Trying to summarize
state licensure laws for
psychologists: Burial by
grains of salt
Mollie Herman
Nathan Sharer
Presented by Mollie Herman at the annual ACCTA
conference, Baltimore, 2012
Special thanks to:
 Sarah Armstrong, Cheryl Blank, Cyndy Boyd, Cindy
Bruns, Daniela Burnworth, Brigid Cahill, Maria CarrubaWhetstone, Paul Castelino, Jane Clement, Rhandi Clow,
Julie Corkery, Kathlyn Dailey, Kristen Davis-Johnson,
Harriet Dickey-Chasins, Glade Ellingson, Pamela Epps,
Betty Fletcher, Mark Forest, Tricia Hanley, Bruce Herman,
Chris Hogan, Merris Hollingsworth, Karen Lese-Fowler,
Peter Liggett, Jenny Lybeck-Brown, Keith Magnus, Joan
Mizrahi, Rosemary Nicolosi, Jennifer Petro, Julia Phillips,
Jeanne Piette, Emil Rodolfa, Felix Savino, Daniel Schulte,
Andrew Shea, Meredith Shefferman, Tawa Sina, Joy
Stephens, Karen Taylor, Jod Taywaditep, and Brett
Vicario
The Tenth Amendment to the US
Constitution (part of the Bill of
Rights)
 Ratified December 15, 1791
 The powers not delegated to the United States by the
Constitution, nor prohibited by it to the States, are
reserved to the States respectively, or to the people.
 Licensing = state power
Licensure laws vary on numerous
dimensions:
 Number of hours of experience required for licensure
 What proportion of those hours must be predoctoral
versus postdoctoral (with some states requiring no
predoctoral hours, others requiring no postdoctoral
hours, and still others requiring 2000 hours of each),
 Whether internship and / or postdoctoral supervisors
need to have been licensed for a specified amount of
time
 Whether interns or postdocs need a certain number of
direct service hours
 If and how direct service is defined
Other professions
 Lawyers: 28 states do not have reciprocity agreements
(Black, 1994)
 Doctors: frustration about licensure mobility, esp with
new technologies like telemedicine (Silverman, 2000)
Psychology’s efforts to ease
mobility: The EPPP
 ASPPB developed the EPPP – first used in 1965
 General agreement that licensure requirements should
include:
 two years of supervised experience
 doctoral degree
 pass the EPPP
But the EPPP does not solve the
problem of….
 Differences in state laws regarding education and
experience requirements for licensure eligibility
Other efforts by ASPPB:
Agreement of Reciprocity
 State accepts another state’s determination of licensure
eligibility regardless of different requirements
 In the 15 years of the Agreement of Reciprocity’s
existence, only 12 jurisdictions have joined
Other efforts by ASPPB: The CPQ
 Certificate of Professional Qualification (1998) 1998
(ASPPB, 2010a)
 Meet certain educational and experience qualifications
 Licensed in the US or Canada
 In practice for at least five years
 No history of disciplinary action
 they can apply for a CPQ
 Can apply for CPQ which facilitates licensure in states
that accept the CPQ (so far 52 of ASPPB’s 63
jurisdictions)
 Not universally accepted
 Need 5 years experience
Other efforts by ASPPB:
 Inter-Jurisdictional Practice Certificate (IPC)
 temporary care across state lines
 But doesn’t address issue of non face-to-face treatment
made possible by technological advances
Problems still persist
 Example: Maryland allows immediate licensure
 Pennsylvania requires 1 year of postdoctoral
experience… BUT
 Pennsylvania will not count supervision that has been
paid for
Even ASPPB and APA disagree…
 In their respective model licensing acts:
 APA recommends 2 full time years of professional
supervised experience, both of which can occur before
degree is granted
 ASPPB recommends that 1 year occur after degree is
granted
How the project got started
Phase I Procedure
 Recruited ACCTOIDS from the listserv
 35 people from numerous states (including this paper’s authors)
investigated 50 states plus DC
 Each researcher was provided with a questionnaire and was asked to
 look at the Handbook of Specific Licensure Requirements by State hosted
on the ASPPB website and state psychology licensure websites
 contact the state licensing boards for clarification of discrepancies or to
provide information that was omitted
 email the completed questionnaire to the authors.
 Complete a brief Survey Monkey survey
Phase I Questionnaire
 State:
 Total hours required for licensure:
 Minimum / maximum years permitted to accrue hours:
 Is internship required by law:
 Is there a specific number of hours required from INTERNSHIP? (Yes / No)
 If yes, total required from internship:
 APA-accreditation requirements for internship? (Yes/No)
 Are there a specific number of POSTDOCTORAL hours required? (Yes / No)
 If so, total required from postdoctoral experience:
 Can you count non-internship predoctoral hours:
 Specific percent of internship experience required to be direct service?
 Definition of direct service (If applicable):
 Supervisor requirements (e.g. must supervisor be licensed in the state in
which the activity occurs; must the supervisor have been licensed for a
specified period of time; etc.):
 Any other particular requirements or important facts:
Enter… Phase II
 As completed questionnaires came in and authors
compared them to ASPPB Handbook and state websites,
quickly became clear that everything was UNCLEAR
 Many of the regulations were confusing and could be
interpreted in different ways
 Also, some items from the Phase I questionnaire were
open to interpretation
Phase II Procedure
 Additional volunteers recruited from ACCTA (and one
extremely dedicated member stayed on from phase I! –
thanks, Sarah!)
 Also invited TUCC staff to help out
 Ten researchers investigated 50 states plus DC
 Repeated the first two steps in phase one and then
checked their findings against phase one findings

Tried to rectify discrepancies with further research
 Completed Survey Monkey survey for each state
researched
 Phase II Questionnaire:

State:

Total hours required for licensure:

Can you count predoctoral hours (including internship)toward the licensure hours requirement?
(Yes/No)

What are the minimum number of hours required for internship? (Total/None/Not-specified)

How many internship hours can you count toward licensure requirements? (Total/None/Not-specified)

How many NON-INTERNSHIP, PREDOCTORAL hours (e.g. externship, practica) can you count toward
licensure hours? (Total/None/Not-specified)

Is there a time limit specified in which to accrue predoctoral hours for licensure? [Yes (Min/Max)/No]

Is internship required by law: (Yes/No)

Does internship have to be APA or CPA-accredited? (Yes/No)

If no, are other specifications listed? (e.g. meet APPIC standards, meet standards of state board; be
acceptable to doctoral program):

Internship supervisor must be licensed in jurisdiction in which supervision takes place? (Yes/No)

Internship supervisor must have been licensed for a specified amount of time?[Yes (how long)/No]

Specific percent of internship experience required tobe direct service?

Definition of direct service (If applicable):

Are there a specific number of POSTDOCTORAL hours required? (Yes/No)

Postdoctoral experience supervisor must be licensed in jurisdiction in which supervision takes place?

Postdoctoral experience supervisor must have been licensed for a specified amount of time?

What percentage of postdoctoral experience must be supervised by a psychologist meeting the
requirements stated above? (Percent)

Specific percent of postdoctoral experience required to be direct service?

Definition of direct service (if applicable)
Where the direction changed…
 One author (me) double-checked all submissions for
consistency with ASPPB Handbook and state laws.
 About 10 states into this process, I gave up
 Endless loop: doing research, becoming confused, seeking
clarification, making a decision, and then, upon doublechecking, becoming confused again.
Mission Impossible
 This was the point at which the authors decided that gathering
truly accurate information about state licensure requirements
for psychologists was impossible.
 Mission changed: tell the story
Summary of licensure laws
 Sent around on ACCTA
 Mistakes found within minutes of sharing
 Mixed feelings about sharing – so many inaccuracies
Results: Responsiveness of
licensing boards
 35% in Phase I and 14% in Phase II attempted to
contact the state board
 Mostly, licensing boards responded quickly;
 but in phase one, 19% never heard back from the board
 in phase two, 19% had to wait over two weeks for a
response, and another 19% never heard back
 Some difficulties reaching the board: broken links on
ASPPB website, wrong contact provided
Results: Helpfulness of licensing
boards
 In phase one, 21% , and in phase two, 72% of
researchers remained confused after communicating
with the board
 Comments about contact with boards:
 quick responses, patient listening, thorough feedback
 “vague”, “confusing”, and “inconsistent” responses
 My experiences with Maryland
Results: Discrepancies
between ASPPB Handbook
and state websites
 Something weird
 Approximately 50% of the researchers in Phase one found
discrepancies.
 Approximately 30% of the researchers in Phase two found
discrepancies
 They were all looking at the same information
 There were discrepancies in identifying discrepancies!
Results: More discrepancies
 Nearly 50% of phase two researchers found
discrepancies between their own findings and those of
the phase one research.
 What this means: Two professionals (many with licenses
in the states they were researching) were presented
with the same licensure law data and…
 half the time
came to different conclusions
about what the law stated.
Places where discrepancies were
most frequently found between
phases I and II
 Number of hours required for licensure
 Whether pre-doctoral hours count toward licensure
 Whether an internship is required
 State law changes not reflected on ASPBB’s website
 Whether a supervisor needs to be licensed (as well as
where and for how long)
 Time limits to accrue hours.
Respondent comments about
doing this research.
 60 responses
 overwhelmingly negative
 most frequent words:
 “difficult”
 “frustrating”
 “time consuming”
 Other words:
 “tedious”
 “unclear”
 “uncertain”
But not universally bad
 Approximately 30% of the respondents who left
feedback reported that the process for their state was
not very taxing and that resources were helpful
 There are clearly differences between states regarding
accuracy and accessibility of information
Implications of this mess
 Costs to the public
 Restricts availability of mental health services – even if you live
on the border of a state, can’t necessarily seek help from
someone a few miles away
 Difficulty with emergency resources in case of disasters
 Obstacles to telepsychology and other new technologies
 Costs to professionals
 Trainees can go crazy trying to figure this stuff out
 Training programs can go crazy trying to figure this stuff out
 Psychologists who wish to relocate or expand their practices can
encounter bureaucratic obstacles
 Seemingly arbitrary differences can have enormous impact on
the ability of professional psychologists to practice where they
want to practice
Recommendations: 3 levels
 Ascend in realism, descend in degree of solving the problems
 1. Dream: would solve the problems, but unlikely to happen
 2. Improvements: could be within reach, but not without a lot of work
 3. Coping: manages the current problem
The DREAM….
 Nationally accepted standard for psychology licensure.
 all states agreed to adopt a common standard for
psychology licensure (with each state having option of state
jurisdictional exam)
 Use evidence to establish this national standard
 Research regarding the number of hours and what types of
experiences are needed for minimum competency. (e.g.
currently: Iowa requires 1500 hours of experience; Florida
requires 4000; any differences in their outcomes?)
The Improvement Level
 State boards provide thorough, accurate, and up-to-date
information about their licensure laws
 Consistent and easily navigated design for state board
websites
 ASPPB Handbook is also accurate and up-to-date and
expands to include:
 Restrictions on eligible supervisors based on their years of
licensure
 Whether a state has particular requirements for the proportion
of experience that is direct service
 State board representatives be better informed of the
issues related to psychologist licensure in their state
 Allows them to accurately complete ASPPB questionnaires for
handbook
 Allows them to respond effectively to direct inquiries
The Coping Level
 Maintain healthy skepticism about licensure information;
get information in writing
 Trainees make conservative choices regarding how and
when they gain professional experiences
 Whenever possible, choose internship supervisors who have
been licensed for at least three years
 Obtain similar postdoctoral supervision
 Doctoral training programs and internship sites provide
informed consent about licensure issues to potential
students and interns
FROM 2012 ACCTA SURVEY: Supervisors
Required to be Licensed for…
FROM 2012 ACCTA SURVEY: If there are no
restrictions on how long supervisors must
have been licensed…
64% provide advance warning to interns
about potential complications related to
licensure eligibility
36% do not
Discussion
 Reactions?
 How do people handle this at their sites?
 Has anyone had any problems with interns getting
licensed elsewhere?
 Any other strategies come to mind to address the
problems?
References
 American Psychological Association (2010). Model Act for State Licensure of
Psychologists
 Adopted by Council as APA Policy 2/20/2010. Retrieved from
http://www.apa.org/about/policy/model-act-2010.pdf
 Association of State and Provincial Psychology Boards (2010a). ASPPB Model Act for
 Licensure and Registration of Psychologists. Retrieved from
http://www.asppb.net/files/Final_Approved_MLRA_November_2010.pdf
 Association of State and Provincial Psychology Boards (2010b). Obtaining a License.
Retrieved from http://www.asppb.net/i4a/pages/index.cfm?pageid=3390
 Association of State and Provincial Psychology Boards (2010c). The Association of
State and Provincial Psychology Boards (ASPPB) Handbook of Licensing and
Certification Requirements. Retrieved from
http://www.asppb.org/HandbookPublic/HandbookReview.aspx
 Black, A. (1994). Canadian lawyer mobility and law society conflict of interest.
Fordham
 International Law Journal, 18, 1.
 Commonwealth of Pennsylvania (2012). Supervisor requirements. Retrieved from
http://www.pacode.com/secure/data/049/chapter41/s41.33.html
 DeMers, S. T., Van Horne, B. A., & Rodolfa, E. R. (2008). Changes in training and
practice of psychologists: Current challenges for licensing boards. Professional
Psychology: Research And Practice, 39(5), 473-479. doi:10.1037/0735-7028.39.5.47
 Hess, H. F. (1977). Entry requirements for professional practice of
psychology. American Psychologist, 32(5), 365-368. doi:10.1037/0003-066X.32.5.365
 Marques, T. (2012). Europe overhauls physician mobility regulations. Canadian Medical
Association Journal , 184(3), E169-E170.
 Missouri General Assembly. (2011). Missouri Revised Statutes Chapter
337 Psychologists—
 Professional Counselors--Social Workers Section 337.025. Retrieved from
http://www.moga.mo.gov/statutes/C300-399/3370000025.htm
 National Council of State Boards of Nursing. (2012). Nurse Licensure Compact.
Retrieved from https://www.ncsbn.org/nlc.htm
 New York State Education Department. (2009). Regulations of the Commissioner.
Retrievedfrom http://www.op.nysed.gov/prof/psych/part72.htm
 Reaves, R. P. (2006). The History of Licensure of Psychologists in the United States and
Canada. In T. J. Vaughn (Ed.), Psychology licensure and certification: What students
need to know (pp. 17-26). Washington, DC US: American Psychological Association.
doi:10.1037/11477-002
 Rodolfa, E., Ko, S. F., & Petersen, L. (2004). Psychology Training Directors' Views of
Trainees' Readiness to Practice Independently. Professional Psychology: Research And
Practice, 35(4), 397-404. doi:10.1037/0735-7028.35.4.397
 Schaffer, J.B. & Rodolfa, E.R. (2011). Intended and unintended consequences of state
practicum licensure regulation. Training and Education in Professional Psychology, 5(4),
222-228.
 Silverman, R. (2000). Regulating medical practice in the cyber age: Issues and
challenges for state medical boards. American Journal of Law & Medicine, 26(2-3),
255-276.
 Tracy, E.N., bucchianeri, M., & Rodolfa, E.R. (2011). Internship hours revisited: Further
evidence for a national standard. Training and Education in Professional Psychology,
5(2), 97-101.