What happens if you don’t reach 25% of your internship hours as direct client contact?

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Hey all. Coming from an anxious intern, i have a site where I am not particularly close to 25% hours from a site being direct client contact hours, as opposed to support or supervision hours.

The state in which I am planning to be licensed, Washington, has the following criteria under thier definition of internship per statute. This is:

“(ii) Content of the internship program.
(A) The internship must be designed to provide a planned sequence of training experiences focusing on breadth and quality of training. Supervision and training related to ethics must be ongoing.
(B) At least twenty-five percent of the internship experience must be in direct client contact providing assessment and intervention services.”

This is making me nervous. I have agitated for more direct client contact opportunities but change has been slow. I’m assuming the state licensure board would not just call an internship invalid without this breakdown in direct hours, but realistically, what happens when a person does not achieve this ratio during an internship? Can that lead to problems with licensure?

If it helps:
-The site is accredited, and
-I do plan to do a postdoc

Thank you for your help!

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When I doubt about licensure, I think it’s good practice to reach out to that specific board and ask questions since they ultimately make licensure granting decisions.

I’m not familiar with WA specifically but it seems like postdoc hours might be able to fill in previous gaps? But this is a total guess that your board can clarify.

Internship​

Applicants must complete an internship as part of the doctoral degree program. The internship must include at least 1,500 hours of supervised experience and be completed within 24 months. The internship program must be accredited by the American Psychological Association; or be a member of the Association of Psychology Postdoctoral and Internship Centers. If the program is not accredited by the APA or APPIC member, it must meet the requirements listed in WAC 246-924-056.

Post-doctoral supervise experience​

If 3,000 hours of supervised experience have not been completed at the end of the doctoral degree program, then up to 1,500 hours of supervised post-doctoral experience that meets all requirements in WAC 246-924-059 may be used to satisfy the 3,000 hours requirement. Post-doctoral supervised experience must be completed only if an applicant does not already have 3,000 hours of supervised experience.
Assuming you have a standard 2000ish hour 12 month full time internship, that would put you at needing ~500 direct hours. Or in other words, ~40 direct hours per month/~10 hours per week/~2 hours per day.

What were your numbers for Oct, Nov and Dec? Some internships can start slow but if you’re still well below 10 hours per week, you must have a lot of free time on your hands (in a bad way).
 
When I doubt about licensure, I think it’s good practice to reach out to that specific board and ask questions since they ultimately make licensure granting decisions.

I’m not familiar with WA specifically but it seems like postdoc hours might be able to fill in previous gaps? But this is a total guess that your board can clarify.

Assuming you have a standard 2000ish hour 12 month full time internship, that would put you at needing ~500 direct hours. Or in other words, ~40 direct hours per month/~10 hours per week/~2 hours per day.

What were your numbers for Oct, Nov and Dec? Some internships can start slow but if you’re still well below 10 hours per week, you must have a lot of free time on your hands (in a bad way).
Ahh that’s a good point, I didn’t know that I was able to reach out to the licensing board directly for questions. I’ve also reached out to my DCT to see about how that process might work as well.

So, my track at my site is primarily focused around evaluations, but there is often lag time between the evaluation for report writing, sometimes more so than is necessary. I am averaging about 7 to 8 hours of direct client contact per week, with a bit of a gap in July and August as the program got up and running. Many opportunities for direct client contact unfortunately have been referred to other interns on less evaluation-centric tracks which has unfortunately created a gap among interns and how they are doing in direct client hours. Requests for more therapy opportunities or opportunities for direct contact have been heard but are slow moving, which is difficult as administration handles the referral process for individual clients.
 
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7-8 face to face hours a week?!? That is ridiculous from the site. How are you not bored out of your mid. We did 20-25 hours a week as VA interns and were still somewhat bored. I would definitely report back to your doctoral program about this place so they know.

This needs to be addressed by administration, as there is little to no reason for this. Also, unless you are in a super saturated area, I am mystified as to how there is not a waiting list for the services. Are their supervisors that you feel you can bring these issues up to and see if they can rattle the cage higher up? This would be something that would threaten accreditation if it's a longer term, systemic issue.
 
You've taken the right steps by talking to your DCT. What did they say when you asked about whether you will have enough hours to meet the 25%?

Washington - Psychology License Application

All the questions are "Yes" and "No" so if you're DCT is agreeing to sign off on your hours, it should be fine. You're at an APA-accredited site, so I assume it should meet the minimal requirements. The application asks for a brochure or letter to document the requirements, which you'll be able to provide. Boards look at your application and what your supervisors are signing off on, and not specifically a break-down of your numbers.

I wouldn't reach out to the board just yet, I personally be worried about setting off red flags (my own paranoia, LOL). Depending on what type of site you can look at taking on some more intakes, on-call/triage, assessment, groups, etc.
 
You've taken the right steps by talking to your DCT. What did they say when you asked about whether you will have enough hours to meet the 25%?

Washington - Psychology License Application

All the questions are "Yes" and "No" so if you're DCT is agreeing to sign off on your hours, it should be fine. You're at an APA-accredited site, so I assume it should meet the minimal requirements. The application asks for a brochure or letter to document the requirements, which you'll be able to provide. Boards look at your application and what your supervisors are signing off on, and not specifically a break-down of your numbers.

I wouldn't reach out to the board just yet, I personally be worried about setting off red flags (my own paranoia, LOL). Depending on what type of site you can look at taking on some more intakes, on-call/triage, assessment, groups, etc.

Personally, I wouldn't assume, that could lead to the applicant perjuring themselves on the application. Especially as they know that they are not meeting specific requirements. I'd want the issue resolved, as there is still a good deal of time left so they do not have to put themselves in that situation.
 
Personally, I wouldn't assume, that could lead to the applicant perjuring themselves on the application. Especially as they know that they are not meeting specific requirements. I'd want the issue resolved, as there is still a good deal of time left so they do not have to put themselves in that situation.
Agreed. Not only is there time to correct things but more importantly, it will help the OP with their internship experience to get more clinical experience.

Talking to your DCT is a good first step since sometimes they can advocate for you in a different way.

I think it's harmless to talk to a board & I doubt anybody has the time to track hypothetical questions with actual applications in 1.5 years time. If you're super paranoid, maybe create a fake Gmail?
 
7-8 face to face hours a week?!? That is ridiculous from the site. How are you not bored out of your mid. We did 20-25 hours a week as VA interns and were still somewhat bored. I would definitely report back to your doctoral program about this place so they know.

This needs to be addressed by administration, as there is little to no reason for this. Also, unless you are in a super saturated area, I am mystified as to how there is not a waiting list for the services. Are their supervisors that you feel you can bring these issues up to and see if they can rattle the cage higher up? This would be something that would threaten accreditation if it's a longer term, systemic issue.
We are, to some extent. In an abundance of caution I am being vague, but i am at a generalist site with forensic positions, of which I am in one. So most of the focus is on brief assessments (on average, 2 hours, with many that have refused the evaluation and thus became purely non-face-to-face) that have detailed reports, and there is an abundance of didactics and other activities which, while valuable, do not count as face-to-face hours. Supervisors I trust have brought up issues but referrals have been slow going. Some of the reactions have made me feel like this may be more typical of those in forensic positions, but either way, it is concerning to me as i’m not working with that much information.

No word yet back from my DCT. I will send a message to the licensing board today and update this thread when I hear back from an authority source, just in case future interns turn this thread up on a search. I am going to do whatever I can to get those direct hours up, so that hopefully this becomes a moot issue, but there’s only so much within the control of the intern.

Thank you all! This is an odd problem but your perspectives have made it feel much less like the death knell of my doctorate.
 
This is definitely something your DCT, and potentially rotation supervisor(s), should be actively monitoring. If an intern is short a few months into internship, I'm not terribly worried, but I am trying to problem-solve ways to get them caught up without over-burdening them (assuming the reason for the low hours in on the site's side and not the intern's). If the intern only has a couple months left, I'm more worried and am working with their rotation supervisor(s) to get a solid course of action in place.

A lot can also depend on the rotation. I've seen rotations where it's not unheard of to only end up with 7-8 direct contact hours per week for multiple weeks due to a variety of factors. But those interns also often end up with other more contact-heavy rotations (e.g., 20 direct contact hours/week) to make up for it.
 
I was in a similar boat on internship. It took some special circumstances, but nothing crazy. 0.5 day didactics, 0.5 days research, 1.5 days secondary rotation involving treatment dissemination & implementation (so technically no client hours). Remaining 2.5 days were outpatient substance use treatment with a forensic population. Exceedingly high no-show rate, very difficult to maintain a caseload because of frequent re-arrest, etc. I didn't think to track my hours during that time, but I'm sure when you factor in ramp-up/ramp-down time, holidays, PTO, etc. it was close or "could" have been under. I was told by the DCT that "25% of the internship experience" is about the internship as a whole and not individual experiences so as long as across the internship on average the interns have large amounts of F2F they don't worry about it. Given some rotations are inpatient medical and other "captive" populations, I'm sure the average was immensely higher. That is playing a good bit faster and looser with licensure laws (and accreditation standards) than I'd feel comfortable with in their shoes, but I guess not tracking my hours gives me plausible deniability in the event I ever piss someone off enough they want to dig through EHR records from 10 years ago and do the math?

This was a name-brand AMC. This was the tip of the iceberg and I could go on and on about how bad an experience it was - I learned almost nothing clinically and actually think my clinical skills receded during the year. That said, still got licensed, etc. and hasn't held me back at all. I consider the internship the most embarrassing line on my CV and it is absolutely the most prestigious affiliation I've had.

TLDR - I'd raise the issue and push to get there because it really shouldn't be that hard, but I also wouldn't assume you are forever doomed if you have 24% at graduation.
 
This happened to me on internship. APA accredited site, so was fine in WA state (and at least one other) was just as anxious as you afterward but wound up being totally fine. VirginiaIsForLovers is correct. But also not too late to get your hours up
 
Hello all. Frankensteining this thread just to provide some resolution and for anyone out there who stumbles upon this thread through Google worried about the same situation.

So, after reaching out to my DCT and my advisor, they repeated similar messages in this thread: if you are at an APA accredited site, those on the application board will not necessarily check your hours breakdown and instead assume that you met the required 25 percent. This contrasted a bit with advice I got about being approved to sit for the EPPP in which they will request your hours, but ultimately the prevailing wisdom is that you will be okay if you do not end internship with 25% of your hours being direct client contact.

For me, it ended up being a moot issue. I cold emailed faculty not associated with the training program to shadow evaluations, asked to sit in groups, self-referred as many clients as I could juggle, and took on extra evaluations until i cleared 500 hours. So I did manage to finish with above the required 25% of direct client contact. However it seems like even if i didn’t, it wouldn’t have been a career-sinking issue.

All that said - if you find this thread from the future with Google, don’t stress too much but my internship experience was much more rewarding with the extra hours. My advice is to do what you can to get your hours up, as the quality of the training you are getting will improve, but don’t do so under the mindset that it is sink-or-swim if you don’t get them. Lastly, many sites will have many opportunities for accruing hours outside of a direct referral process. Though it is of course uncomfortable as an intern to ask for things and to agitate for more hours in ways that you worry might bristle faculty, there are tons of valuable opportunities you might miss out on if you do not ask. So consider ways to get more hours even if they are not typically things interns sit in on or do, and ask for them!
 
Glad to hear it worked out. And yes, shadowing can be a great opportunity to get additional face-to-face hours (and perspective), particularly if it involves observing non-psychology professionals. It also tends to be pretty easy and resource-unintensive for the site to setup.
 
Glad to hear it worked out. And yes, shadowing can be a great opportunity to get additional face-to-face hours (and perspective), particularly if it involves observing non-psychology professionals. It also tends to be pretty easy and resource-unintensive for the site to setup.
Yeah, shadowing was a great opportunity during internship for me as well. It was helpful to see what perspectives other providers had about the same patients and more generally how they were conceptualizing certain issues, what problems they were running into, what their priorities were, etc. I was lucky to have supervisors who were looking for these enrichment opportunities throughout the year.
 
For me, it ended up being a moot issue. I cold emailed faculty not associated with the training program to shadow evaluations, asked to sit in groups, self-referred as many clients as I could juggle, and took on extra evaluations until i cleared 500 hours. So I did manage to finish with above the required 25% of direct client contact. However it seems like even if i didn’t, it wouldn’t have been a career-sinking issue.

All that said - if you find this thread from the future with Google, don’t stress too much but my internship experience was much more rewarding with the extra hours. My advice is to do what you can to get your hours up, as the quality of the training you are getting will improve, but don’t do so under the mindset that it is sink-or-swim if you don’t get them.

I respectfully disagree. While I understand that it wouldn't have mattered in your case because someone wasn't paying attention, that's a very risky thing to count on or to recommend. There are many entities that define the requirements for successfully completing an internship: the internship program itself, the doctoral program, APA, APPIC, licensure boards, and other credentialing organizations. Any requirements for internship that are set out by these organizations are important to take seriously - even when they contradict each other. To do otherwise is an unnecessary role of the dice.

I was not so lucky with my postdoc. I did my postdoc in California under California rules at the time. I moved to Texas and attempted to get licensed, but my postdoc hours were tossed out by the Texas Board because they didn't meet one of the Board's rules at that time (the hours had to be completed consecutively, without a break in the middle). While I thought that was a ridiculous technicality, it didn't really matter what I thought -- because the Board rejected my complaints and discarded my licensure application.

I recognize my experience is about postdoc and not internship, but the point remains: You need to know the requirements (which I obviously didn't) and strictly abide by them.
 
Agreed. Different states will probably put different amounts of effort into specifically verifying individual components of the application. But even if the state doesn't verify the hours thoroughly, and even if the internship director(s)/supervisor(s) are willing to sign off on those hours, as the applicant, you're still affirming that the information on that application is correct when you know it's not (i.e., you're lying).

Thinking worst-case: if you eventually come across a state that does attempt to more thoroughly verify your hours, and/or your internship DCT switches out and isn't willing to automatically sign off on the hours, your license application could be denied. Which you then have to report on all subsequent licensure applications and renewals. In the case of the next renewal for your current license(s), this could then raise some uncomfortable questions when you have to explain why your licensure application was denied for the new state, and why that means you didn't provide false information on your application for the current state. Or if you do any forensic work and it comes up in a deposition, again, it could result in some very, very uncomfortable questioning.

Ultimately, in this case, it's a moot point, which is great. But for future trainees, even if your site falls asleep at the wheel in terms of ensuring you get your hours, I'd encourage you (like the OP here) to do everything you can to get the hours you need. And also to be proactive in looking at state(s) where you anticipate you might get licensed so that you can ensure you meet their requirements, both on internship and afterward.
 
Some advice I received, when I was an anxious intern:

“Do you really think that the board hasn't dealt with this issue before?"
 
Some advice I received, when I was an anxious intern:

“Do you really think that the board hasn't dealt with this issue before?"
I'm not sure what your point is here - but if you are saying that Boards have dealt with a lot of issues in the past and are thus willing to be flexible, I strongly disagree. (If I misunderstood your point, my apologies!). Yes, Boards have dealt with lots of issues. But Boards are not flexible, and they have no hesitation in rejecting applications that don't meet their standards.

Licensure Boards have no choice but to follow their own rules as well as State laws. When they don't, they get sued. I would never expect a Board to do anything but vigorously enforce every picky detail in State Law and their own rules and policies.
 
I'm not sure what your point is here - but if you are saying that Boards have dealt with a lot of issues in the past and are thus willing to be flexible, I strongly disagree. (If I misunderstood your point, my apologies!). Yes, Boards have dealt with lots of issues. But Boards are not flexible, and they have no hesitation in rejecting applications that don't meet their standards.

Licensure Boards have no choice but to follow their own rules as well as State laws. When they don't, they get sued. I would never expect a Board to do anything but vigorously enforce every picky detail in State Law and their own rules and policies.
Absolutely. The majority of board operations are handled by low level government employees, who are incentivized to follow the rule based rubric.

That being said:

1) The relevant legal term is "direct client contact". There are no known legal definitions for the term. OP is focused on evaluation. There is a reasonable argument to say that interpretation of psychological testing MAY count towards that. It would not be unreasonable to ask the board such a question. APPIC has a document that says time spent in interpretation is "support". However, that same document includes many other activities that count as direct client contact The published literature also has some activities that count as direct client contact, which are not immediately obvious.

2) While there are absolutely hard and fast rules, board staff usually have some discretion to kick things up to the actual board members. This is the same process as board complaints. The board members HAVE to have dealt with oddball experiences before (e.g., death of a supervisor).
 
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