks openly advertising a doctorate degree, but licensed as mid-levels. It is just interesting... (Personally, I believe the ACA ought to modify the language in their code of ethics and just be done with this issue once and for all.)



References

American Counseling Association. (2014). 2014 ACA code of ethics. Alexandria, VA: American Counseling Association. https://www.counseling.org/Resources/aca-code-of-ethics.pdf
In many jurisdictions, it is comes down to the regulations (and boards) related to licensure at the HIGHER degree. For example, the actual "violation" of an MA level practitioner calling themselves "Dr," or "Ph.D" is practicing psychology without a license. The line of thinking is that by using the doctoral level title or degree, the public would reasonably believe that the person was credentialled and practicing at the doctoral level- i.e., as licensed psychologist. While different boards and regulations (and ethics codes, for that matter) should not be contradictory, ultimately it comes down to who's turf the violation occurs on. This is all governed by state regulations, which may or may not be in line with ACA, APA, AMA, etc. In the case of the nursing example, it may not be addressed in the nursing regulations, but could be in the physician regulations.
 
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I haven't looked at the nursing code of ethics, but I can say that just yesterday I saw a website on which a DNP in the "about us" section was referred to as "Dr. Jane Smith" numerous times. There are also a couple DNPs in my system who are often referred to as "Dr." in meetings, although I honestly don't know if they refer to themselves as such with patients.
Hmmm, curious. You may have just killed my theory before it even got off the ground. (My poor ego haha!) Jokes aside, I am now curious if what you just described is considered ethical (or even legal) on the nursing side. As I am in counseling, I should probably stay in my own lane here. (Keeps me out of more trouble this way haha)

But in a broader sense, I would think that in ANY clinical setting or field, that this general ethical rule would apply. Do folks really bicker about being called "Dr." in a clinical setting when they are licensed as mid-levels? Are people really this petty?? (Serious question) I would think that the licensure level would be the ultimate defining factor in all clinical fields. So, to refer to oneself as "Dr." they must be licensed at the doctoral-level -- or at the very least, eligible for licensure at this level. (I do know of a couple of legitimate doctorate-level clinical psych folks who are licensed as mid-level LPC's, for various obscure reasons.)

I TOTALLY understand that many mid-levels might wish to pursue further training at the doctorate level for a variety of personal reasons. But if/when these degrees (some folks on here referred to them as "vanity" degrees) are not clinical in nature, they are not license-eligible. If a counselor (master's level) earned a Ph.D. in a field closely related to counseling, then I suppose they ought to list it in advertising. Again, the ACA actually instructs this, though it is hard visualizing anyone feeling obligated to report a mid-level clinician for NOT advertising their non-clinical doctorate degree. (Then again, we have established just how petty some folks can be haha.) But they should NEVER use the title "Dr." outside of an educational setting. This is just my humble opinion. Folks are free to take it for whatever they feel it is worth. (And it is likely not worth much in the grand scheme of things!)
 
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In many jurisdictions, it is comes down to the regulations (and boards) related to licensure at the HIGHER degree. For example, the actual "violation" of an MA level practitioner calling themselves "Dr," or "Ph.D" is practicing psychology without a license. The line of thinking is that by using the doctoral level title or degree, the public would reasonably believe that the person was credentialled and practicing at the doctoral level- i.e., as licensed psychologist. While different boards and regulations (and ethics codes, for that matter) should not be contradictory, ultimately it comes down to who's turf the violation occurs on. This is all governed by state regulations, which may or may not be in line with ACA, APA, AMA, etc. In the case of the nursing example, it may not be addressed in the nursing regulations, but could be in the physician regulations.
This is an interesting (and new) concept for me. (I am pretty sheltered in my profession of counseling, surrounded almost exclusively by other counselors.)

Am I understanding your thinking here correctly that the APA code of ethics essentially "outranks" (for lack of a better term) the ACA ethical guidelines, at least in certain regions, because the APA licenses at the doctoral-level?

Like you note, much of it boils down to turf. I can visualize this becoming quite a quagmire in certain environments. (I recall a Mel Brooks film scene where about 2-3 minutes is devoted to a small group of men all introducing themselves to each other as "doctor.") But mostly, I am struggling to understand who, exactly, is appointed as the enforcer? Can the APA demand that a state licensing commission takes action against a licensed counselor or social worker? I am just trying to visualize the process.

So Bob Smith (master's counselor) gets his Ph.D. in underwater basketweaving therapy (entirely theory-based degree) and then advertises as Bob Smith, Ph.D. His professional association (ACA) is okay with this because his degree is "closely related[ish]" to counseling. But then Dr. Competence, MD runs across this advertisement and feels obligated to report it. He alerts the APA because they license at the doctoral-level. After reviewing the complaint, the APA disapproves of "Dr." Smith's advertising practice and contacts Smith's regional licensing board and demands action? But then "Dr." Smith pulls out the ACA Code of Ethics and defends his practice. So his defense for his doctorate degree is that he is a mid-level clinician?? (Is it normal for one's brain to hurt while trying to visualize this mess?) The ACA then backs up Smith because literally, nobody in the counseling field has clinical doctorates because no such degree exists. (Except perhaps the Ph.D. in Counselor Education/Supervision, which is arguably not truly clinical.) In the meantime, IF this complaint ever found a resolution, it would undoubtedly take at least a couple of years to go through all of the above-listed agencies. During these two years, thousands of other mid-levels obtain their own non-clinical doctorates and add these initials to their shingles, and Dr. Competence's (MD) head understandably implodes.
 
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This is an interesting (and new) concept for me. (I am pretty sheltered in my profession of counseling, surrounded almost exclusively by other counselors.)

Am I understanding your thinking here correctly that the APA code of ethics essentially "outranks" (for lack of a better term) the ACA ethical guidelines, at least in certain regions, because the APA licenses at the doctoral-level?

Like you note, much of it boils down to turf. I can visualize this becoming quite a quagmire in certain environments. (I recall a Mel Brooks film scene where about 2-3 minutes is devoted to a small group of men all introducing themselves to each other as "doctor.") But mostly, I am struggling to understand who, exactly, is appointed as the enforcer? Can the APA demand that a state licensing commission takes action against a licensed counselor or social worker? I am just trying to visualize the process.

So Bob Smith (master's counselor) gets his Ph.D. in underwater basketweaving therapy theory and then advertises as Bob Smith, Ph.D. His professional association (ACA) is okay with this because his degree is "closely related[ish]" to counseling. But then Dr. Competence, MD runs across this advertisement and feels obligated to report it. He alerts the APA because they license at the doctoral-level. After reviewing the complaint, the APA disapproves of "Dr." Smith's advertising practice and contacts Smith's regional licensing board and demands action? But then "Dr." Smith pulls out the ACA Code of Ethics and defends his practice. So his defense for his doctorate degree is that he is a mid-level clinician?? (Is it normal for one's brain to hurt while trying to visualize this mess?) The ACA then backs up Smith because literally, nobody in the counseling field has clinical doctorates because no such degree exists. (Except perhaps the Ph.D. in Counselor Education/Supervision, which is arguably not truly clinical.) In the meantime, IF this complaint ever found a resolution, it would undoubtedly take at least a couple of years to go through all of the above-listed agencies. During these two years, thousands of other mid-levels obtain their own non-clinical doctorates and add these initials to their shingles, and Dr. Competence's (MD) head understandably implodes.

State dept of health.
 
...So Bob Smith (master's counselor) gets his Ph.D. in underwater basketweaving therapy (entirely theory-based degree) and then advertises as Bob Smith, Ph.D. His professional association (ACA) is okay with this because his degree is "closely related[ish]" to counseling. But then Dr. Competence, MD runs across this advertisement and feels obligated to report it. He alerts the APA because they license at the doctoral-level...
APA/ACA/etc. are professional organizations that do not licence anybody. Licensing is controlled by state boards of licensure (as Wisneuro points out above, they are often- but not always- housed with Stat Dept. of Health), according to the regulations of a specific state. Professional organization issue ethics codes, but do not have any authority to enforce them. State boards will often use the ethics codes when enforcing their own state standards, but ultimately the state regulations guide the practice of a specific discipline. If I felt that a licensed someone was engaging in the practice of psychology illegally (which is often the same as unethically, but not always) I'd report the issue to the board of psychology (or whoever else the state policies dictate I should report to). The board would then judge that person's behavior according to the laws and policies of that state (note that they would not look too kindly on someone who was not following the ethical guidelines of their own profession, but would not have any authority to enforce those guidelines UNLESS local regulations and policies said they did).

It's important to remember that state licensing boards primarily oversee the practice and not the practitioner. If you are licensed as a social worker, but engage in behaviors that fall under the category of practicing psychology, then you are subject to discipline under the regulations governing the practice of psychology (including any regs related to using doctoral level degrees or credential in advertising or otherwise putting yourself out to the public). Similarly, if I- as a license psychologist- engage in behaviors related to master's level credentials that I do not have, I could be subject to sanction under the regulations governing the practice of that discipline. All of this is not necessary hierarchical, with one board or set of regs "trumping" another. You are, at all times, subject to ALL regulations and board policies in your jurisdiction, not just the one governing your own profession.
 
This is an interesting (and new) concept for me. (I am pretty sheltered in my profession of counseling, surrounded almost exclusively by other counselors.)

Am I understanding your thinking here correctly that the APA code of ethics essentially "outranks" (for lack of a better term) the ACA ethical guidelines, at least in certain regions, because the APA licenses at the doctoral-level?

Like you note, much of it boils down to turf. I can visualize this becoming quite a quagmire in certain environments. (I recall a Mel Brooks film scene where about 2-3 minutes is devoted to a small group of men all introducing themselves to each other as "doctor.") But mostly, I am struggling to understand who, exactly, is appointed as the enforcer? Can the APA demand that a state licensing commission takes action against a licensed counselor or social worker? I am just trying to visualize the process.

So Bob Smith (master's counselor) gets his Ph.D. in underwater basketweaving therapy (entirely theory-based degree) and then advertises as Bob Smith, Ph.D. His professional association (ACA) is okay with this because his degree is "closely related[ish]" to counseling. But then Dr. Competence, MD runs across this advertisement and feels obligated to report it. He alerts the APA because they license at the doctoral-level. After reviewing the complaint, the APA disapproves of "Dr." Smith's advertising practice and contacts Smith's regional licensing board and demands action? But then "Dr." Smith pulls out the ACA Code of Ethics and defends his practice. So his defense for his doctorate degree is that he is a mid-level clinician?? (Is it normal for one's brain to hurt while trying to visualize this mess?) The ACA then backs up Smith because literally, nobody in the counseling field has clinical doctorates because no such degree exists. (Except perhaps the Ph.D. in Counselor Education/Supervision, which is arguably not truly clinical.) In the meantime, IF this complaint ever found a resolution, it would undoubtedly take at least a couple of years to go through all of the above-listed agencies. During these two years, thousands of other mid-levels obtain their own non-clinical doctorates and add these initials to their shingles, and Dr. Competence's (MD) head understandably implodes.

Professional organizations set the standards for the profession, but carry little actual enforcement authority. States have to codify those standards into law and then enforce them on the grounds of state law. Also, two states may enforce the ACA standards differently. One state I worked in was quick and swift in their response to posers claiming to have doctoral level credentials. The state places people on a publicly available blacklist and imposes fines. I made a board complaint in a second state I worked in because a master's level clinician, with no actual doctorate, was referring to themselves as "Dr. So and so" to their patients and associated stakeholders. The second state DID NOTHING about it. I never received a call back and that person remains licensed without sanction. Regardless of how the state's licensing board decided to act, I believe the clinician in this example is acting unethically because it violates the standards set by the profession.
 
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If I felt that a licensed someone was engaging in the practice of psychology illegally (which is often the same as unethically, but not always) I'd report the issue to the board of psychology (or whoever else the state policies dictate I should report to). The board would then judge that person's behavior according to the laws and policies of that state
This part I feel confident in clarity. For instance, if I advertised online as a mid-level "counseling" (LPC) clinician that I offered my clients a med-management program where I instructed or advised them on which medicines to take or dosage, or even what time of day to take a medicine, then all the sudden, I am now practicing medicine without a license (a felony in my state, I might add) -- a BIG GIANT no-no!! For counselors, med-management means helping clients better identify, and/or cope with medicine side effects and so on. But the minute I start advising/instructing which medicine a client should/should not take, or dosage etc., I will promptly find myself in a heap of troubles.

The same is true for anyone claiming to practice clinical psychology duties. This would be practicing psychology without a license. (Also a criminal offense + steep fines in many US states.)

It's important to remember that state licensing boards primarily oversee the practice and not the practitioner. If you are licensed as a social worker, but engage in behaviors that fall under the category of practicing psychology, then you are subject to discipline under the regulations governing the practice of psychology (including any regs related to using doctoral level degrees or credential in advertising or otherwise putting yourself out to the public).
This is where the lines get a bit blurred for me. While I understand the ACA and CACREP both actively wish to distinguish the profession of clinical counseling from that of clinical psychology, the fact remains, there is a great deal of overlap here. By my current understanding, aside from some varying theories and philosophies in training/practice, the main difference between these two professions is found more in the scope of practice. Well, this and we counselors are licensed at the master's level, whereas psychologists are licensed at the doctoral level. (Please forgive the longwindedness of this reply, as I am trying to consider future readers who may be new to these concepts in my response now.) But can any of us really explain the [clinical] difference between clinical counseling and psychology in a single coherent sentence? But essentially, more training (i.e., psychologists) = a broader scope of practice. But the lines get blurred.

As an LPC in my state, I have the authority to diagnose mental disorders. While I personally willfully choose to forfeit this duty, the fact remains, I COULD do it if I chose. I would not want somebody I knew/loved being diagnosed by a mid-level when there was access to a qualified psychologist or physician. Thus, I prefer referring to local psychologists for diagnoses and treatment planning, and I then just follow the treatment plan and perform the therapy. This was the original intent of the mid-level clinician, imu, but this is a matter of discussion for another day/thread. (But also, not everyone lives in areas with ready access to psychologists or mental health physicians, hence, the LPC's authority to diagnose comes into play.) But my bigger point is that I have authority and duties which overlap with psychology.

But back to the OP, is advertising a doctorate degree a scope of practice issue? By this I mean is a counselor (LPC) that advertises their theory-based doctorate degree somehow a form of practicing psychology? (It all seems to boil back down to the implication of advertising this way possibly confusing or leading the public to believe that clinician was implying doctoral-level competence.) And if it is the implication that is the main issue at hand, then this seems more like a systematic issue rather than beef with any single mid-level clinician. (Again, there are literally OODLES of mid-levels advertising this way online.)

Again, I completely understand why some mid-levels might wish to pursue further training in a theory or research-based area and then list this degree on their website. Many mid-levels write books or create various workshops etc. and specialized knowledge in a niche area may be relevant. If I authored a popular book or workshop and people already knew me as "Bob Smith, Ph.D." from these books, then it seems appropriate to remain consistent on a website for advertising purposes. (Though I would also CLEARLY note my licensure as the mid-level.) At the same time, since the ACA allows stuff like this as a professional courtesy, (See ACA Code of Ethics C.4.d), many mid-levels apparently take advantage of this grey area and present themselves in shady ways, where it leaves the potential (or in some cases, even intentionally leads) the public to believe they had doctoral-level competence as a practitioner. So, again, this just seems more like a systematic beef than an individual one. Though as Matey noted, there certainly ARE clear cases where individual clinicians willfully misrepresent themselves in scandalous ways. (Referring to oneself to patients as "Dr." when one has no such degree at that level of any kind, for example. I presume that none of us would view this as a grey area!)

With all this said, I am really curious now, from your perspectives as Ph.D. Psychologists (and the OP being an MD), would it make a difference to you folks if/when a mid-level clinician listed their research doctorate in advertising IF they also did it in a way that very clearly distinguished themselves as a mid-level clinician?

Example: Hi, my name is Bob Smith, Ph.D. I am a licensed professional counselor (LPC) practicing as a master's-level clinician. I earned my clinical master's degree at State University. I particularly enjoy helping clients explore their spiritual natures, so I obtained my Ph.D. in Pastoral Counseling from suchandsuch Seminary. I am a Nationally Certified Counselor (NCC), certified as a mental health counselor. While I treat most mental health concerns as a generalist, I specialize in the integration of spiritual beliefs, for clients who desire and request this service.

Notice in this above example they distinguished themselves as a counselor, not a psychologist. They also do not refer to themselves as "Dr." Bob Smith, Ph.D. but just "Bob Smith, Ph.D." What I am wondering is, from the perspective of clinical psychologists, are there any situations where it could be appropriate for a mid-level to list their non-clinical doctorate in a clinical setting (like advertising)?

One final disclaimer: I personally have no dog in this fight. I am a mid-level clinician (LPC) and hold no doctorate degree from any academic discipline. I MAY someday pursue a Ph.D. in clinical psych, but that is another matter entirely. Even if I did obtain a clinical doctorate in psychology, I probably would still not refer to myself as "Dr." just because of my theoretical orientation and I just prefer a more egalitarian nature of the relationship between clients and myself. But again, I see this issue come up a lot. I see/hear many of my peers on the counseling side dismiss any such concerns as mere "credential hubris" without really even listening to the arguments from our psychologist colleagues. This disappoints me. I really appreciate you folks sharing your perspectives with me in this discussion. My own personal opinion on the matter is that clinicians ought not to refer to themselves as "Dr.'s" unless they are explicitly license-eligible at the doctorate level. But it also seems reasonable, to me, for mid-level clinicians to advertise their non-clinical doctorate degrees, so long as they CLEARLY distinguish themselves as master's level practitioners. But perhaps you clinical psych folks might move my needle on this. So I am really curious if you believe it could ever be appropriate, or if it is a hard "NO" 100% of the time. Does motive/intent matter here?
 
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...But back to the OP, is advertising a doctorate degree a scope of practice issue? By this I mean is a counselor (LPC) that advertises their theory-based doctorate degree somehow a form of practicing psychology? (It all seems to boil back down to the implication of advertising this way possibly confusing or leading the public to believe that clinician was implying doctoral-level competence.) And if it is the implication that is the main issue at hand, then this seems more like a systematic issue rather than beef with any single mid-level clinician. (Again, there are literally OODLES of mid-levels advertising this way online.)...
Depending on the state regs and board policies, it could be seen as putting oneself out to the public as a doctoral level credentialed mental health clinician, and in many (most? all?) jurisdictions, doctoral level mental health licensure is limited to psychologists. Many boards feel that it is not appropriate to expect the public to understand that the "LPC" is related to licensure/applied clinical work, but the "Ph.D." is not.

.., since the ACA allows stuff like this as a professional courtesy, (See ACA Code of Ethics C.4.d), many mid-levels apparently take advantage of this grey area and present themselves in shady ways...
As mentioned in previous posts, ACA/APA etc. ethics codes are not relevant to this discussion. This is about state regulations and board policies. Yes- you should certainly be following the ethics code of your professional organization (and some states may have codified "follow your ethics code" in some regulations or policies. However, when it comes down to choosing between ethics codes and state regulations/policies, a good rule of thumb is to adhere to the STRICTEST standard.

With all this said, I am really curious now, from your perspectives as Ph.D. Psychologists (and the OP being an MD), would it make a difference to you folks if/when a mid-level clinician listed their research doctorate in advertising IF they also did it in a way that very clearly distinguished themselves as a mid-level clinician?

Example: Hi, my name is Bob Smith, Ph.D. I am a licensed professional counselor (LPC) practicing as a master's-level clinician. I earned my clinical master's degree at State University. I particularly enjoy helping clients explore their spiritual natures, so I obtained my Ph.D. in Pastoral Counseling from suchandsuch Seminary. I am a Nationally Certified Counselor (NCC), certified as a mental health counselor. While I treat most mental health concerns as a generalist, I specialize in the integration of spiritual beliefs, for clients who desire and request this service.
What we think as psychologists or physicians is irrelevant- it's what the state board thinks and the regs say that are important. While your example makes sense to me, would it make sense to the average client off the street what is going on? I'm pretty sure that that example would not fly with my state board. They are especially picky about Ph.D.s in related fields, and the part in your example where you say "Ph.D. in Pastoral Counseling" is a big red flag, as it implies DOCTORAL level clinical training, which is the realm of psychologists. They get particularly ornery with people who actually did doctoral level psychology (clinical/counseling) who use their doctoral degree when practicing under an MA level license, and expressly say in one of their policy papers that they (the board) considers that an attempt to get around psychology licensing regulations and is practicing psychology without a license.

I, personally, have never made a complaint to a board regarding somebody using doctoral degree in advertising their MA level practice. I have reported somebody for referring to themselves as a "psychologist" and to their work as being "psychology" (after first trying to resolve the issue informally by informing them of the regulations. Those terms are legally protected and, in the context of applied clinical services, can be used only by licensed psychologists.

... But again, I see this issue come up a lot. I see/hear many of my peers on the counseling side dismiss any such concerns as mere "credential hubris" without really even listening to the arguments from our psychologist colleagues....
...Does motive/intent matter here?
I'd caution your friends that it doesn't matter what they think. Intent isn't accounted for in the regs and policies that I have seen- It's pretty straightforward "don't do this or you risk sanction" language. It can be hard for us to put ourselves in the place of the general public, as terms such as counselor, LPC/LMHC, LICSW, and Psychologist all have specific meanings to us. That's why the boards and regulations don't leave it up to us.
 
Depending on the state regs and board policies, it could be seen as putting oneself out to the public as a doctoral level credentialed mental health clinician, and in many (most? all?) jurisdictions, doctoral level mental health licensure is limited to psychologists. Many boards feel that it is not appropriate to expect the public to understand that the "LPC" is related to licensure/applied clinical work, but the "Ph.D." is not.
I definitely understand your thinking here. To a large degree, I align with you very closely. Again, as a clinician myself, I have a challenging time explaining the difference between psychology and counseling to clients. (It essentially involves a brief history lecture.) That said, whether we like it or not, a distinction between psychiatry, psychology, counseling (including MFT), and social work has been established. How often do you psychologists get thought of as psychiatrists by your patients? The key difference, though, just to state the obvious, is these are both doctoral-level positions. For that matter, did this same debate formulate back shortly after psychiatry conferred some of their authorities to psychologists? i.e., was there a concern that psychologists might be mistaken by the public as practitioners of medicine? (Another irrelevant rabbit trail, I know, but there is a partial parallel here.)

As time goes on, the distinctions between the professions continue to become more concrete. There was a time when very few people understood what a nurse practitioner or physician's assistant was. But the distinction is much more clear today and continues gaining distinction over time. I suppose it mostly boils down to specific turf and region as you noted earlier. If I had to guess, in my state, I doubt there would be much of a fuss made in the end. But this is only a guess. I still wonder if it might have to do with whether a clinician refers to themselves as "Dr." in clinical settings (rather than listing the degree type itself).

Anyhow, beyond this, I am likely beating a dead horse at this point searching for a universal standard. This would have made a great subject for my ethical dilemma paper in my graduate school days.
What we think as psychologists or physicians is irrelevant- it's what the state board thinks and the regs say that are important.
I understand this. I was just peeking down a rabbit trail here. I am still curious if any doc-psychs felt like chiming in here just for the heck of it as a quick side-discussion, changing the discussion from "is it allowed?" to "How do I approach it?" (I appreciate your approach, btw.) Personally, I would probably not advertise a non-clinical doctorate unless it was explicitly in relation to an educational context like a workshop or book, etc. But at the same time, I probably won't bother reporting anyone for advertising this way unless it appears willfully or recklessly deceitful.
I have reported somebody for referring to themselves as a "psychologist" and to their work as being "psychology" (after first trying to resolve the issue informally by informing them of the regulations. Those terms are legally protected and, in the context of applied clinical services, can be used only by licensed psychologists.
I bet this person wishes they would've listened a little closer when you first approached them. They say hindsight is 20/20! "Psychologist" is indeed a legally protected title in most (all?) US states. This is day one stuff. Especially considering you approached them privately at first, I find myself lacking any sympathy for this clinician. (I would not sympathize even if you reported them without approaching them first, frankly.)

That all said, I would be interested in hearing from anyone willing to argue fully in favor of (mid-levels) advertising a non-clinical doctorate exterior of an educational context. I am just curious if there might be any angles of this I am not seeing yet. (I have learned to never say never.)
 
Add on to above comment^^

Consider the mid-level who wants to specialize in a niche area. So Bob Smith, MA, earns a non-clinical doctorate in sexology. His area desperately needs a clinician in this niche. He advertises himself as clearly/ethically as he can as a master's-level clinician, but he does also list his doctorate in sexology so potential consumers can know of his expertise. We have (more or less) established that this is arguably not allowed, at least in some/most regions. But how do/should we approach situations like this? Is there not room for some grace here in our approach? Again, I am contrasting this against the mid-levels that advertise in questionable ways, listing a Ph.D. but without any explanation whatsoever.

Should Bob Smith, sexologist in this scenario, perhaps, just allude to his doctorate instead of listing it? (i.e., "I am licensed at the master's level, and I pursued further training/certification in sexology" or something along these lines?)
 
Add on to above comment^^

Consider the mid-level who wants to specialize in a niche area. So Bob Smith, MA, earns a non-clinical doctorate in sexology. His area desperately needs a clinician in this niche. He advertises himself as clearly/ethically as he can as a master's-level clinician, but he does also list his doctorate in sexology so potential consumers can know of his expertise. We have (more or less) established that this is arguably not allowed, at least in some/most regions. But how do/should we approach situations like this? Is there not room for some grace here in our approach? Again, I am contrasting this against the mid-levels that advertise in questionable ways, listing a Ph.D. but without any explanation whatsoever.

Should Bob Smith, sexologist in this scenario, perhaps, just allude to his doctorate instead of listing it? (i.e., "I am licensed at the master's level, and I pursued further training/certification in sexology" or something along these lines?)

You probably want somebody else to get in on this, but you're stuck with me! The example you chose points out the problem with such "non-clinical" doctorates. I know it's just a random example, but do a web search for doctoral programs in "sexology." Anything look good to you? The regulations and boards actually specify the minimum content of doctoral level training, including coursework and supervised clinical work. When I use my "Ph.D." in conjunction with the legal title "psychologist", it's not just an honorific, but a statement that I have completed a minimal level off training DIRECTLY APPLICABLE to the work I do as a psychologist. Non-clinical/counseling Ph.D., degrees convey no such thing. As to your question about what Bob Smith should do, what you propose seems reasonable to me (as long as the training/certification is actually of a nature and quantity to improve his "sexology" related clinical behaviors). There are plenty of shady doctorates out there, and they either meet minimum standards or they don't. If they meet the standards, then graduates should get doctoral level licensure. If they don't, then any reference to them in advertising or public facing behaviors is misleading.
 
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You probably want somebody else to get in on this, but you're stuck with me! The example you chose points out the problem with such "non-clinical" doctorates. I know it's just a random example, but do a web search for doctoral programs in "sexology." Anything look good to you? The regulations and boards actually specify the minimum content of doctoral level training, including coursework and supervised clinical work. When I use my "Ph.D." in conjunction with the legal title "psychologist", it's not just an honorific, but a statement that I have completed a minimal level off training DIRECTLY APPLICABLE to the work I do as a psychologist. Non-clinical/counseling Ph.D., degrees convey no such thing. As to your question about what Bob Smith should do, what you propose seems reasonable to me (as long as the training/certification is actually of a nature and quantity to improve his "sexology" related clinical behaviors). There are plenty of shady doctorates out there, and they either meet minimum standards or they don't. If they meet the standards, then graduates should get doctoral level licensure. If they don't, then any reference to them in advertising or public facing behaviors is misleading.
I've been "stuck" with worse :) Really, I appreciate you sharing your thoughts. I am unsure why this subject grabs me as it does. Again, I have no horse in this race. But I think it is a worthwhile discussion, nonetheless. It seems like a legitimate ethical dilemma to me, at least concerning the cases where no deceit is intended by practitioners. On one hand, listing any doctoral degree implies doctoral-level practice/training. On the other hand, it seems like it is not serving the public (arguably may be harmful in some cases?) when clinicians cannot candidly disclose their educational backgrounds and areas of expertise. It seems to me that consumers ought to have access to all relevant information when screening/evaluating potential therapists. But essentially treating the general public as though they "can't handle the truth" just kind of rubs me the wrong way, even though I completely understand the altruistic motivations behind it. Sure enough, though, the second we give people an inch, we see some of them take a mile. Next thing we know, we see mid-levels presenting themselves as "Ph.D.'s" when their degree is in sociology and is nonclinical in nature.

Yes, sexology was a poor example in practice. But in theory (if/when this niche area found traction and accreditation in academia) it still holds. (Or just insert any other niche area: traumatology, LGBTQ+ studies, religion, or any other just fill-in-the-blank.) If an otherwise reasonably healthy individual needed a therapist for this niche area, then a mid-level with such education and research background might actually be the more appropriate choice for this consumer. (This is up to the consumer, obviously.) Alas, law/regs are not intended to help the public know which therapist might be the most appropriate or even the most qualified. They exist to regulate the profession as a whole, as you noted earlier, and distinguish/protect certain titles.

I could surely think of a few more "what if" scenarios for ole Bob Smith, but I will give the poor guy (and you) a break. "Dr." Bob Smith is undoubtedly ready to sue me for defamation of his character at this point anyhow. I could go round and round whipping the horse in this dilemma, but again, I think the horse died a good while ago.
 
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