ASPPB Potential Regulatory Implications of Master’s Licensure (PRI-LM) Task Force

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More than 20,000 students graduate every year with a master’s degree in psychology. In most jurisdictions, these individuals are unable to become licensed by a psychology regulatory body; instead, they might become licensed professional counselors or marriage and family therapists, or they might join the ranks of another mental health profession.

In jurisdictions where psychology boards do license master’s-level practitioners, the particulars of licensure vary greatly. Some jurisdictions require that these individuals maintain life-long supervision while others offer a path to independent practice. The defined scope and limits of practice vary across jurisdictions, and more than five (5) different licensure titles are in use across those jurisdictions. As more jurisdictions consider adding this licensure status, or as jurisdictions review their existing requirements for licensing those with master’s degrees in psychology, uniformity for the process and requirements for licensure can provide consistency that will aid the public in better understanding the professional role of these individuals. This uniformity will allow these professionals to also have better access to mobility and other professional opportunities.



The ASPPB Potential Regulatory Implications of Master’s Licensure (PRI-LM) Task Force was formed to suggest a license title and scope of practice for those trained in psychology master’s programs to assist member jurisdictions that were considering creating a pathway for licensure for those individuals. As the Task Force began its work, it quickly became clear to us that we needed to elaborate much more than we were originally tasked to do. We saw that a title and a scope made no sense without a focus on the licensure process which would help clarify the reasons for the titles and scopes of practice we were suggesting.



The Task Force has now completed its work. We have outlined requirements, titles, scopes of practice, and processes for licensing graduates from master’s-level psychology programs. We are now inviting comments from interested parties and stakeholders about the attached documents. Included are an Outline of the licensure process for master’s-level psychology practitioners, a detailed Diagram that provides a snapshot of the process, a suggested Model Act and Model Regulations, and Further Elaboration for the Testing and Assessment track for those psychology regulatory boards/colleges considering adding this license status or amending already existing laws and regulations regarding the licensure of master’s-trained individuals from psychology programs.

In reviewing these documents for comment, please particularly attend to the following:


• The three identified tracks and their individual scopes of practice

• Residency and supervised experience during training

• Determination of equivalency for those not graduating from accredited programs

• The rationale for using the recommended passing scores for the EPPP

• The process for how to approach failure to pass the EPPP, including the number of attempts allowed



We look forward to any comments or suggestions you might have.

Thank you,


The PRI-LM Task Force

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I am not a fan of the assessment-related scope of practice.

I've sent a somewhat lengthy email to the listed address expressing my displeasure with the proposed tracks and scopes of practice. I'd encourage all other psychologists to do the same. IMO, it's a disaster waiting to happen if the guidelines go forth as written.
 
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I am not a fan of the assessment-related scope of practice.

I've sent a somewhat lengthy email to the listed address expressing my displeasure with the proposed tracks and scopes of practice. I'd encourage all other psychologists to do the same. IMO, it's a disaster waiting to happen if the guidelines go forth as written.

Mind backchanneling me that e-mail? I'll adapt and send one too.
 
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I am not a fan of the assessment-related scope of practice.

I've sent a somewhat lengthy email to the listed address expressing my displeasure with the proposed tracks and scopes of practice. I'd encourage all other psychologists to do the same. IMO, it's a disaster waiting to happen if the guidelines go forth as written.

What don't you like? I don't have time to read this right now.
 
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Along this same scope- what are your thoughts on doc MFTs being able to become licensed as psychologists? I have some thoughts and feelings about (a primary concern being assessment as one piece of that, another being them supervising practicum students in clinical psych programs having never done the match process/assessment/etc). This is without doing a doc re-specialization mind you.
 
Let's see what nonsense title ASPPB comes up with. I'm betting a 90% chance their title pisses me off.


Along this same scope- what are your thoughts on doc MFTs being able to become licensed as psychologists? I have some thoughts and feelings about (a primary concern being assessment as one piece of that, another being them supervising practicum students in clinical psych programs having never done the match process/assessment/etc). This is without doing a doc re-specialization mind you.
They can't. MFTs are NOT psychologists. It is a wholly different profession, that should be licensed as such. A plumber isn't licensed as an electrician.

The mistake here, is being nice about it. Just point out that they are not a psychologist, and do not have the same training.
 
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Let's see what nonsense title ASPPB comes up with. I'm betting a 90% chance their title pisses me off.



They can't. MFTs are NOT psychologists. It is a wholly different profession, that should be licensed as such. A plumber isn't licensed as an electrician.

The mistake here, is being nice about it. Just point out that they are not a psychologist, and do not have the same training.
Can we tell THAT to the licensing board that has approved some of them 😬 granted I’m guessing they’ll have a REALLY hard time passing the EPPP, etc.

I’ll give you three guesses as to which schools they’re coming from (and yes- I know three different people that are doctoral level MFTs who are getting licensed as psychologists. Lots of thoughts and feelings about this).

Edit- yes I have also talked to them directly about why this is NOT appropriate, differences in our training, etc. They don’t care/don’t believe that it’s true. I pointed out at bare minimum all your ethics classes were BBS, we are governed by APA. So even ethically speaking you’re gonna have to learn a new code (because there are differences).
 
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What don't you like? I don't have time to read this right now.
I haven't read through it all yet either. If you go to the "Scope of Practice" section, it lists a "Testing and Assessment track" with the scope, limitations, and examples of what different areas of assessment would be.

Testing and Assessment track: Further requirements and limitations with examples
1. Treatment planning:

a. The scope of practice includes testing and assessment to inform mental health treatment planning by other professionals, such as psychologists and psychology practitioners, medical or other healthcare professionals, psychiatrists, and counselors in professions other than psychology.

b. Testing and assessment for mental health treatment planning by other health professionals is limited to mental health treatment planning by those professionals.

c. The scope of practice does not include treatment planning in domains other than mental health treatment planning, such as risk assessment or appropriateness of organ transplant or other surgical interventions.

Examples:

A pediatrician expresses concern that a child is responding atypically to a treatment protocol for ADHD and requests diagnostic assessment for further clarification of the child's symptoms. Because the assessment is related to mental health treatment planning, the assessment would be within the scope of practice for the individual practicing independently at the master's level who is trained and competent inasmuch assessment.

A psychiatrist requests a psychological battery, including personality testing and "that inkblot test" to aid in the psychiatrist's need to differentiate symptoms of posttraumatic stress disorder from personality disorder. The use of projective measures and personality assessment is outside the scope of practice for an individual practicing independently at the master's level, and the referral should be declined.

An internist requests a psychological assessment to determine whether a patient is a good candidate for liver transplant surgery. Because the assessment is not related to mental health treatment planning, the assessment would not be within the scope of practice for the individual practicing independently at the master's level.

2. Educational Planning and Placement:

a. The scope of practice includes testing and assessment requested by educational institutions where the individual being assessed receives services or is enrolled. Purposes of the assessment may include eligibility for services, clarification of educational needs, remediation planning, and disability manifestation determinations related to school-based discipline.

b. The scope of practice includes testing and assessment requested by individuals and organizations other than educational institutions where the referral and the assessment serve the purposes of educational planning and placement for the individual being assessed.

c. The scope of practice is limited to measures of cognitive ability and potential, adaptive functioning, academic achievement, and data from parent and teacher reports of behavioral and school functioning. Parent and teacher reports maybe obtained by standardized measurement or structured or unstructured interview.

d. The scope of practice does not include testing and assessment for determination other than educational planning and placement, such as institutional liability for failure to meet a student's needs.

Examples:
A primary school requests psychological assessments of applicants to its specialized programming, which requires a specified range of intellectual functioning for eligibility purposes. Because the assessment serves the purpose of educational placement, the assessment would be within the scope of practice for the individual practicing independently at the master's level.

An attorney requests psychological assessment of a school-aged child for the purposes of lawsuit against the school district claiming damages for the school's refusal to provide special education services to the child. Because the assessment is for litigation purposes and not for educational planning and placement services, the assessment would not be within the scope of practice for the individual practicing independently at the master's level.

3. Occupational Planning and Placement:

a. The scope of practice includes referrals from governmental agencies responsible foredetermining an individual's eligibility for disability, based on the individual's scope affability and limitations in the workplace, including the individual's needs for accommodation in the workplace.

b. The scope of practice includes referrals from individuals or educational institutions assess an individual's interest in or goodness of fit for occupational fields or career paths.

c. The scope of practice does not include referrals from employers, licensing boards, or other sources of privileges to determine an individual's fitness for duty, fitness for practice, fitness for tenure, or fitness for continued service.

d. The scope of practice does not include referrals for assessments related to wrongful termination, compensation and damages, failure to provide accommodations, discrimination, or other personal injury, regardless of the referral source.

Examples:

An agency with responsibility for determining eligibility for disability benefits seeks evaluation related of an individual to determine the individual's employability, ability to work, and ability to perform tasks. Because the referral and assessment are related to the individual's scope of abilities and limitations in the workplace, the assessment would be within the scope of practice for an individual practicing independently at the master's level. The referral would be included whether initiated by a government agency or a private contractor, so long as its purpose is within the scope of practice.

An employer seeks psychological assessment of an individual's needs for accommodations related to diagnosis of autism spectrum disorder. Because the referral and assessment are related to an individual's need for accommodations in the workplace, the referral would be within the scope of practice for an individual practicing independently at the master's level.

A governmental agency seeks psychological assessment to determine whether an employee's psychological symptoms were caused by the behavior of the employer or the workplace environment. Because the referral and assessment are not related to occupational planning and placement for the individual being assessed, the referral would not be within the scope of practice for the individual practicing independently at the master's level.

A police department seeks psychological assessment of a law enforcement officer to determine whether the officer remains fit for sworn duty. Although the referral and assessment are related to occupational planning for the individual being assessed, the assessment requires a level of specialized training which is not expected to be included at the master's level of education, training, and experience. The referral would not be within the scope of practice for an individual practicing independently at the master's level.

4. Practice of Psychology, Intervention Track:

a. The following provisions regarding scope of practice apply to all activities in the Intervention Track by those individuals authorized to practice with a master's degree, regardless of application or licensure status, and regardless of the requirement of supervision.

b. The Intervention Track includes the observation, description, interpretation, prediction, and modification of human behavior by the application of psychological principles, methods, and procedures, for the purposes of:
1) preventing, eliminating, or predicting symptomatic, maladaptive, or undesired behaviors.
2) facilitating the enhancement of individuals or groups of individuals including personal effectiveness, adaptive behavior, interpersonal relationships, and work and life adjustment.

c. Scope of practice for the Intervention Track:
1) An initial assessment intake shall be conducted on individuals, couples, families, or individual members of a group for treatment planning. It includes assessments for clients of the psychology practitioner or for a group practice or organization to which the psychology practitioner belongs. Referrals for assessments for other purposes, or under other referral circumstances, are include din the Testing and Assessment Track.
2) An initial assessment intake includes interviewing and screening methods for the purpose of case formulation, diagnosis, and treatment planning. An initial assessment intake does not include personality measures, neuropsychological assessment, or forensic assessment measures.
3) Continuing assessment for treatment planning includes the use of screening measures for patient status within the scope of a continuing therapeutic relationship.
 
Let's see what nonsense title ASPPB comes up with. I'm betting a 90% chance their title pisses me off.



They can't. MFTs are NOT psychologists. It is a wholly different profession, that should be licensed as such. A plumber isn't licensed as an electrician.

The mistake here, is being nice about it. Just point out that they are not a psychologist, and do not have the same training.
I'm not a fan of the title, either. It's "licensed psychology practitioner," if I'm remembering correctly.
 
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Any possibility for me too?


Yeah, that's definitely not going to confuse the public when they're looking for a psychologist. /s

Same, please.

Done and done.

Mind you, I make no claims that my email was a good one, but it's at least a starting point.

And yeah, the title doesn't (IMO) sufficiently differentiate rather than just confuse further.
 
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More than 20,000 students graduate every year with a master’s degree in psychology. In most jurisdictions, these individuals are unable to become licensed by a psychology regulatory body; instead, they might become licensed professional counselors or marriage and family therapists, or they might join the ranks of another mental health profession.

Okay, but are they trying to be psychologists? That makes no sense. If you go to a program that prepares you for masters-level licensure (e.g. counseling, MFT), you graduate and prepare to pursue… a master’s level license.
 
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More than 20,000 students graduate every year with a master’s degree in psychology. In most jurisdictions, these individuals are unable to become licensed by a psychology regulatory body; instead, they might become licensed professional counselors or marriage and family therapists, or they might join the ranks of another mental health profession.

Okay, but are they trying to be psychologists? That makes no sense. If you go to a program that prepares you for masters-level licensure (e.g. counseling, MFT), you graduate and prepare to pursue… a master’s level license.
Unfortunately for some- yes. Their schools (ahem think some of our degree mills) are not entirely honesty about the path the licensure. See above with MFTs being told they can get licensed as psychologists and MFTs (when really they either can’t/shouldnt).
 
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Done and done.

Mind you, I make no claims that my email was a good one, but it's at least a starting point.

And yeah, the title doesn't (IMO) sufficiently differentiate rather than just confuse further.

Can I get a copy as well. I agree that this will simply increase confusion for referral sources and muddy the water regarding what can and cannot be assessed. Will they know how to rule out delirium or cognitive impairment from assessment of a mental health concern?

I do think that we need a masters level license that falls under psychology, but I think the scope is very unclear and will be poorly implemented.
 
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More than 20,000 students graduate every year with a master’s degree in psychology. In most jurisdictions, these individuals are unable to become licensed by a psychology regulatory body; instead, they might become licensed professional counselors or marriage and family therapists, or they might join the ranks of another mental health profession.

Okay, but are they trying to be psychologists? That makes no sense. If you go to a program that prepares you for masters-level licensure (e.g. counseling, MFT), you graduate and prepare to pursue… a master’s level license.
Can I get a copy as well. I agree that this will simply increase confusion for referral sources and muddy the water regarding what can and cannot be assessed. Will they know how to rule out delirium or cognitive impairment from assessment of a mental health concern?

I do think that we need a masters level license that falls under psychology, but I think the scope is very unclear and will be poorly implemented.

This is like complaining that someone who goes to nursing school will become a nurse and won't be licensed by the medical board like physicians do.

I get wanting to expand the purview of psychology boards and bring , but why do they need to create this new "master’s-level psychology practitioner" role? Why can't they just absorb them under their relevant roles, i.e., have psychology board regulate counselors, LMFTs, etc. or create a new master's level psychology licensure with the same scope as other midlevels?
 
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Yeah, that's why someone else should take it over.
Eh, there’s nothing inherently wrong with lobbying for your profession within reason. It’s important in representing your professional interests to legislators who have essentially no idea what you do. And saying that masters-level counselors are essentially “psychologist” enough to be regulated by the same board could easily bite psychologists in the back.
 
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Eh, there’s nothing inherently wrong with lobbying for your profession within reason. It’s important in representing your professional interests to legislators who have essentially no idea what you do. And saying that masters-level counselors are essentially “psychologist” enough to be regulated by the same board could easily bite psychologists in the back.
I'm mostly joking, though I'd argue that some of the advocacy I've seen isn't "within reason" and is basically trying to make master's level providers to have an equal scope of practice to psychologists with doctorates.
 
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The assessment stuff is wild.

Many generalist psychologists are better off sticking to therapy, and they have hundreds of hours of training in assessment and related areas like stats/psychometrics, etc. Having a mid-level provider try to do a psych or cog assessment is not only ethically dubious, but it like will be garbage in/garbage out bc they won’t know what they don’t know.

I recently completed an IME where the primary diagnoses and treatments were done by a well-meaning but COMPLETELY out of their depth counselor. The way in which they interpreted the data were wrong (from self-assessment measures), their differential diagnosis was wrong, and 80% of the interventions they claimed to practice were trash approaches like “brainspotting”, IFS, and some kind of Jungian approach to treat PTSD.

While low hanging fruit for my IME work, it sucks that people are needlessly suffering bc they aren’t receiving the right treatments. These proposed changes will just create an army of clinicians who at best will misinterpret the data from their “assessments”, and at worse they will ruin lives by their mismanagement of the cases.
 
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I laughed at the Rorschach example. I wouldn't feel comfortable administering or interpreting one and I actually got trained on it, and used it fairly often, in a prac back in grad school.
 
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APA would better spend it's energy trying to build a joint coalition with the mid-levels orgs to build better adherence to EBPs than confuse the public even more by adding yet another MH credential, especially one that sounds like 'psychologist.' Mids every year in my state get disciplined for trying to pass themselves off as psychologists, I can only imagine this exponentiating the problem.

Also, I can't imagine that the 'intervention track' would be any different on the ground than any other mid-level credential given the post-degree supervision requirements. These are already a free-for-all at the master's level with very uneven results. Unless they have plans of building internship-like experiences for these folks, we can expect more of the same.
 
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APA would better spend it's energy trying to build a joint coalition with the mid-levels orgs to build better adherence to EBPs than confuse the public even more by adding yet another MH credential, especially one that sounds like 'psychologist.' Mids every year in my state get disciplined for trying to pass themselves off as psychologists, I can only imagine this exponentiating the problem.

Also, I can't imagine that the 'intervention track' would be any different on the ground than any other mid-level credential given the post-degree supervision requirements. These are already a free-for-all at the master's level with very uneven results. Unless they have plans of building internship-like experiences for these folks, we can expect more of the same.
Here's the flow chart of what the proposed licensure process would be. Seems like it would as uneven and variable as the existing path to licensure for midlevels.




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Seems like it would as uneven and variable as the existing path to licensure for midlevels.

Yep. This (minus the extensive testing) is no different than what is already in place in the states where I've carried a midlevel license. Post-degree 'supervision' is essentially hand-waving away concerns about provider competence without a formal structure in place where those competencies are measured and tracked. Sure, there are exceptions, but they are exceptions nonetheless.
 
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