Rationale for the Proposed Revisions to the Educational Requirements for Licensure as a Psychologist

Rationale for the Proposed Revisions to the Educational Requirements for Licensure as a Psychologist The WV Board of Examiners of Psychology has a rather unique perspective on the practice of psychology in this state- a perspective mandated by state law, and informed by its history of examining candidates for licensure and its ongoing interaction with comparable Boards from other states and with Association of State and Provincial Licensing Boards. The Board also has a unique set of responsibilities which center on the requirement to promote and protect the public interest and general welfare of the citizens of the state as these relate to the practice of psychology. From this vantage point, the Board believes that the public is best served through periodic reviews of and possible revisions to the law which governs professional practice. Further, the Board believes that any proposed changes to the law should be based upon patterns of evidence, not on anecdotes or characteristics of individuals, and should serve the purpose of policy development that will best serve the overall welfare of the public. The basic law governing the practice of psychology has remained unchanged since its original passage some 25 years ago. Though the sections on school psychology are more recent, parts of the wording in that area also require updating to be consistent with both state and professional expectations. The field of psychology has grown far more complex than it was a quarter century ago, with specialty areas emerging, such as health psychology and medical psychology, that were almost unknown earlier while other areas such as neuropsychology and forensic psychology are now far more developed and demanding than in previous times. The legal issues involved in the private practice of psychology and associated incorporation and private practice management procedures are more complex than they used to be, and the educational and continuing education expectations for psychologists all over the country have evolved considerably over the last three decades. In other words, it is time for a thorough review and updating of the law and associated rules. Clearly, the most controversial of the proposed changes is the requirement of a doctoral degree in psychology for full licensure as a psychologist. There are a number of important reasons that provide the basis for this proposal. 1. Review and revision of standards and training requirements for certification, licensure and professional practice is not uncommon. Within medicine, the one year internship that used to be the norm has evolved into multi year residencies. Here in WV as well as within the overall field of school psychology, the educational requirement for certification as a school psychologist has increased from the MA degree plus a Certificate of Advanced Study to an Ed. S. degree, which includes a full year, full time internship in school psychology. Over time, the educational requirements for licensing and certification in many other professions have increased as well. These changes reflect the increasing demands and complexity of the professions involved. Such changes are clearly not expressions of disrespect for veteran professionals trained in an earlier time, nor

do they indicate that such professionals do poor work. Rather, these changes simply recognize that the public is best served when formal designations such as licensing and certification signify that the holder of the license or certification has had the highest and most appropriate level of education and training that is normative within the profession throughout the country. It is essentially a licensing level equivalent of the common expectation that professionals engage in best practices in their work. While there are many examples of excellent work being done by MA level psychologists, it is the Board s belief that public policy should never be set based on the anecdotal performance of particular individuals, but rather on an overall analysis of the profession and the roles it serves for the public. 2. It is absolutely clear that the doctoral degree is the normative educational requirement for licensure as a psychologist throughout the country. West Virginia is the only state in the country that allows persons with master s degrees to be licensed for the exact same title ( Psychologist ) and practice privileges as persons with doctoral education. No masters level psychologist in this state would be eligible for reciprocal licensure with any other state. Within the federal government, VA system and Medicare, psychologists are defined as doctoral level professionals and MA level professionals are excluded from eligibility for the title of psychologist. The American Psychological Association (APA), which is the largest and most influential professional association in our discipline, defines the doctorate as the minimum educational requirement for psychologists, and APA limits their accreditation procedures for educational institutions throughout the country exclusively to doctoral programs. The Association of State and Provincial Boards of Psychology (which is the umbrella organization of psychology licensing boards), and the National Register of Health Service Providers in Psychology are just two additional major national organizations that similarly define psychology as a doctoral level profession. The doctoral degree requirement is clearly the national norm, including within states having geographic, economic and cultural characteristics similar to our own. 3. Why is the doctoral degree considered so important? There are significant, substantive differences in educational preparation at the MA and Doctoral levels. a. At the most basic level is sheer quantity. While exact credit hour requirements vary widely, most MA programs take anywhere from 1-2 years to complete for full time students, whereas doctoral programs in the clinical/professional areas require 5 or more years. b. Doctoral programs have planned sequences of training that move from more basic concepts and skills through more advanced education and training. This sequential education with advanced coursework and training is simply not possible within the brevity of MA programs c. Concomitant with the additional time, sequencing and complexity of doctoral education are the opportunities for students to gain supervised experience in a variety of professional roles over an extended period of time- opportunities that are again not available within MA programs.

Training in specialized roles such as supervision and behavioral health psychology can be incorporated into doctoral programs, whereas the more limited contact within an MA program prohibits that type of specialized role development. d. Consistency and standards of programs: At the doctoral level, there are nationally accepted curriculum expectations and criteria for evaluating programs that are simply not available for MA programs. Whereas doctoral programs must document adherence to a wide range of curriculum content, carefully supervised clinical training and quality indicators to achieve and maintain accreditation, there is no such parallel set of expectations at the MA level. The result here is wide variability in content, expectations and quality of MA programs. e. Quantity and quality of clinical training experiences: MA programs often require two and sometimes three semesters of supervised clinical training, most often consisting of 10 to 15 hours per week of supervised experience called practicum ; some programs include a field internship of perhaps 400 clock hours. It is very rare to see an MA program in psychology that requires a total of more than 500 total supervised hours within the program. Again, since there are no nationally accepted standards for what constitutes appropriate training experiences at the MA level, there is a great deal of variability within this training. Obviously, within their longer time frames, Doctoral programs require many more clock hours of supervised experience. In addition to the greater number of semesters of basic supervised practicum training, the most critical issue here is the culminating full year, full time internship in professional psychology. This year long experience is an intensive clinical training process which itself must meet a series of training requirements, and serves to crystallize a series of professional proficiencies. At least 1800 clock hours in length, there is simply no parallel or equivalent at the MA level. While it is true that MA level professionals must be supervised for several years more than Doctoral level graduates, that supervised work experience is essentially unstructured, widely variable and not primarily educational or training oriented, in the way that the doctoral internship must be. 4. Supervision is a significant problem within the licensure process. Since current law provides for the same title and license to be awarded to both MA and Doctoral level practitioners, the functional assumption implicit in the 5 year post MA supervision requirement is that the extra years of supervision serve to educate and prepare MA practitioners to level that is equivalent to the preparation of doctoral level candidates. However, supervision is largely unregulated, and there is little statutory guidance in terms of specific requirements for supervisory qualifications or procedures. Supervision practices vary widely and there is no set of rules or regulations that effectively mandate that supervision serve a

consistently educative function. While there are certainly many fine supervisors in the state, in most instances their professional time and responsibilities are not devoted primarily to an educative or training role, but rather to clinical and/or administrative and practice management duties. Even the best supervisor is just one person, and no one psychologist s expertise is equivalent to the range of knowledge, skills and sequenced training that is available in a doctoral training program. It has been the Board s regular experience at the oral exams that compared to doctoral applicants, MA level candidates far too often demonstrate rather limited appreciation of their own professional competence boundaries. We see this as at least partially the responsibility of supervisors who have not adequately assessed the strengths and weaknesses of their supervisees or helped/insisted that their supervisees do the same. Candidates often see themselves as ready to do far more than their training and supervision actually prepared them to do, at least as evaluated by the Board. Frequently this includes a self perceived readiness to immediately supervise others for licensure, though the candidate may have little experience, limited areas of expertise, and no training or experience in supervision. Perhaps even more problematic, as evidenced by the competency forms completed by their supervisors, the supervisors have regularly seemed to support or even initiate this exaggerated scope of practice conception. In contrast, doctoral candidates have regularly demonstrated high levels of professional self regulation whereby they clearly articulate their practice strengths and boundaries. 5. Observable professional consequences- There is a pattern of data that supports the Board s contention that there are consistent and significant differences between the groups that indicate significant and important differences between them in terms of their preparedness for independent practice. a. Performance on the EPPP: The Examination for Professional Practice in Psychology (EPPP) is the standardized, written examination of the content knowledge in psychology required for licensure in all states of the country. From any vantage point, there is clear evidence that as a group, MA-level graduates perform at an unacceptable level and far more poorly on the exam than do doctoral level graduates. MA-level examinees, both within WV and nationally, have significantly lower mean scores than those of doctoral level candidates. Proportionate to their rate of taking the exam, they achieve failing scores far more frequently than do doctoral examinees and far more masters than doctoral candidates never pass the exam at all. Nationally, for EVERY administration of the EPPP from 1988 through 2001, the average (mean) score for MA candidates has been a failing score, while this has never occurred on even a single administration of the exam for doctoral level applicants. Even for those candidates that eventually pass the exam, MA level candidates require more retakes, and ultimately earn significantly lower scores within the passing range than do Doctoral candidates. It is very important to remember that MA candidates have 5 years to pass the exam and those that never pass have been

continuing to deliver services to the public for up to 5 years. b. Performance on the Oral Examination: The Board s experience has been that there is a clear, consistent and significant set of differences between MA and Doctoral level licensure candidates. In examining this data, it is important to remember that the oral exam occurs only for the subset of candidates who have passed the EPPP and who have completed the required period of supervised professional practice. In other words, these are the candidates who are presenting themselves to the Board as fully prepared to enter into the independent practice of psychology. As required by our law, at oral exams the Board grades each candidate on a 1-5 scale, with a 3 required for passing. Grades are based on Board members appraisal of the candidates knowledge within their proposed areas of practice, their understanding of ethical issues and their recognition of their own professional competencies and limits as evidenced in written work samples, oral responses to questions about those samples, and discussions of their proposed competency areas. Our data base from January of 2000 through March of 2003 contains 117 candidates (67 at the MA level and 50 at the Doctoral level). Doctoral candidates scored significantly higher ( x = 4.0) than did MA candidates ( x =3.4) (t = 7.3, p<.0001). It is important to note this significant difference emerged even though the size of each group is relatively small and the range of possible scores is quite limited. These are factors which work against finding significant differences between groups, suggesting that the differences are based on the consistency of score differences between the groups. In other words, the differences reflect a very real pattern of group level differences in performance at the oral exam. Additional data from this data base concerning the oral examination is consistent with this pattern: -When the Board perceives that the licensure applicant and his/her supervisor have not done an adequate job of providing an appropriately limited scope of practice for the applicant (i.e. the applicant is claiming a greater range of competencies than s/he has adequately demonstrated) the Board will impose restrictions on the person s scope of practice. Between the beginning of 2000 and March of 2003, the Board judged it necessary to impose restrictions 19 times; 16 of those were upon MA level practitioners, whereas 3 were Doctoral level. -When the Board evaluates the applicant s performance at the oral to indicate that the person has not yet demonstrated readiness for licensure, whether due to problems with written work samples, ability to discuss their work, etc, the Board will continue the oral, with suggestions or requirements for additional supervised work prior to a return for a

continuation of the oral exam process. In this same time period, the Board has continued 9 oral exams- in all 9 cases, they were MA level applicants, and none were needed for doctoral level applicants. Taken together, these data demonstrate a pattern whereby Doctoral level applicants are better prepared academically (i.e. the clear differences in program requirements), they perform consistently better on the nationally written examination of the knowledge base in psychology that is nationally accepted as the appropriate exam for this purpose (the EPPP) and the oral exam conducted by the Board, and they more clearly recognize their professional competencies and, most important, the limits or boundaries on their competence. Conversely, as a group MA applicants are not adequately prepared academically for the roles associated with the professional title of psychologist, they perform at an unacceptably low level on the national examination of content knowledge, and even those that do pass the national exam perform significantly more poorly on the oral exam required for licensure in this state. To the Board, the data provide strong empirical evidence in support of our contention that the public would best be served by requiring a doctoral degree in psychology for licensure at the highest level- that of a psychologist. 6. Continued need for MA level practitioners: The Board is well aware of the continuing need for MA level professionals in psychology to provide services in the state. To that end, the Board s proposal provides for the creation of a new title for MA practitioners- Psychological Practitioners. As defined in the proposed revision to the law, the title of Supervised Psychological Practitioners will provide a supervised professional role for MA level practitioners immediately upon completion of their degrees, while the Licensed Psychological Practitioner would be a licensure status available to more experienced MA level professionals who seek out additional graduate training and demonstrate competence to independently provide specific, limited services to the public. This is very similar to the model used quite successfully in Kentucky. Conclusion As noted at the outset, the Board has a unique role and perspective. We are a group consisting of experienced psychologists and concerned lay people. Our proposal was developed after years of experience with the current law, and was approved by the Board. We do not speak for or represent the interests of individual psychologists, nor are we a voice for any professional organizations within psychology. Rather, after careful consideration of all available data, examining the national norms licensing practices in other states, consideration of the ongoing problems we have encountered with the law as currently written and implemented, and the very real needs of this state for psychological services, we believe that the proposed revisions are in the best interests of the state and its citizens.