Executive Summary

NCPA supports a thoughtful path to independent practice for master’s-level psychologists with a limited scope of practice commensurate with their training and experience.

In April 2023, the North Carolina Association of Professional Psychologists (NCAPP) introduced Senate Bill (SB) 570. If enacted, this Bill would have required the NC Psychology Board (Board) to grant independent practice status and Health Services Provider (HSP) certification to Licensed Psychological Associates (LPAs) with at least 3,000 hours of post-licensure experience within 24-60 months of initial licensure. The Senate did not pass SB 570, so this bill per se will see no further action in the 2023-24 long session of the General Assembly. However, it is possible that the substance of this bill will appear in an “omnibus” bill later in the short session. SB 570 does not address or incorporate the American Psychological Association’s (APA’s) recently established standards for the accreditation of Master’s degrees (MA) related to health services (APA, 2021), and it does not anticipate the forthcoming model statutes for licensure of MA-level psychologists by the Association of State and Provincial Psychology Boards (ASPPB).  Many professional groups have been involved in developing these standards, guidelines, and model statutes with input from licensing boards and legislators.

Licenses and Educational Standards

Public protection, health, safety, and risk reduction are the foundations of state licensure of professions. Learned professions like medicine, psychology and law are difficult and complex; if attempted by an untrained, or a poorly trained person, it is more likely that someone will be hurt. Licensure by a qualified authority gives the licensee permission to do something that is otherwise prohibited (Legal Information Institute, 2020).  Indeed, “[t]he practice of psychology in North Carolina is hereby declared to affect the public health, safety, and welfare, and to be subject to regulation to protect the public from the practice of psychology by unqualified persons and from unprofessional conduct by persons licensed to practice psychology” (N.C.G.S. 90-270.135.(b)).

Education and training standards dovetail with the desire for public protection and serve professional interests as well. For any profession, its professional and academic leaders define what is expected in terms of organized, supervised education and experience for entry level professional practice. Legislators rely on these professional standards when crafting enabling legislation. Consumers look to these standards when choosing providers, particularly when different mental health professionals might offer the same or similar services (e.g., psychotherapy). Aspiring professionals look to these standards to understand what might be expected of them to achieve licensure. Licensing boards use the standards as enacted into law as rational, defensible guidelines for deciding when it is appropriate to grant (or deny) licensure, and when it is appropriate to sanction (or support) the actions of a particular licensee. All parties are best served when the educational and training standards, and the relevant laws, are clear and complete.[1]

[1] In White v. Board of Examiners of Practicing Psychologists (1990), the North Carolina Court of Appeals found the original Psychology Practice Act to be unconstitutionally vague in part.  This led to the overhaul of the Psychology Practice Act in 1993.

Licensing in Mental Health Professions

Licensure is a thoughtful and deliberative process, based on established standards, recommendations, training, and applied skills as established by professionals, leaders, and stakeholders in their respective fields. Licensing laws lay out the requirements for practice, the scope of practice, title(s) that can be used, and continuing education to maintain licensure.

Psychology as a field moved towards licensure following World War II with the adoption of the Boulder Model, followed by APA’s accreditation of doctoral-level training programs in 1948 and internship programs in 1956. North Carolina established licensure for psychologists in 1967 (Resnick, 1976). All of this occurred in the context of substantial opposition by organized medicine, in spite of the fact that doctoral-level psychologists had an organized, accredited set of training programs and internships, which would safely allow them to practice independently.APA established national standards for MA-level psychology training programs regarding health services only recently (APA, 2021).

In 1983, Clinical Social Workers and Licensed Clinical Mental Health Counselors (nee’ Licensed Professional Counselors) followed psychology in achieving North Carolina licensure (see N.C.G.S. 90-B and 90-329 et seq. respectively). In both cases, the professions approached the General Assembly with established national standards regarding program accreditation and training before seeking licensure.

LPAs are a notable exception to accreditation and professional standards proceeding licensure. North Carolina is one of the minority of states that license individuals with a master’s degree in psychology, with the goal of increasing access to care. In the absence of standards regarding core curriculum, supervised training, and experience, the Psychology Practice Act required LPAs to be supervised by a Licensed Psychologist (LP) or an equivalent supervisor. While the Board eased regulations regarding the amount of required supervision in 1997 and allowed LPAs with more experience to have less supervision, the law still requires at least some supervision.

The combination of APA’s deliberate pace in adopting MA-level training standards and the continuing development of other MA-level independent practitioners leaves existing LPAs out of sync with their master’s level competitors. Current licensed LPAs, even with minimal supervision requirements, are at a competitive disadvantage, and indeed the number of LPAs in North Carolina has declined since 2013 while the number of LPs and other MA-level health practitioners has increased steadily (NCAPP, 2023; Collins, 2023). For LPAs to remain viable as a mental health career choice, we need to overhaul current training expectations and licensure. APA has provided accreditation standards for master’s training programs and ASPBB is drafting recommendations for title and scope of practice. A remaining issue is how to provide for existing LPAs in a manner consistent with public protection. For reasons that we explain below, we regard SB 570 as highly flawed to accomplish this goal.

Recent Events and the Path Forward

For over 10 years, NCPA and NCAPP have discussed a pathway for independent practice for current and future LPAs. In 2020, the Board went on record supporting some sort of legislative solution for LPA independent practice following an unsuccessful attempt to address this simply through a regulation change (Hill, 2020). Statements by NCAPP that the Board “approved” a path to independence in 2020, meaning an end to lifetime supervision, might be misleading to some because the Board cannot do this of its own accord. Such a change requires legislative action.

In 2020-21, NCPA organized a task force to address this issue. The task force surveyed NCPA members and found that 67% of NCPA members supported creating a pathway to independent practice for LPAs, with 88% supporting the concept that the pathway should follow APA’s then-pending guidelines on education, training, and accreditation. This remains NCPA’s stance.

During the 2021 long session, NCAPP introduced House Bill (HB) 881 (North Carolina General Assembly, 2021). NCPA opposed this bill based on several important considerations, including what was then the lack of national standards or an accreditation process for master’s level training in psychology, the lack of consensus on the appropriate scope of practice for master’s trained psychologists, and the critical importance of ensuring a well-qualified workforce in North Carolina.  The bill did not advance.

In late 2022, the Board convened a work group composed of Board members and representatives from NCPA and NCAPP to address possible legislative action. During those meetings, the NCAPP representative indicated that NCAPP again had a bill that it wanted to introduce but declined to share the text of the draft bill when both NCPA and the Board requested it. NCPA leadership reached out to NCAPP leadership for separate meetings, but NCAPP declined to continue those meetings after two conversations via Zoom.

In April 2023, Senator Burgin introduced SB 570 (North Carolina General Assembly, 2023). The bill is a lightly reformatted version of HB 881, with the addition of text that would revise the current process[2] by which members of the Board are appointed by the Governor. Senator Burgin hosted a meeting including representatives from the Board, NCAPP, and NCPA; this has been the only such meeting to date directly involving these major stakeholders. NCAPP’s decision to move forward with SB 570 without prior discussions with stakeholders precludes a more collegial discussion and achievement of consensus before introducing any bill. Further actions now involve lobbyists, legislators, hearings, and amendments or bill substitutes.

NCPA was and remains concerned about the limitations of SB 570 for the following reasons:

  • SB 570 did not incorporate APA’s fully approved standards for accreditation for master’s programs in health service psychology, nor did it address the model statute for licensure of master’s-level psychologists under development by ASPPB. 
  • SB 570 failed to bring our statute into harmony with national developments that would allow enhanced professional mobility and practice opportunities for LPAs regarding interstate practice that LPs currently enjoy through PSYPACT and related credentials.
  • SB 570 only dealt with existing LPAs and does not incorporate current education and training standards for future LPAs.   
  • SB 570 would have allowed LPAs the same title and scope as LPs, despite lower standards in core knowledge and supervised experience.
  • SB 570 did not set the appropriate minimum passing score of 500 on the EPPP, which represents a national consensus on core knowledge for entry level practice. It is currently set at 440 for LPAs vs. 500 for LPs in North Carolina.
  • SB 570 did not enable the Board to examine an LPA’s relevant course work before awarding HSP certification, something required of LPs.
  • SB 570 did not create a new title for LPAs with independent practice status, thus giving consumers no clear distinction between doctoral trained practitioners and those with a master’s degree. SB 570 thereby failing to address issues potentially affecting public protection, which is the cornerstone of any professional licensure.

NC Psychology Board member Susan Hurt, JD, PhD is a member of the ASPPB task force addressing this issue, and she briefed the Board at its November 2023 meeting. The model legislation would propose a different title for independent MA-level psychologists, propose a scope of practice consistent with demonstrated training and experience, require a higher level of initial supervision of post-degree experience than North Carolina’s current standard, and involve a revision of the existing PSYPACT interstate compact to allow similar professional mobility for this new class of independent psychologists (Evers, 2023).

To the extent that North Carolina’s laws and regulations differ from the ASPPB model legislation, either regarding existing (legacy) licensees or MA-level psychologists trained in newly accredited programs, that difference would raise potential challenges regarding participation in PSYPACT. Any state that had simpler (lower) licensing standards would risk the unintended consequence of becoming a professional home for those who could not achieve licensure elsewhere, something at odds with public protection. Finally, any downward departure from national standards encourages more strict scrutiny by any credentialling body like insurance companies or hospitals. In this situation, public protection interests and professional interests align in that having well-defined, well-accepted standards regarding training, experience and scope of practice benefits both the consumer and the practitioner.

 [2] The North Carolina Psychological Association, or its successor, shall, having sought the advice of the chairs of the graduate departments of psychology in the State, for each vacancy, submit to the Governor a list of the names of three eligible persons. (90-270.140). NCPA membership is not a prerequisite for nomination to the Psychology Board. 

In Summary

It is in the best interests of all parties and the public that we serve to develop a thoughtful and sound path to independent practice for MA-level psychologists.  It is imperative that future legislation regarding LPA practice issues be guided by already developed and evolving national accreditation, training, and licensing standards for the protection of both licensees and the public. NCPA is committed to working toward legislation that would meet these ends.

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Collins, Dan (2023, February 14). Personal communication to Richard Rumer.

American Psychological Association (2021, February). Standards of Accreditation for Health Service Psychology:  Master’s Programs. Washington, DC:  APA. Accessed at https://www.apa.org/about/policy/health-service-psychology-masters-programs.pdf as recently as 31 October 2023.

Evers, Mary (2023, November 9). Personal communication to Richard Rumer et al.

Hill, Robert W. (2020). [North Carolina Psychology] Board statement on supervision of licensed psychological associates. Accessed at https://ncapp.org/nc-psychology-board-supports-the-end-of-career-long-supervision-of-lpas/  on 3 November 2023.

Legal Information Institute, Cornell Law School (2020). “License.”  Accessed at https://www.law.cornell.edu/wex/license  on 31 October 2023.

North Carolina Association of Professional Psychologists (2023). Table showing number of licensees in North Carolina allied healthcare professions, 2013-2018. Accessed at https://ncapp.org on 3 November 2023.

North Carolina General Assembly (2021, May 5). House Bill 881. Accessed at https://www.ncleg.gov/BillLookUp/2021/H881 as recently as 31 October 2023.

North Carolina General Assembly (2023, April 4). Senate Bill 570. Accessed at https://www.ncleg.gov/BillLookUp/2023/S570 as recently as 31 October 2023.

Resnick, Robert J. (1996).  A brief history of practice – expanded. Presidential Address, American Psychological Association.  Accessed at https://pages.charlotte.edu/richard-mcanulty/wp-content/uploads/sites/268/2013/09/A-brief-history-of-practice-expanded.pdfon 31 October 2023.

White v. Board of Examiners of Practicing Psychologists (1990, February 1). 97 NC. App 144 (NC. Ct. App. 1990) 388 S.E.2d 148