NCPA's Comments on APA's Model Act for State Licensure

NCPA's Comments on the American Psychological Association's Model Act for State Licensure of Psychology Professionals

Click here to review the APA Model Act

The North Carolina Psychological Association is our state’s oldest and, by far, largest organization of professional psychologists. Our goals are to promote psychology as a profession and to advocate for human welfare with science. We have had both doctoral-level Licensed Psychologists (LPs) and masters-level Licensed Psychological Associates (LPAs) since 1967. LPAs worked under supervision of LPs, consistent with their more limited training as well as the absence of accreditation for MA-level programs in health psychology. However, as other masters-level mental health practitioners began to be licensed for independent practice, and particularly with the recent advent of APA accreditation for master’s programs in health service psychology, it became clear that our LPAs also deserved some sort of independent practice.  

NCPA has long endorsed a thoughtful path to such independent practice, and we believe the APA’s Model Act is largely consistent with that goal. The Model Act reflects the core truth that psychology’s identity as a health service is based on its scientific approach to the complexities of human behavior. Professional psychology began by requiring the doctoral degree, and continuing to require that degree as a minimum for the most complex aspects of the practice of psychology is appropriate for the public protection. APA’s relatively new standards for accreditation of master’s programs in health services, as well as this Model Act’s proposal for a scope of practice for Licensed Practitioners of Psychology that is slightly attenuated from that for Licensed Psychologists, give prospective masters-level psychologists a more defined career path, and a scope of practice consistent with their training and experience. In so doing, this may improve the public’s access to mental health care, but this will be by adding new MA-level psychologists to the work force rather than by the minor changes in licensure for existing licensees.

Lines 80-82, definition of “psychological assessment”. The word “diagnosis” is not defined in the Model Act. It would be good to note here that diagnosis – deciding if a patient meets pre-defined criteria for an externally-defined taxonomy – can be one outcome of a psychological assessment.

Lines 202-208, Exclusions to Practice of Licensed Practitioners of Psychology. While NCPA believes that it is important to protect the public safety by requiring appropriate training and supervised experience for the higher-skill, high-impact aspects of our practice, writing appropriate rules in this area will likely be challenging. For example, at what point does a psychoeducational evaluation become so complex as to cross into the realm of neuropsychology? The across-the-board prohibition of LPPs engaging in forensic psychology is also inconsistent with the experience of states like North Carolina, where our Licensed Psychological Associates, with appropriate training and under supervision, conduct initial forensic evaluations. The more nuanced language in the Association of State and Provincial Psychology Board’s Model Statutory and Regulatory Language deserves consideration here.

Lines 218-222, Psychology Board Membership. North Carolina is more generous in its representation of Licensed Psychological Associates on the Psychology Board than the Model Act’s proposal. The Board has three Licensed Psychologists and two LPAs, while there are approximately 3,000 LPs, and 1,000 LPAs, licensed in North Carolina.

Lines 224-226, Psychology Board Membership. In addition to the requirement for active practice, consider the additional qualifier that “such activity during the two years preceding appointment shall have occurred primarily in this State” (NCGS 90-270.141(a)(2)). Even with a national model practice act, its integration into each state’s statutes may be idiosyncratic, and it is better for Board members to be familiar with that.

Lines 290-291, rationale about doctoral degree. Refer here to “Licensed Psychologist” rather than simply “psychologist” to clarify that this does not apply to proposed Licensed Practitioners of Psychology or current Licensed Practicing Psychologists.