Psychology CLINICAL PRIVILEGE WHITE PAPER Psychology Background Psychology is a broad field that includes the scientific study of mental processes and behavior. It is similar to the medical field of psychiatry. Psychologists focus on the development of personality and the workings of the nervous system, and investigate the attitudes and relationships of human beings in social settings. Most psychologists have an MA, PhD, or PsyD degree, and may or may not specialize in the treatment of mental disorders. The state of Florida, for example, defines psychology as the use of psychological methods to diagnose and treat: mental, nervous, psychological, marital, or emotional illnesses; disability, alcoholism, and substance abuse; disorders of habit or conduct; and psychological aspects of physical illness, accident, injury, or disability, including neuropsychological evaluation, diagnosis, etiology, and treatment. The question of whether hospitals should grant admitting privileges to psychologists is very controversial. Most psychologists are considered allied health practitioners in many institutions and therefore hospitals do not grant them admitting privileges. Moreover, most states laws do not address this issue. Wisconsin is the only state to expressly permit psychologists to hold admitting privileges. In comparison, Ohio law prohibits psychologists from holding admitting privileges. Involved specialists Psychiatrists and psychologists. Allied health professionals, such as social workers; marriage, child, and family counselors; and psychiatric nurse practitioners, very often treat mental, emotional, or behavioral disorders. Furthermore, studies by the National Institutes of Mental Health have shown that family physicians treat more cases of mental or emotional disorder than psychiatrists. Positions of societies and academies APA The APA feels that qualified psychologists have the requisite skills to provide psychological services to patients in the hospital setting independent of physician services. This position is based on psychologists status as independent mental health professionals under state psychology scope of practice statutes. A supplement to Briefings on Credentialing 781/639-1872 Criteria reviewed 2006 1
Psychology The APA formed a Task Force on Hospital Privileges to review the issue of establishing standards for developing criteria necessary for privileges, reviewing credentials, recommending specific privileges for psychologists, specifying criteria for renewal of privileges, and participating in the renewal of privileges. The resulting document, Guidelines on hospital privileges: Credentialing and bylaws, as developed by Robert Resnick, Michael Enright, and Robert Thomson, was adopted as official APA policy in August 1991. In Analysis of Existing Hospital Practice Laws for Psychologists, Elizabeth Cullen, JD, MPA, the APA s practice directorate, says the ability of psychologists to practice in the hospital setting without physician oversight is measured by the right to apply for membership on a facility s medical staff and to enjoy full clinical, admitting, and discharge privileges within the scope of their professional license. It has long been the position of the APA that qualified psychologists have the requisite skills to provide psychological services to patients in the hospital setting independent of physician services. In October 1993 the American Psychological Association (APA) conducted a review of state laws. The following table outlines its findings. Hospital Admitting Privileges for Psychologists States Alabama Alaska Arizona Arkansas California Colorado Connecticut Delaware District of Columbia Florida Georgia Hawaii Idaho Illinois Indiana Legislation Authorizes admitting (may be revised) Authorizes admitting continued 2 A supplement to Briefings on Credentialing 781/639-1872 Criteria reviewed 2006
Psychology States Iowa Kansas Kentucky Louisiana Maine Maryland Massachusetts Michigan Minnesota Mississippi Missouri Montana Nebraska Nevada New Hampshire New Jersey New Mexico New York North Carolina North Dakota Ohio Oklahoma Oregon Pennsylvania Rhode Island South Carolina South Dakota Tennessee Texas Utah Vermont Virginia Washington West Virginia Wisconsin Wyoming Legislation Joint admitting only Joint admitting only Authorizes admitting Source: American Psychological Association, October 1993 A supplement to Briefings on Credentialing 781/639-1872 Criteria reviewed 2006 3
Psychology Psychology American Psychiatric Association The American Psychiatric Association has no position regarding the privileges of psychologists. Positions of other interested parties JCAHO Case law The Joint Commission on Accreditation of Healthcare Organizations (JCAHO) permits psychologists to join medical staffs of hospitals and to provide patient care services independently within the scope of their license and hospital clinical privileges (MS.1.1). However, the JCAHO has no formal position concerning the delineation of privileges for psychologists. Its 1995 Accreditation Manual for Hospitals states (MS.2.4.1), Professional criteria... constitute the basis for granting initial or continuing staff membership and for granting initial or renewed/revised clinical privileges. The JCAHO further requires (MS.2.4.1.3) that the criteria pertain to, at the least, evidence of current license, relevant training and/or experience, current competence, and health status. While the JCAHO does not require hospitals to use any specific method in delineating clinical privileges, it does require that such privileges be hospital-specific and based on an individual s demonstrated current competence (MS.2.15). It further requires that (MS.2.15.1 2.15.1.3) privileges are related to an individual s documented experience in categories of treatment areas or procedures, the results of treatment, and the conclusions drawn from quality assessment and improvement activities when available. In 1984, the California Association of Psychology Providers sued the California Department of Health Services (California Association of Psychology Providers v. Rank, 51 Cal. 3d1, 793 P.2d, 1990) to invalidate regulations in violation of the Hospital Practice Act. The act empowered psychologists to provide psychological services in hospitals within the scope of their licensure and without discrimination. The California Psychiatric Association, California Medical Association, and California Hospital Association appealed the original decision to amend regulations and allow psychologists authority to admit and discharge provided 4 A supplement to A Briefings supplement on Credentialing to Briefings on 781/639-1872 Credentialing 781/639-1872 Criteria reviewed Criteria 2006 reviewed 2006 4
Psychology Practice Area Practice 171 Area 171 that a physician is responsible for the necessary medical care. The court concluded that when state laws say nothing about who may admit patients to hospitals, the psychologists statutory authority to carry out the responsibility of diagnosis and treatment implies the authority to admit patients for these purposes. CRC draft criteria Minimum threshold criteria for requesting core privileges in psychology The following draft criteria are intended to serve solely as a starting point for the development of an institution s policy regarding this practice area. Education: PhD or PsyD Minimum formal training: The successful applicant must be able to demonstrate successful completion of an approved doctoral degree from a regionally accredited training program. Required previous experience: The successful applicant must be able to demonstrate that he or she has provided inpatient, outpatient, or consultative service to at least 30 patients during the past 12 months. Note: Three letters of reference must come from practitioners who have known the applicant for at least two years and who are acquainted with his or her current professional status. Core privileges in psychology Special requests for psychology Privileges include being able to diagnose, provide treatment, and consult to patients above the age of 15 who suffer from mental, behavioral, or emotional disorders. Privileges can include biofeedback and hypnotherapy. These privileges do not include any of the following special requests. Hospitals should base their psychologist s eligibility to admit or coadmit on state law as well the clinician s training and experience. For more information For more information regarding privileging this practice area, contact: American Psychological Association 750 First Street NE Washington, DC 20002-4242 Telephone: 202/336-5500 A supplement to Briefings on Credentialing 781/639-1872 Criteria reviewed 2006 5 5
Psychology Privilege Request Form Psychology In order to be eligible to request clinical privileges for psychology, a practitioner must meet the following minimum threshold criteria: Education: PhD or PsyD Minimum formal training: The successful applicant must be able to demonstrate successful completion of an approved doctoral degree from a regionally accredited training program. Required previous experience: The successful applicant must be able to demonstrate that he or she has provided inpatient, outpatient, or consultative service to at least 30 patients during the past 12 months. References: Three letters of reference must come from practitioners who have known the applicant for at least two years and who are acquainted with his or her current professional status. If you meet the criteria above, you may request privileges as specified below. I hereby request core psychology privileges as follows: Privileges include being able to diagnose, provide treatment, and consult to patients above the age of 15 who suffer from mental, behavioral, or emotional disorders. Privileges can include biofeedback and hypnotherapy. These privileges do not include any of the following special requests. For each special request, the applicant must meet minimum threshold criteria. Special requests include: Admit/coadmit I understand that in making this request I am bound by the applicable bylaws or policies of the hospital and hereby stipulate that I meet the minimum threshold criteria for this request. Physician s signature: Typed or printed name: Date: The information contained in this document has been designed and is intended for use by hospitals and their credentials committees in developing their own local approaches and policies for various credentialing issues. These materials, opinions, and draft criteria should not be adopted for use without careful consideration, discussion, and additional research by physicians in local settings. The Credentialing Resource Center does not provide legal or clinical advice; for such advice, the counsel of competent individuals in these fields must be obtained. Reproduction outside the recipient s institution in any form is forbidden without prior written permission. Opus Communications retains the copyright to the Clinical Privilege White Papers. 6 A supplement to Briefings on Credentialing 781/639-1872 Criteria reviewed 2006