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Weird.
I mean, I guess that is good? I care *a lot* more about all of the mid-level encroachment, lack of lobbying influence, and half a dozen other things more than I care about boarding RxP, but I guess it's good.
I mean, I guess that is good? I care *a lot* more about all of the mid-level encroachment, lack of lobbying influence, and half a dozen other things more than I care about boarding RxP, but I guess it's good.
I personally know the committee who was working on this and can tell you from my own experience navigating the field, this is a massive win for all of us. Our colleagues in medicine place a large value on board certification (and rightfully so, when you understand their structure), so having this in place, opens a great many doors for supporting future growth in psychopharmacology legislation. The requirements for completing the process, as proposed, are not too out of the way for any one seeking licensure (given how arduous this is by itself), so again, it really is just a nice way of demonstrating competence to other professions.Weird.
I mean, I guess that is good? I care *a lot* more about all of the mid-level encroachment, lack of lobbying influence, and half a dozen other things more than I care about boarding RxP, but I guess it's good.
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Vermont's RxP bill signed into law today. That makes 8 states (ie, CO, IA, ID, IL, LA, NM, UT, VT).
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Hawaii as well.
This has not yet passed, I believe.
Medicine person here. Why does America need psychologists prescribing?
Medicine person here. Why does America need psychologists prescribing?
Why does it need any type of provider (MD/DO, NP, PA, etc) prescribing?
Literal answer: According to the empirical literature, it reduces suicide rates, and increases rural access.Medicine person here. Why does America need psychologists prescribing?
In depth answer: For the same reasons that America allows MBBS graduates to be called "doctor".
Why does it need any type of provider (MD/DO, NP, PA, etc) prescribing?
Provider....ick.
Because people with mental illness need psych meds and people who know how to safely prescribe them. For the record, I am generally against midlevel encroachment, particularly from NP's. PA's do receive excellent medical training though.
Literal answer: According to the empirical literature, it reduces suicide rates, and increases rural access.
In depth answer: For the same reasons that America allows MBBS graduates to be called "doctor".
Could you cite the study(ies) that examine the direct effect of psychologists prescribing and suicide rates? I'm not doubting the claim. Just curious and wanting to learn more. Increasing rural access makes sense though.
By the way. MBBS is not really much different from the growing 6 year MD/DO programs. Depending on the country, it's usually 2 years of clinical rotations (same as here). MBBS's either have to do residency here (and pass all the brutal USMLE exams), or in the states that allow IMG's to practice medicine without residency, need years of supervised practice before they are granted full licensure.
Sanman
O.G.
Provider....ick.
Because people with mental illness need psych meds and people who know how to safely prescribe them. For the record, I am generally against midlevel encroachment, particularly from NP's. PA's do receive excellent medical training though.
Could you cite the study(ies) that examine the direct effect of psychologists prescribing and suicide rates? I'm not doubting the claim. Just curious and wanting to learn more. Increasing rural access makes sense though.
By the way. MBBS is not really much different from the growing 6 year MD/DO programs. Depending on the country, it's usually 2 years of clinical rotations (same as here). MBBS's either have to do residency here (and pass all the brutal USMLE exams), or in the states that allow IMG's to practice medicine without residency, need years of supervised practice before they are granted full licensure.
1. How is that midlevel encroachment fight going so far?
2. How many medicare patients are you seeing?
3. How much psychotherapy are you doing? How much are you billing for?
1. How is that midlevel encroachment fight going so far?
2. How many medicare patients are you seeing?
3. How much psychotherapy are you doing? How much are you billing for?
1. Not well 🤕
2. Vast majority on Medicaid/medicare or uninsured
3. Can psychotherapy cause a patient’s heart to stop?
Have you seen a bunch of heart attacks from patients of prescribing psychologists? I did the psych rxp training (to inform my research) and I think, on average, they are pretty well prepared. I’m not a fan of online training, as I did all B&M classes, but I know some prefer online classes.1. Not well 🤕
2. Vast majority on Medicaid/medicare or uninsured
3. Can psychotherapy cause a patient’s heart to stop?
A big difference I see in mid-level prescribers v psych rxp is how research is consumed and how psych rxps seem more likely to NOT prescribe in response to every inquiry.
Provider....ick.
Because people with mental illness need psych meds and people who know how to safely prescribe them. For the record, I am generally against midlevel encroachment, particularly from NP's. PA's do receive excellent medical training though.
Now that we have decades of data on this, can you cite me the studies that say that Psychologists with prescribing privileges are less safe than other prescribing providers?
1) No problem. If you are genuinely interested, I would suggest you read the Cato Institute's review. With all due respect to you, there is a history of opposition claiming, "If that happens, there will be X problem". Then peer reviewed research disproves X concern. Then opposition says, "well, it's really about something else". Unfortunately, that bad faith debate style has really soured discussion.Could you cite the study(ies) that examine the direct effect of psychologists prescribing and suicide rates? I'm not doubting the claim. Just curious and wanting to learn more. Increasing rural access makes sense though.
By the way. MBBS is not really much different from the growing 6 year MD/DO programs. Depending on the country, it's usually 2 years of clinical rotations (same as here). MBBS's either have to do residency here (and pass all the brutal USMLE exams), or in the states that allow IMG's to practice medicine without residency, need years of supervised practice before they are granted full licensure.
2) I'm not doubting that the clinical equivalence of MBBSes, MDs, and USA-based DOs. However, there is a centuries old separation between the term "physician" and the term "doctor", and those without a doctorate shouldn't be called "doctor".
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Sanman
O.G.
So, if that horse has left the barn, who you believe in more competent, an NP or a psychologist with two years of RXP training?1. Not well 🤕
Are you in PP? I know of barely any psychiatrists accepting medicaid or Medicare near me. Plenty accepting cash though.2. Vast majority on Medicaid/medicare or uninsured
You avoided my question. Are you billing 90833? How many times? Do you believe that psychotherapy can have iatrogenic effects? What kind of psychotherapy are you providing?3. Can psychotherapy cause a patient’s heart to stop?
If the argument is that only the most competent providers should engage in the their craft, fine. I hope you have a referral list of strong doctoral level psychotherapy providers available to your patients and are not billing psychotherapy codes so as create double billing situations for those psychotherapists.
So, if that horse has left the barn, who you believe in more competent, an NP or a psychologist with two years of RXP training?
Are you in PP? I know of barely any psychiatrists accepting medicaid or Medicare near me. Plenty accepting cash though.
You avoided my question. Are you billing 90833? How many times? Do you believe that psychotherapy can have iatrogenic effects? What kind of psychotherapy are you providing?
If the argument is that only the most competent providers should engage in the their craft, fine. I hope you have a referral list of strong doctoral level psychotherapy providers available to your patients and are not billing psychotherapy codes so as create double billing situations for those psychotherapists.
I have one in my Metro area that I know of who does, but is not accepting new patients as their panel is more than full, unsurprisingly. I know some in healthcare systems who do, but those systems are closed to outside referrals and have 4+month waitlists for in-system new intakes. It's....not great out there unless folks are willing pay out of pocket.
Sanman
O.G.
I have one in my Metro area that I know of who does, but is not accepting new patients as their panel is more than full, unsurprisingly. I know some in healthcare systems who do, but those systems are closed to outside referrals and have 4+month waitlists for in-system new intakes. It's....not great out there unless folks are willing pay out of pocket.
Same here, if not longer. I wonder how many of those folks are booking patients for gradual dose reductions of their antidepressants following treatment? I have said it before, I could fill a practice just doing good psychotherapy and GDRs.
Same here, if not longer. I wonder how many of those folks are booking patients for gradual dose reductions of their antidepressants following treatment? I have said it before, I could fill a practice just doing good psychotherapy and GDRs.
I would kill for a prescriber with good gero experience. The amount of ridiculous polypharm is crazy in my clinical folks.
1) No problem. If you are genuinely interested, I would suggest you read the Cato Institute's review. With all due respect to you, there is a history of opposition claiming, "If that happens, there will be X problem". Then peer reviewed research disproves X concern. Then opposition says, "well, it's really about something else". Unfortunately, that bad faith debate style has really soured discussion.
2) I'm not doubting that the clinical equivalence of MBBSes, MDs, and USA-based DOs. However, there is a centuries old separation between the term "physician" and the term "doctor", and those without a doctorate shouldn't be called "doctor".
This was interesting. I'd be also interested in a counter-opinion, if you have one.
The most fair I can be, would be to cite the AMA's counter opinion. There are some good points, combined with some outright falsehoods which makes things hard to discuss in a reasonable manner.This was interesting. I'd be also interested in a counter-opinion, if you have one.
1) There is a difference in length and content of education.
a. prerequisite science coursework
- this is somewhat true. It would be odd, but I guess it could happen.
b. length of residency/clinical training
- Somewhat true. Buuuuut they are not counting our practica, post doc, lab hours, or MSCP hours for psychologists. Then they are using the total hours from psychiatrists who do an additional fellowship as a baseline. It's comparing their best to our worst. Also, their estimates for psychiatry would almost be an AGME/OSHA violation.
c. educational content
- again, some truth, but they also excluded all of the MSCP coursework in their arguments.
2. Our MSCP education isn't standardized
- Unless APA removed their approval criteria, this is objectively false.
3. MSCP education is "insufficient" to safely prescribe
- This is objectively false, as safety has been proven. Conflating safety with other issues is a loser move.
4. RxP won't increase access to care
- this is objectively false.
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For me, I wouldn’t mind doing PCP-like prescribing, but I would get the other side of the spectrum bc I do neuropsych for TBI and poly-trauma; train wreck cases w a ton of other meds onboard already. It’s a PITA and not worth the headache compared to just doing my forensic work, so I stick w that.
As for the tired and disingenuous unfounded attacks about “safety” make me laugh bc bad prescribers are all over the place. I will refer to psych rxps bc they are more open and interested in the research and not just using flowcharts and shortcuts to rx. I’m not saying every prescriber is that way, but I can usually tell when someone trained by the meds they choose.
As for the tired and disingenuous unfounded attacks about “safety” make me laugh bc bad prescribers are all over the place. I will refer to psych rxps bc they are more open and interested in the research and not just using flowcharts and shortcuts to rx. I’m not saying every prescriber is that way, but I can usually tell when someone trained by the meds they choose.
Have you seen a bunch of heart attacks from patients of prescribing psychologists? I did the psych rxp training (to inform my research) and I think, on average, they are pretty well prepared. I’m not a fan of online training, as I did all B&M classes, but I know some prefer online classes.
A big difference I see in mid-level prescribers v psych rxp is how research is consumed and how psych rxps seem more likely to NOT prescribe in response to every inquiry.
I don't live in a state that allows psychologists to prescribe so no. PS heart attacks are not the cause of a heart stopping that you should be concerned about with many of the commonly prescribed psych meds. It's an entirely different pathophysiology.
As far as your anecdote about mid-levels vs prescribing psychologists... I can't speak on that but from my experience mid-levels are very cookie-cutter in how they prescribe- based on algorithms. Do you meet the criteria for this disorder in the DSM? Let me offer an FDA approved medication for that. Monkey see, monkey do as one of my attendings in med school liked to say. To be fair, that is the standard of care.
Now that we have decades of data on this, can you cite me the studies that say that Psychologists with prescribing privileges are less safe than other prescribing providers?
I'm not sure that's the question we should be asking here.
The question for me is, do psychologists receive enough medical training to prescribe potentially life-threatening medications? It seems like there isn't enough data to claim that they do, and the burden of proof is not on the people asking this question on behalf of patients' safety.
1) No problem. If you are genuinely interested, I would suggest you read the Cato Institute's review. With all due respect to you, there is a history of opposition claiming, "If that happens, there will be X problem". Then peer reviewed research disproves X concern. Then opposition says, "well, it's really about something else". Unfortunately, that bad faith debate style has really soured discussion.
Thank you for linking this. I took the time to read through the article and skim the studies the article cites because I am very interested in this topic.
To summarize my thoughts, the studies this particular review cites are not convincing to me, and many of the claims the author extrapolates from them are straight up dishonest.
To the point about reducing suicide rates, the Hughes and McGrath 2023 study is paywalled and I am unable to access it. The author cites 'Hughes and Phillips 2023' as evidence of reducing suicide rates, of which there are two Hughes + Phillips 2023 articles in the bibliography, one of which talks about psychologist's role's in prescribing meds for opioid use disorder and the other is a healthcare cost analysis of psychologists prescribing. That is pretty dishonest to include these next to the claim about reducing suicide rates.
The Ekong 2023 article is a thesis from a Harvard student who used chi-square analyses to compare before-and-after statewide mental health outcomes in New Mexico, Idaho, and Iowa (Rxp states) vs. Kansas, Montana, and Nevada (non prescribing states). Needless to say, that is also a questionable inclusion in a review article.
The Plemmons 2021 article it cites is a commentary posted on USNews.com. The Singer 2024 article is literally a blog post.
I was able to access Choudhury et al 2021's 'natural experiment' study which seems to be where the 5-7% reduction claim comes from which uses a 'difference-in-difference' estimation for New Mexico and Louisiana versus all non Rxp states. I think that is promising, but I don't think it is adequate to establish a causal relationship between Rxp and decreasing suicide rates. I think you would need more data examining specific patient outcomes in patients being prescribed psych meds by psychologists to make a causal statement. How many psychologists in these states are prescribing? Is it actually even making a difference in the number of people being prescribed psych meds?
As per the claims about safety, which I am more concerned about, the Curtis et al. 2023, Younger 2012, Whitney and Cummings 1998, and Peck et al. 2021 articles cited appear to be paywalled. Which is concerning, considering these studies seem to help make up the basis of the claim that it is safe for patients for psychologists to prescribe medications and are presumably being used to justify the legislation that allows them to do so. Reading the abstract of the Peck et al. article, it seems like it was a longitudinal study of the practices of...43 psychologists.
The study by the neuropsychopharmacology institute from 1998 examined the practices of a whopping 10 (ten) prescribing psychologists in the military.. which is not exactly extrapolatable to the general public anyway.
The Kaylor and Gallios 2025 article that the author cites as a 'study' is one she (Gallios) herself wrote, and actually isn't a study at all but a magazine article that cites other studies. That is straight up academic malpractice.
The DeAngelis 2023 "peer-reviewed study" they cited is also just a magazine article from the APA's Monitor on Psychology.
The best study with a good sample size that it cites is the Hughes study from 2025 assessing adverse drug events and hospitalizations in PCP's vs. psychologists vs. psychiatrists in New Mexico and Louisiana. But hospitalizations or ED usage are not objective measures of whether someone safely prescribes medication. And adverse drug events can literally be anything, including allergic reactions or things that a patient could perceive as being caused by a medication they're taking. A better measure would be preventable adverse drug events, such as prescribing a patient with zyprexa and sending them into HHS.
On a side note, the author makes this claim which is very far off the mark and unfortunately reveals her own biases.
Resistance to RxP does not solve that problem; it prolongs it. Psychiatrists are welcome to pursue — and many have pursued — advanced psychotherapy training through institutes led by psychologists, an opportunity that organized psychology has consistently supported in the interest of expanding patient access to mental health care services. Yet when psychologists seek comparable integration via prescriptive authority, resistance emerges from the very group long embraced as partners in care. Mutuality cannot be selective.
Psychotherapy and psychopharmacology do not have the same risks. Period.
Furthermore, one of the most disturbing claims I saw in this review was this:
Multiple studies have found that prescribing psychologists' advanced training in prescribing medications to treat mental health conditions is on par with that of psychiatrists and exceeds that of primary care providers and non-psychiatric nurse practitioners, indicating that patients receive appropriate medications with minimized risk (Cooper 2020; Muse and McGrath 2010).
Just... no.
2) I'm not doubting that the clinical equivalence of MBBSes, MDs, and USA-based DOs. However, there is a centuries old separation between the term "physician" and the term "doctor", and those without a doctorate shouldn't be called "doctor".
Okay gotcha, I'm not arguing that point.
So, if that horse has left the barn, who you believe in more competent, an NP or a psychologist with two years of RXP training?
I think they're both not trained well enough to prescribe psychiatric medications without a physician's supervision. To argue whether one or the other is more competent avoids the underlying issue that there is a lack of access to 'providers' (ick) who can prescribe psych meds, which I'm sure no one here disagrees on. I'm just not sure if allowing psychologists to prescribe without supervision is an entirely positive band-aid for that.
Are you in PP? I know of barely any psychiatrists accepting medicaid or Medicare near me. Plenty accepting cash though.
I work for a safety net health system
You avoided my question. Are you billing 90833? How many times? Do you believe that psychotherapy can have iatrogenic effects? What kind of psychotherapy are you providing?
What I do is a moot point. I could hypothetically do psychotherapy for all my patients. It's still impossible for me to kill my patients or directly inflict great bodily harm by doing so.
If the argument is that only the most competent providers should engage in the their craft, fine. I hope you have a referral list of strong doctoral level psychotherapy providers available to your patients and are not billing psychotherapy codes so as create double billing situations for those psychotherapists.
I wasn't aware this was an issue, and I appreciate you bringing it to my attention. I'll read more about it.
The AMA has published their counter opinion. There are some good points, combined with some outright falsehoods.
1) There is a difference in length and content of education.
a. prerequisite science coursework
- this is somewhat true. It would be odd, but I guess it could happen.
The prerequisite science coursework PsyD's and Ph.D's receive is not at all comparable to what physicians have to do, a lot of which is pharmacologically relevant (general chemistry, biochemistry, cell biology, organic chemistry, hell even physics is important).
b. length of residency/clinical training
- Somewhat true. Buuuuut they are not counting our practica, post doc, lab hours, or MSCP hours for psychologists.
Are those practica, post doc, and lab hours being spent medically managing patients or prescribing psychiatric medications + monitoring their effects? If not, they are irrelevant.
Then they are using the total hours from psychiatrists who do an additional fellowship as a baseline. It's comparing their best to our worst. Also, their estimates for psychiatry would almost be an AGME/OSHA violation.
Oof, that's an oversight/dishonest on their part.
c. educational content
- again, some truth, but they also excluded all of the MSCP coursework in their arguments.
It's not just coursework. You need years of clinical training to be competent in this.
2. Our MSCP education isn't standardized
- Unless APA removed their approval criteria, this is objectively false.
3. MSCP education is "insufficient" to safely prescribe
- This is objectively false, as safety has been proven. Conflating safety with other issues is a loser move.
4. RxP won't increase access to care
- this is objectively false.
Can't speak on MSCP education standardization as I don't know much about it. As far as point 3 there's not enough data. And point 4 I agree with you. For the record I strongly dislike the AMA.
The most fair I can be, would be to cite the AMA's counter opinion. There are some good points, combined with some outright falsehoods which makes things hard to discuss in a reasonable manner.
Seems that way. On the one hand, I agree with you that some on these points in the fact sheet are laughably untrue where some would give me more pause. Plenty of NPs, PA, and PCPs with near-zero mental health training prescribe these medications every day. I'm under no illusions that I could attain the same competence as a psychiatrist with these medications through directed postdoctoral study plus a clinical internship, but an NP? Seems doable.
On the other hand, the Cato piece seems to be assuming that psychology doctoral training is more standardized than it really is. Not all of us do postdocs and there's a ton of variability in postdocs because the process is less regulated than internship. Also, the variability in our training models does tends to produce variability in clinical practice (e.g., what PCSAS is trying to accomplish though I think they cut too deep). Granted one would hope that this would be weeded out in an MSCP admissions process, but (and I grant further this is a cynical take) hinging it to a university also creates incentives to keep admissions rates a certain level for program survival.
FTR, I'm not arguing against RxP per se. I'm personally ambivalent on the issue.
I was being flippant in my “heart attack” response bc claiming harm to patients has been a red herring since before I did my training.I don't live in a state that allows psychologists to prescribe so no. PS heart attacks are not the cause of a heart stopping that you should be concerned about with many of the commonly prescribed psych meds. It's an entirely different pathophysiology.
I see most prescribers taking a cookie-cutter approach; it’s basically inevitable bc there is so much to cover. When I went through training, probably 1/2 of the instructors were MD or MD/PhD, and most of the rest were PhDs and PharmDs, so their perspectives were different. There were ~31 antidepressants on the US market when I trained and we couldn’t just pick our favorite 1-3 of each class to learn. We were not allowed to repeat meds on any of the case examples on our exams bc they wanted to force us to consider ALL of the options. It was annoying back then, but I get it now.As far as your anecdote about mid-levels vs prescribing psychologists... I can't speak on that but from my experience mid-levels are very cookie-cutter in how they prescribe- based on algorithms. Do you meet the criteria for this disorder in the DSM? Let me offer an FDA approved medication for that. Monkey see, monkey do as one of my attendings in med school liked to say. To be fair, that is the standard of care.
I’m not saying my training was exactly what the training is now, bc it wasn’t. The years since have taught me to be even more skeptical of throwing pills at everything. Am I going to be slinging Clozaril like a PCP hands out an SSRI, absolutely not. Is it important I understand the risks and benefits of Clozaril, yes.
Eh, the psychiatry forum is fine with IMGs going directly to fellowship, AI refills, and "supervising" NPs. Then they're against RxP. The only difference is their income.For me, I wouldn’t mind doing PCP-like prescribing, but I would get the other side of the spectrum bc I do neuropsych for TBI and poly-trauma; train wreck cases w a ton of other meds onboard already. It’s a PITA and not worth the headache compared to just doing my forensic work, so I stick w that.
As for the tired and disingenuous unfounded attacks about “safety” make me laugh bc bad prescribers are all over the place. I will refer to psych rxps bc they are more open and interested in the research and not just using flowcharts and shortcuts to rx. I’m not saying every prescriber is that way, but I can usually tell when someone trained by the meds they choose.
1) That is fair.The prerequisite science coursework PsyD's and Ph.D's receive is not at all comparable to what physicians have to do, a lot of which is pharmacologically relevant (general chemistry, biochemistry, cell biology, organic chemistry, hell even physics is important).
Are those practica, post doc, and lab hours being spent medically managing patients or prescribing psychiatric medications + monitoring their effects? If not, they are irrelevant.
Oof, that's an oversight/dishonest on their part.
It's not just coursework. You need years of clinical training to be competent in this.
Can't speak on MSCP education standardization as I don't know much about it. As far as point 3 there's not enough data. And point 4 I agree with you. For the record I strongly dislike the AMA.
2)
b. If you are getting that granular, then you need to exclude every hour from medical education that is not spent in medical management of psychiatric patients used in your day to day work (eg., OSTEOPATHIC MANIPULATION, rads rotation, nuclear medicine, stats, etc). You're saying that the specific job tasks requires specific education, yet counting crap you don't use regularly. Either it counts or it doesn't. Does your medical stats course count, while mine don't? Unless you're being unfair to to get an advantage.
3) You're moving the goal post, and saying your own guesses supersede evidence. It's the intellectually dishonest approach I predicted.
4)
a. Cite the specific safety/outcome literature to support your assertion, or admit your assumptions of competence is conjecture.
b. You're making an appeal to authority, by saying "I get to decide competence, but I'm not going to give any definition or measure for competence.". It's a BS approach that can be pointed right back at you (e.g., psychiatrists need to complete a clinical psychology PhD to be competent in psychotherapy).
every time.
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I'm not sure that's the question we should be asking here.
The question for me is, do psychologists receive enough medical training to prescribe potentially life-threatening medications? It seems like there isn't enough data to claim that they do, and the burden of proof is not on the people asking this question on behalf of patients' safety.
It's exactly the question we should be asking here, as it's the same burden of proof that existing prescribers have. The data is there, if RxP is going to lead to catastrophic damage at signifcantly higher rates than pre-existing prescribers, what haven't the detractors been able to provide evidence after so much time of this being in effect. Additionally, where is the same research that "proves" other prescriber's safety and competence?
b. If you are getting that granular, then you need to exclude every hour from medical education that is not spent in medical management of psychiatric patients used in your day to day work (eg., OSTEOPATHIC MANIPULATION, rads rotation, nuclear medicine, stats, etc). You're saying that the specific job tasks requires specific education, yet counting crap you don't use regularly. Either it counts or it doesn't. Does your medical stats course count, while mine don't? Unless you're being unfair to to get an advantage.
I'm not trying to be granular or 'get an advantage', nor am I trying to be dismissive of the mental health training psychologists receive, and I apologize if I came across that way.
I'm trying to convey that the discrepancy physicians are worried about is not mental health training, it is medical training. Psych meds can affect every system in the body and themselves cause a lot of bad side effects and conditions. And they interact with a lot of non-psych meds and cause even more conditions. You have to know how these systems work, and to know what these conditions look like and how to spot them, diagnose them, and manage them, and understand the pathophysiology's of these conditions and specifically how the mechanisms of actions of these meds can cause those conditions. That's the basis of the practice of medicine.
3) You're moving the goal post, and saying your own guesses supersede evidence. It's the intellectually dishonest approach I predicted.
4)
a. Cite the specific safety/outcome literature to support your assertion, or admit your assumptions of competence is conjecture.
b. You're making an appeal to authority, by saying "I get to decide competence, but I'm not going to give any definition or measure for competence.". It's a BS approach that can be pointed right back at you (e.g., psychiatrists need to complete a clinical psychology PhD to be competent in psychotherapy).
every time.
I'm not guessing, but I haven't seen convincing evidence that Rxp is safe, and I am open to reading studies that suggest otherwise.
Nor am I appealing to authority, nor do I decide competence. But medical errors leading to patient harm happen often even with the years of medical training physicians receive. Intuitively, letting people with substantially less medical training prescribe medications without physician oversight could be dangerous.
It's exactly the question we should be asking here, as it's the same burden of proof that existing prescribers have. The data is there, if RxP is going to lead to catastrophic damage at signifcantly higher rates than pre-existing prescribers, what haven't the detractors been able to provide evidence after so much time of this being in effect. Additionally, where is the same research that "proves" other prescriber's safety and competence?
Psychologists have been prescribing medications for 24 years in the US in a handful of states. I'm simply not sure there's enough data to say people who are not trained in medicine can safely prescribe medications compared to other 'prescribers'. And to your point about other 'prescribers' safety and competence, like I said, I'm also not comfortable with mid-levels prescribing psych meds without supervision.
Psychologists have been prescribing medications for 24 years in the US in a handful of states. I'm simply not sure there's enough data to say people who are not trained in medicine can safely prescribe medications compared to other 'prescribers'. And to your point about other 'prescribers' safety and competence, like I said, I'm also not comfortable with mid-levels prescribing psych meds without supervision.
The issue is, we've never established any standard for any prescribing provider aside from "this is just the way we do things." So, you're holding other providers to standards that have never been demonstrated by existing providers. And, there is data, however underwhelming you find it as to safety, yet I have seen no data, of any kind, showing the harm that many have been foretelling for some time now. So, what empirical evidence are we holding ALL prescribing providers to having to demonstrate safety aside from "I'll know it when I see it?"
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The issue is, we've never established any standard for any prescribing provider aside from "this is just the way we do things." So, you're holding other providers to standards that have never been demonstrated by existing providers. And, there is data, however underwhelming you find it as to safety, yet I have seen no data, of any kind, showing the harm that many have been foretelling for some time now. So, what empirical evidence are we holding ALL prescribing providers to having to demonstrate safety aside from "I'll know it when I see it?"
I see your point, but I don't think challenging the legitimacy and expertise of medicine as a profession is an argument that holds up for allowing non-medically trained people to practice said profession.
And for the record, my personal stance is I'm not entirely opposed to letting psychologists prescribe medications. I think they should be able to do so with physician supervision.
I see your point, but I don't think challenging the legitimacy and expertise of medicine as a profession is an argument that holds up for allowing non-medically trained people to practice said profession.
And for the record, my personal stance is I'm not entirely opposed to letting psychologists prescribe medications. I think they should be able to do so with physician supervision.
That's fair in terms of an opinion. I tend to disagree according to the available evidence and lack of the sky falling as I have been warned over the years. If shown compelling evidence otherwise, I am open to changing my views.
I'm trying to convey that the discrepancy physicians are worried about is not mental health training, it is medical training. Psych meds can affect every system in the body and themselves cause a lot of bad side effects and conditions. And they interact with a lot of non-psych meds and cause even more conditions. You have to know how these systems work, and to know what these conditions look like and how to spot them, diagnose them, and manage them, and understand the pathophysiology's of these conditions and specifically how the mechanisms of actions of these meds can cause those conditions. That's the basis of the practice of medicine.
This is the acute anxiety I feel about not knowing what I don't know when it comes to RxP. It's not true that we do not get biological training. Many of us take neuroscience/neuroanatomy courses and have published neuroscience papers, which is training that could be capitalized on in a theoretical well-designed MSCP program. If I went for RxP, I would welcome physician supervision.
Also, I think a lack of MH training can cause significant problems too. I'm certain I'm not the only one who has seen a pt overdose with ETH on benzos for panic attacks because some PCP didn't think about BPD.
This is the acute anxiety I feel about not knowing what I don't know when it comes to RxP. It's not true that we do not get biological training. Many of us take neuroscience/neuroanatomy courses and have published neuroscience papers, which is training that could be capitalized on in a theoretical well-designed MSCP program.
I’m not saying psychologists don’t get biological training, but psych meds can affect a lot more things than the nervous system.
Also, I think a lack of MH training can cause significant problems too. I'm certain I'm not the only one who has seen a pt overdose with ETH on benzos for panic attacks because some PCP didn't think about BPD.
Absolutely. I 100% believe in a multidisciplinary approach for patients with mental illness.
I see your point, but I don't think challenging the legitimacy and expertise of medicine as a profession is an argument that holds up for allowing non-medically trained people to practice said profession.
And for the record, my personal stance is I'm not entirely opposed to letting psychologists prescribe medications. I think they should be able to do so with physician supervision.
1) Psychologists ALWAYS prescribe with physician supervision.
2) As Wisneuro has pointed out, medical curriculum is historically based, not based upon a job task analysis using objective factors. Absent objective measures, we have no idea as to what makes a competent physician. CME is accepted to bring old people up to date, so it's not fully about formal coursework.
3) You're again moving the goal post from self defined "competence" to "medical errors", to your own personal comfort, which is not supported by the science. But I'll get on board with your idea. When establishing the bar for the interaction between licensing and medical errors, exactly how many are allowed, under which specific populations? Is trauma surgery going to be okay?
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Sanman
O.G.
What I do is a moot point. I could hypothetically do psychotherapy for all my patients. It's still impossible for me to kill my patients or directly inflict great bodily harm by doing so.
You sure about that? Then why require us to carry a license and malpractice insurance if there is no risk of harm at all? If there is some risk of harm to a patient, why not require the highest standard of practice?
If you are willing to accept some risk of harm to a patient, then comes the slippery slope of how much?
1) Psychologists ALWAYS prescribe with physician supervision.
Do they? Like I said, I personally can get behind that even if the AMA can't. I thought each states' laws were different though- are all Rxp states and states in the future having/going to have that requirement?
2) As Wisneuro has pointed out, medical curriculum is historically based, not based upon a job task analysis using objective factors. Absent objective measures, we have no idea as to what makes a competent physician. CME is accepted to bring old people up to date, so it's not fully about formal coursework.
I think this is a misconception of medical education. Medical schools do not teach things based on how things have been historically done - medical curriculum is based on data and current standards of care, and it is standardized by on the USMLE/COMLEX board examiners who design their exams based on these best current data and practices. These exam forms literally change month to month. As per your claim about objective measures of competence, I'll talk about that below.
And you're right - it's not fully about formal coursework, but a physician who was trained in the 50's learned the fundamentals of human anatomy, physiology, and pathology, and had years of training treating patients in a hospital before they were an attending. CME is definitely an imperfect system, but the fundamentals and basic clinical training are still there. The family medicine/internal medicine boards and ABPN also require either sitting for standardized exams every couple of years or standardized longitudinal assessments on top of CME.
3) You're again moving the goal post from self defined "competence" to "medical errors", to your own personal comfort, which is not supported by the science. But I'll get on board with your idea. When establishing the bar for the interaction between licensing and medical errors, exactly how many are allowed, under which specific populations? Is trauma surgery going to be okay?
I'm not sure exactly which claim you're referring to that isn't supported by science. Preventable medical errors are a good objective measure of competence. Although I agree with you that there aren't many good standardized measures of a physician's 'competence'. Patient outcomes is one, if that's what we're getting at - and I'm not doubting that prescribing psychologists can help people, because psych meds work, and in the vast majority of patients many of the most commonly prescribed meds are well-tolerated. But patient safety in those off-cases is the main critique of Rxp from the medical standpoint.
I would say that that bar is determined by employers who can stomach only so many errors, or a lawyer suing the physician. It's a multibillion-dollar industry and its own law specialty for a reason. Part of the basis of these cases is did the physician provide the standard of care, which is more subjective but I think is also a good measure of competence. Standard of care is a legal term that varies by state, but basically means, would another reasonable provider have provided similar care under similar circumstances? And my question is MSCP training enough to bring psychologists up to this speed? I'm not convinced at the moment.
You sure about that? Then why require us to carry a license and malpractice insurance if there is no risk of harm at all? If there is some risk of harm to a patient, why not require the highest standard of practice?
So do schoolteachers. Look up malpractice payouts for physicians versus therapists.
If you are willing to accept some risk of harm to a patient, then comes the slippery slope of how much?
I see your point, but I think discussing this slippery slope is semantics. It's not the same risks, period, because of what it is you're doing.
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I'm not doubting that prescribing psychologists can help people, because psych meds work, and in the vast majority of patients many of the most commonly prescribed meds are well-tolerated. But patient safety in those off-cases is the main critique of Rxp from the medical standpoint.
If you accept RxP under physician supervision, this critique largely vanishes.
If you accept RxP under physician supervision, this critique largely vanishes.
Eh, not entirely. Medical residents are also liable to get sued (alongside their attendings) because they still bare a lot of responsibility for what happens to their patients even if they are technically practicing medicine under an attending physician's license and the attending is also supposed to see those patients themselves. That's kind of the framework I'm thinking of when I say physician supervision.
And do you know if all of the Rxp states require physician supervision?
Eh, not entirely. Medical residents are also liable to get sued (alongside their attendings) because they still bare a lot of responsibility for what happens to their patients even if they are technically practicing medicine under an attending physician's license and the attending is also supposed to see those patients themselves. That's kind of the framework I'm thinking of when I say physician supervision.
That's not really what I'm talking about. If the concern is that gross incompetence harms patient safety, then it vanishes by having a responsible, knowledgeable party assume responsibility vanishes the concern because a knowledgeable party is present to assure patient safety. This is the same logic that underlies PA practice. Who can be sued for malpractice is beside the point.
No, but I wouldn't support independent RxP for reasons I described.
That's not really what I'm talking about. If the concern is that gross incompetence harms patient safety, then it vanishes by having a responsible, knowledgeable party assume responsibility vanishes the concern because a knowledgeable party is present to assure patient safety. This is the same logic that underlies PA practice. Who can be sued for malpractice is beside the point.
I know that’s what you meant, and that’s what my post is addressing. I’m saying that the risk of patient harm does not completely vanish when you have a knowledgeable party assuming responsibility. I’m using liability of residents (and also by extension PA’s) as an example because that fact underlies this principle.
No, but I wouldn't support independent RxP for reasons I described.
I’m not saying you do, I was genuinely asking because I do not know.
Sanman
O.G.
Eh, not entirely. Medical residents are also liable to get sued (alongside their attendings) because they still bare a lot of responsibility for what happens to their patients even if they are technically practicing medicine under an attending physician's license and the attending is also supposed to see those patients themselves. That's kind of the framework I'm thinking of when I say physician supervision.
And do you know if all of the Rxp states require physician supervision?
The vast majority, if not all, states require physician collaboration for practice of RXP. I am not an expert but I don't know of any state that does not require physician collaboration. That said in 27 states and DC, the standard of care is an independent NP. Psych NPs can also practice psychotherapy. The irony is, opposing us will likely strengthen NP numbers.
I would certainly steer someone to NP school based on costs, time in schooling, and what the license allows. We require more schooling for a more restricted license.
I know that’s what you meant, and that’s what my post is addressing. I’m saying that the risk of patient harm does not completely vanish when you have a knowledgeable party assuming responsibility. I’m using liability of residents (and also by extension PA’s) as an example because this principle underlies that fact.
I didn't say completely. You're ok with PA practice, correct? I'm saying that RxP would function similar to that. I'll grant there are still risks, but I'd wager it's are the same amount of risk in PA practice. You can even make a case than it's more minimal considering that we are content experts in mental health in ways that PAs are not experts in medicine. The real area of anxiety, for me at least (and I think for you too), would be prescribing a substance that has unknown effect on another body system or interact with another chemical in a manner that I am unfamiliar or could not have anticipated. But I don't feel at all incompetent in my ability to diagnose a mental health condition, which can't be said for many who do prescribe these medicines. Germane to cardiac events mentioned upthread, misdiagnosis of ADHD, which is rampant, does carry that risk.
I think the real, and more important question lies in our confidence in the MSCP program. Can it train psychologists to function as well as PAs or could it train psychologists to function as well as dentists in relation to prescribing medication? You mentioned upthread that you're unconvinced the MSCP program could effectively do this and I think this is an area where I am more likely to agree. I have reservations about two-year online program's ability to teach me what I really need to know to practice effectively, even under supervision. But I'm open to being convinced otherwise.
1) All prescribing psychologists have to be supervised by a physician who personally examines the patient first, and then agrees with the proposed prescription.Do they? Like I said, I personally can get behind that even if the AMA can't. I thought each states' laws were different though- are all Rxp states and states in the future having/going to have that requirement?
I think this is a misconception of medical education. Medical schools do not teach things based on how things have been historically done - medical curriculum is based on data and current standards of care, and it is standardized by on the USMLE/COMLEX board examiners who design their exams based on these best current data and practices. These exam forms literally change month to month. As per your claim about objective measures of competence, I'll talk about that below.
And you're right - it's not fully about formal coursework, but a physician who was trained in the 50's learned the fundamentals of human anatomy, physiology, and pathology, and had years of training treating patients in a hospital before they were an attending. CME is definitely an imperfect system, but the fundamentals and basic clinical training are still there. The family medicine/internal medicine boards and ABPN also require either sitting for standardized exams every couple of years or standardized longitudinal assessments on top of CME.
I'm not sure exactly which claim you're referring to that isn't supported by science. Preventable medical errors are a good objective measure of competence. Although I agree with you that there aren't many good standardized measures of a physician's 'competence'. Patient outcomes is one, if that's what we're getting at - and I'm not doubting that prescribing psychologists can help people, because psych meds work, and in the vast majority of patients many of the most commonly prescribed meds are well-tolerated. But patient safety in those off-cases is the main critique of Rxp from the medical standpoint.
I would say that that bar is determined by employers who can stomach only so many errors, or a lawyer suing the physician.
2) I will point out that I initially stated my reservations, noting that discussion is frequently not held in good faith. You asked about evidence, and I gave you a fairly good narrative review from an independent party. You have since offered several opposing ideas with have zero data. I have pointed out that you are using a shifting metric, and shifting arguments ,that are not defined by anything other than your sentiment. Despite your conflation of things and incorrect description of standard of care, what we are licensed to do has nothing to do with standard of care or employers. You're also saying that the a physician that was trained without computer access with the idea that peptic ulcers were caused by stress has the same basic skill set as a surgeon in his 30s. And if he doesn't, then he still doesn't need formal remedial training.
This is the problem with this discussion: It ALWAYS starts off under the pretext of an honest exchange and devolves into a bad faith argument. "It's about X concern! And if that concern is disproved, then it's about something else. And if that is wrong, then it's about something else.". It's a bad faith argument, and bad science.
The vast majority, if not all, states require physician collaboration for practice of RXP. I am not an expert but I don't know of any state that does not require physician collaboration. That said in 27 states and DC, the standard of care is an independent NP. Psych NPs can also practice psychotherapy. The irony is, opposing us will likely strengthen NP numbers.
I would certainly steer someone to NP school based on costs, time in schooling, and what the license allows. We require more schooling for a more restricted license.
That's a fair argument. In an ideal world we would have enough physicians who can prescribe mental health medications to address America's mental health crisis. I believe that both NP's and Rxp are very well-intentioned means to addressing that end, it just makes me uncomfortable because I'm not sure the pro's outweigh the risks.
I didn't say completely. You're ok with PA practice, correct? I'm saying that RxP would function similar to that. I'll grant there are still risks, but I'd wager it's are the same amount of risk in PA practice. You can even make a case than it's more minimal considering that we are content experts in mental health in ways that PAs are not experts in medicine.
I am okay with PA's practicing under physicians. But to say that the risk of letting psychologists is the same is not accurate. PA's are medically trained, even though they do less training in medicine than physicians. They receive essentially the same (but abridged) medical education physicians do, and although they do not have to do residency, many psych PA's do postgraduate fellowship or residency in psychiatry.
Again, this speaks more to my earlier point that the risks with medication prescribing is not about expertise with mental health, but expertise in medicine and monitoring the medical side effects of these medications.
The real area of anxiety, for me at least (and I think for you too), would be prescribing a substance that has unknown effect on another body system or interact with another chemical in a manner that I am unfamiliar or could not have anticipated. I don't feel at all incompetent in my ability to diagnose a mental health condition, which can't be said for many who do prescribe these medicines. Germane to cardiac events mentioned upthread, misdiagnosis of ADHD, which is rampant, does carry that risk.
I think the real, and more important question lies in our confidence in the MSCP program. Can it train psychologists to function as well as PAs or could it train psychologists to function as well as dentists in relation to prescribing medication? You mentioned upthread that you're unconvinced the MSCP program could effectively do this and I think this is an area where I am more likely to agree. I have reservations about two-year online program's ability to teach me what I really need to know to practice effectively, even under supervision. But I'm open to being convinced otherwise.
I agree with most of what you said here, and would add that I do believe psychologists have more knowledge about diagnosing mental health conditions compared to primary care physicians. I would also add that many PCP's refer to psychiatry (depending on access) once the first 1 or 2 SSRI's don't work or for the management of bipolar or psychotic disorders entirely. It's all about understanding the limits of your knowledge and expertise.
I will point out that I initially stated my reservations, noting that discussion is frequently not held in good faith. You asked about evidence, and I gave you a fairly good narrative review from an independent party. You have since offered several opposing ideas that have zero data. I have pointed out that you are using a shifting metric, and shifting arguments ,that are not defined by anything other than sentiment. That is what I predicted initially. Despite your conflation of things, what we are licensed to do has nothing to do with standards of care or employers.
I read through that review you cited and reviewed all of the studies (those not behind a paywall) it mentioned as evidence for the safety of Rxp and its effects on suicide rates. I then offered measured criticisms of the evidence (many of such evidence were not any sort of study at all, but rather blog posts or magazine articles). I had thought you had read through these studies since you were the one who shared this review with me, and would then respond to my criticisms in 'good faith'. Now I'm starting to think you didn't click on any of those studies yourself.
And I feel like I've been pretty consistent that my chief concern is patient safety, which by the way is absolutely related standards of care when you are opening yourself up to liability for practicing medicine- something traditionally outside the scope of psychologists.
You're also saying that the a physician that was trained without computer access with the idea that peptic ulcers were caused by stress has the same basic skill set as a surgeon in his 30s. And if he doesn't, then he still doesn't need formal remedial training.
Who said that?
This is the problem with this discussion: It ALWAYS starts off under the pretext of an honest exchange and devolves into a bad faith argument. "It's about X concern! And if that concern is disproved, then it's about something else. And if that is wrong, then it's about something else.". It's a bad faith argument, and bad science.
Well, I'm still not sure if any of the concerns about safety have been disproven. I don't think we're at the 'something else' part yet of this argument you've imagined.
If it wasn't obvious how I felt about this exchange between you and I, I'm not sure how you can try to pigeonhole my opinions into this preconceived framework of discussion you may have seen other users on this forum abide by, and then accuse me of arguing in bad faith in the same breath. I do apologize if I've come across as dismissive of mental health training. That was absolutely not my intention. and I did come to discuss this in good faith and I have already learned a lot from this discussion.
I think our end goals are the same in that we want the best for patients and mental health in this country. Our disagreement is the ways in which we get there. Could we at least level there?
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Sanman
O.G.
That's a fair argument. In an ideal world we would have enough physicians who can prescribe mental health medications to address America's mental health crisis. I believe that both NP's and Rxp are very well-intentioned means to addressing that end, it just makes me uncomfortable because I'm not sure the pro's outweigh the risks.
I am okay with PA's practicing under physicians. But to say that the risk of letting psychologists is the same is not accurate. PA's are medically trained, even though they do less training in medicine than physicians. They receive essentially the same (but abridged) medical education physicians do, and although they do not have to do residency, many psych PA's do postgraduate fellowship or residency in psychiatry.
Again, this speaks more to my earlier point that the risks with medication prescribing is not about expertise with mental health, but expertise in medicine and monitoring the medical side effects of these medications.
This is where your argument falls on its face. You are okay with PAs practicing supervised after two years of training but not psychologists with a doctorate and two additional years of prescribing training? I have publications in psychophysiology. How many physicians can even say that?
That makes no sense.
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This is where your argument falls on its face. You are okay with PAs practicing supervised after two years of training but not psychologists who a doctorate and 2 additional years of prescribing training?
That makes no sense.
PA's receive substantially more formal medical education than psychologists. Prescribing training, although helpful, is not the same as medical training. If I have a doctorate in English, that does not make me as qualified to administer psychotherapy as you. And I've also said multiple times now that I generally agree with psychologists prescribing with physician supervision.
It also wasn't really an argument, it was a point about how the risks are different because PA's learn a hell of a lot more about medicine and the human body than prescribing psychologists before either of them are licensed to prescribe.
Sanman
O.G.
PA's receive substantially more formal medical education than psychologists. Prescribing training, although helpful, is not the same as medical training. If I have a doctorate in English, that does not make me as qualified to administer psychotherapy as you. And I've also said multiple times now that I generally agree with psychologists prescribing with physician supervision.
It also wasn't really an argument, it was a point about how the risks are different because PA's learn a hell of a lot more about medicine and the human body than prescribing psychologists before either of them are licensed to prescribe.
The problem here is that I don't think you are very familiar with the breadth of psychology training. Many of us here have years of neuroanatomy and neurophysiology training. We didn't cover obstetrics, so call the PA if you need to deliver a baby. However, something tells me that is not relevant to the discussion here and that training time is not relevant to mental health practice short of a discussion of post-partum depression.
The problem here is that I don't think you are very familiar with the breadth of psychology training. I have more many of us here have years of neuroanatomy and neurophysiology training. We didn't cover obstetrics, so call the PA if you need to deliver a baby. However, something tells me that is not relevant to the discussion here and that training time is not relevant ro mental health practice.
I think the problem here is that you are not comprehending that these medications affect far more things than just the brain. I acknowledge that expertise in mental health diagnostics is very relevant and helpful for prescribing psychiatric medications, and that you are the experts when it comes to how the mind works. But that is only a piece of the puzzle and not helpful for understanding the harmful sequelae that can arise from these medications.
Again, the question for me is: are two years of MSCP enough medical training to understand things that require several years of education to have a decent understanding of?
Explain the consistency between your cited concerns of:That's a fair argument. In an ideal world we would have enough physicians who can prescribe mental health medications to address America's mental health crisis. I believe that both NP's and Rxp are very well-intentioned means to addressing that end, it just makes me uncomfortable because I'm not sure the pro's outweigh the risks.
I am okay with PA's practicing under physicians. But to say that the risk of letting psychologists is the same is not accurate. PA's are medically trained, even though they do less training in medicine than physicians. They receive essentially the same (but abridged) medical education physicians do, and although they do not have to do residency, many psych PA's do postgraduate fellowship or residency in psychiatry.
Again, this speaks more to my earlier point that the risks with medication prescribing is not about expertise with mental health, but expertise in medicine and monitoring the medical side effects of these medications.
I agree with most of what you said here, and would add that I do believe psychologists have more knowledge about diagnosing mental health conditions compared to primary care physicians. I would also add that many PCP's refer to psychiatry (depending on access) once the first 1 or 2 SSRI's don't work or for the management of bipolar or psychotic disorders entirely. It's all about understanding the limits of your knowledge and expertise.
I read through that review you cited and reviewed all of the studies (those not behind a paywall) it mentioned as evidence for the safety of Rxp and its effects on suicide rates. I then offered measured criticisms of the evidence (many of such evidence were not any sort of study at all, but rather blog posts or magazine articles). I had thought you had read through these studies since you were the one who shared this review with me, and would then respond to my criticisms in 'good faith'. Now I'm starting to think you didn't click on any of those studies yourself.
And I feel like I've been pretty consistent that my chief concern is patient safety, which by the way is absolutely related standards of care when you are opening yourself up to liability for practicing medicine- something traditionally outside the scope of psychologists.
1) Patient safety (again, evidence is presented compared to your speculation, despite elementary school basics of the null hypothesis. "These omissions are glaring because over 30 years of research — including studies from the US Department of Defense and various jurisdictions that have enacted RxP — show that prescribing psychologists perform safely, effectively, and within scope (Hughes, Niznik, et al. 2025a; Kaylor and Gallios 2025; Peck et al. 2021; Wiggins and Cummings 1998). Available data show that prescribing psychologists pose no greater risk to patient safety than psychiatrists, underscoring comparable standards of care. In fact, evidence demonstrates comparable or superior safety relative to other non-physician prescribers based on research and malpractice data (Curtis et al. 2023; Younger 2012)" But thanks for telling me that I imagined that. )
2) Medical errors (I think you're unaware of the IOM and ICD meaning of this term, but it's not how you're using it)
3) Patient Outcomes (If you are suggesting that medications' efficacy rates change because of who prescribed them, you need to contact the FDA today)
4) Your own comfort (immeasurable)
5) Employer preference (somehow you're conflating the ability to legally perform a professional task with how employers feel about that)
6) Standard of care (a locally defined issue, related to medmal)
Those are all separate issues. And you're quickly shifting the issues.
2) You literally said "And you're right - it's not fully about formal coursework, but a physician who was trained in the 50's learned the fundamentals of human anatomy, physiology, and pathology, and had years of training treating patients in a hospital before they were an attending." That age group is before Barry Marshal won the Nobel Prize in 2005, and you don't think that everyone needs formal education after that. So tell me how I am wrong.