Petition Advocating Recommendations Of The New York State Psychological Association For The State Education Department and The Honorable Board of Regents Regarding The 12-01-04 Revised Proposed Regulations For The Licensing of Mental Health Practition sign now

We appreciate many of the amendments made to the original Proposed Regulations for the four, new mental health practitioner groups that took into consideration public comments and concern for standards of training and practice. However, we continue to be very concerned about the glaring discrepancies between the required curricula and training for these new groups and the responsibilities, privileges, and authority to practice in the mental health field granted by Article 163 and the amended Proposed Regulations.

This discrepancy poses serious threats to the protection of consumers of mental health services. The discrepancy between the training standards and the conferred levels of responsibility reflects a serious underestimation and devaluation of the complexities of mental health evaluation, treatment, and practice. In addition, there is a danger to the public welfare and safety in granting licenses and privileges to practice in the mental health field when the insufficiencies of the training are so discrepant from the responsibilities.

This danger is exacerbated by the proposal to grant licensure without an examination to individuals in all four practitioner groups who have only obtained baccalaureate degrees. People with only a baccalaureate degree, regardless of their years of practice, lack the benefits of organized knowledge, training, practice and discipline required for a profession. Individuals with only baccalaureate degrees are not eligible for licensure in medicine or law regardless of claimed years of experience. There should be no difference in standards for the mental health field to protect its integrity.

We remain concerned that the proposed curricula for each of the mental health practitioner groups is insufficient to develop accurate clinical judgement to utilize complex, multileveled diagnostic systems. Therefore, the question remains as to whether this training prepares them to make differential and co-morbid diagnoses among emotional disturbances, mental disorders. personality disorders, serious mental illness, life transition issues, and organically based dysfunction. The training does not appear to provide the diagnostic skills necessary to do appropriate evaluation for treatment planning. This would expose the public to the dangers of misdiagnosis and mistreatment.

In each of the following sections, we shall present specific concerns and proposed amendments.

Mental Health Counselors

The proposed increase from 45 to 48 required course credits listed in Section 52.32 is insignificant in view of the nine areas of competence expected of mental health counselors. The delay in increasing the required curriculum to sixty credits would set up two classes of mental health counselors - those with 48 credits as opposed to those with 60 credits. Also, by the time the first graduating class will be ready to sit for the licensing examination, the 60 course requirement will be implemented. Therefore, we propose that the training programs be instructed immediately to develop a 60 credit curriculum so that all mental health counselors will be equally trained. No qualifications exist for what is required training for demonstrable competence for the areas of practice.

Marriage and Family Therapy

The curriculum for marriage and family therapy does not require sufficient training regarding the role, importance and influence of multicultural factors on the organization and functioning of families. The proposed curricula also does not provide for the recognition of the mutual influence of the full range of psychopathology, neurobiological disorders, individual development and family dynamics. A lack of such knowledge and understanding may lead to inaccurate evaluation and misguided and inappropriate treatment. Therefore, the curriculum requirements need to be significantly increased to include these areas. In addition, we recommend that the three-year experience equivalent to become a supervisor should be gained post-licensure, and therefore be in addition to the 1500 clinical contact hours required for licensure. The Regulations should specify that supervisors of marriage and family therapy, who are licensed pursuant to Articles 131, 131-b, 139, 153, 154, and 163, shall have specific training in marriage and family therapy in order to adequately supervise it. We support the need to have the 1500 required client contact hours of supervised experience occur in a clinical setting and not in a private practice setting.

Creative Arts Therapists

While we agree that the increase of the credit hours for creative arts therapists from 30 to 48 will strengthen the training and competence of future, professional creative arts therapists, this is still not adequate to cover the nine required areas in the curriculum. Individual courses on psychopathology should be a minimum of an independent, year-long course that is not subsumed under a course on the foundation of creative arts therapy. This curriculum reflects such a lack of a comprehensive training in psychopathology that these students will not be sufficiently trained to accurately utilize any complex, multileveled diagnostic system or understand its relevance for treatment.

The employment of supervisors who have completed only a baccalaureate degree, regardless of experience, would raise questions about the competence of the supervisor to supervise students in a masters or higher level degree program. In addition, the requirement that such a supervisor have only three years or the part-time equivalent of experience further raises the question of such a supervisor's adequacy. The use of supervisors with such limited education and experience would raise serious questions about the adequacy of students so supervised.


We are concerned that the revisions made to the Proposed Regulations for psychoanalysis still do not adequately address the core issues for the training of psychoanalysts. The training as it is articulated in the Proposed Regulations ignores the national consensus as advanced by the Consortium and the Accreditation Council for Psychoanalytic Education of a minimum three sessions per week model both for the psychoanalytic candidate and the patient. That is, the psychoanalytic candidate should have received a psychoanalysis on a minimum of a three times per week basis, and be educated, trained and supervised to conduct psychoanalysis on a minimum of a three sessions per week model. The lack of such stated requirements will encourage individuals who are not so trained to use this model and thus to endanger the mental health and welfare of their patients. Thus, the Proposed Regulations as now promulgated do not provide adequate consumer protection.

Students who will be licensed as psychoanalysts according to the Regulations as they are now promulgated will never be able to become part of the national and international psychoanalytic community despite having a state license in psychoanalysis because their training does not reflect national and international standards. In addition, learning psychopathology based only on psychoanalytic theory is not adequate for the utilization of complex, multileveled diagnostic systems that include organic, biological, cognitive, and perceptual disorders which may confound individual and relational dynamic processes. Therefore, an additional, broad-based course on psychopathology should be required. The employment of individuals as supervisors who have completed only a baccalaureate degree, regardless of experience, would raise questions about the competence of the supervisor to supervise in a masters or higher degree program. In addition, the requirement that a supervisor have only three years of full-time or equivalent part-time experience further raises the questions about a supervisor's competence.


In summary, we urge you to strengthen the requirements for training of these four practitioner groups in order to protect the integrity and complexity of mental health practice, to provide adequately trained practitioners, and to protect the public welfare.

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Aaron CallahanBy:
Petition target:
The New York State Education Department and the Honorable Board of Regents


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