APA Model Licensure Task Force
c/o Practice Directorate – Attn: Lynn Bufka, PhD
American Psychological Association
750 First Street, NE
Washington, DC 20002-4242
Dear Model Licensure Act Task Force Members:
As a member of the California Association of School Psychologists (CASP) I request that
the Task Force reinstate the exemption for school psychologists in the APA Model Act
for State Licensure of Psychologists. This long-standing provision provides an exemption
to the licensure act for school psychologists who are appropriately credentialed by their
respective state board of education to hold the title “school psychologist” and to practice
independently in school settings.
School psychologists at both the specialist and doctoral levels have practiced
independently in schools since the 1950s. Removal of the exemption has potentially
serious implications for the status of all school psychologists’ credentials – those at the
doctoral level as well as those at the specialist level. For example, changes in the
jurisdiction of credentialing from the California Commission on Teacher Credentialing to
the State Board of Psychology (under the jurisdiction of the state Department of
Consumer Affairs) possibly would:

Create an incongruent credentialing system in which school psychologists would
work under licensure regulations intended for the independent practice of
psychology, not the public practice of school psychology in school settings. For
example, I hold a Pupil Personnel Services credential, with emphasis in school
psychology, from the Commission on Teacher Credentialing, which also
credentials all certificated school personnel. The State Board of Psychology has
no jurisdiction over this commission.

Increase substantially the yearly cost of credentialing and make credentialing for
public service prohibitive for many school psychologists working in the schools.
Only three universities in California offer doctoral degrees in school psychology,
one is a private institution and the other two are in the University of California
system. Most school psychologists in California receive their degrees from the
California State University system, a lower-cost alternative to UC, that offers
excellent programs.

Impose continuing professional development requirements developed originally
for private practice clinical psychologists and not necessarily appropriate to
school-based practice.

Unnecessarily confuse the public and other stakeholders about the provision of
school psychological services at a time when standards for training and practice
are well-established and being broadly implemented.
The California Association of School Psychologists, many Special Education Local
Planning Agencies (SELPAs), school districts and the National Association of School
Psychologists all offer excellent continuing education programs. Most school
psychologists take advantage of these learning opportunities to enhance their skills and
to keep up with the latest best practices.
Please also take into consideration that school psychologists’ wages are more in line
with teachers than with psychologists, with or without licenses. If school districts were
forced to only hire psychologists with doctoral degrees to practice school psychology,
there could be a shortage of qualified personnel, especially in these days of the declining
economy.
The school psychology exemption has been a part of the APA model licensure act for
over 30 years and has served the public interest well. There is no public benefit to
removing it now. Specialist level school psychologists provide quality, evidence-based
services and make significant contributions to the children and families. Ample
protections already exist to ensure the quality of services provided by school
psychologists credentialed by the California Commission on Teacher Credentialing.
Removing the exemption actually poses real harm to children, families, and schools by
putting at risk the availability of school psychological services.
Consider all the implications the cancellation of the exemption for school psychologists
in the MLA could cause. Please reinstate the licensure exemption for school
psychologists.
Sincerely,