A. Licensed Marriage and Family Therapists
The Marriage and Family Therapist licensing law, specifically Section 4980.40 of the Business and Professions Code, requires at least two years’ experience in interpersonal relationships; marriage and family therapy; and psychotherapy. Section 4980.43 further defines this requirement by specifying that two calendar years of supervised experience is required, consisting of at least 3,000 hours obtained over a period of not less than 104 weeks. Experience must be gained within the six years immediately preceding the date the application for licensure is filed, except that up to 500 hours of clinical experience gained in the required practicum is exempt from this six-year rule.
Experience may be gained only when the applicant is employed or volunteering in a setting that lawfully and regularly provides mental health counseling or psychotherapy such as: a governmental entity; a school, college or university; a licensed health facility, a nonprofit and charitable corporation; or a private practice. A private practice setting is defined as employment by an LMFT, an LCSW, a licensed Psychologist, a Psychiatrist, or a professional corporation of any of the licensed professions. Only individuals who have received their qualifying master’s degree and are registered as interns may work in a private practice setting. An applicant must have a minimum of 104 weeks of supervised experience and may claim up to five hours of supervision in any week. Applicants must keep weekly logs of all hours of experience gained, and may claim no more than a total of 40 hours of experience in any one week. (Cal. Bus. & Prof. Code § 4980.43.)
The supervised work experience breaks down into the following categories: direct counseling work experience (minimum 1,500 hours); individual therapy/counseling (no minimum or maximum); group therapy or counseling (maximum 500 hours); telemedicine (telephone or Internet) counseling (maximum 375 hours); administering and evaluating psychological tests, writing clinical reports, writing progress or process notes (maximum 250 hours); and non-counseling work experience (maximum 1,250 hours), which are broken down into the following categories: workshops, seminars, training sessions, or conferences (maximum 250 hours); personal psychotherapy received (maximum 100 x 3= 300 hours); client centered advocacy; and supervision (individual and group). (Cal. Bus. & Prof. Code § 4980.43.)
With respect to supervision, Section 4980.03 of the Business and Professions Code specifies that applicants for the MFT license must be supervised by an LMFT, an LCSW, a licensed Psychologist, or a Physician certified in psychiatry by the American Board of Psychiatry and Neurology. Each of these supervisors must meet additional criteria. The regulations provide that the supervisor must be licensed in California for at least two years prior to commencing any supervision, that his/her license must be in good standing (i.e., his/her license is not on probation or suspension), and that he/she must have practiced psychotherapy or supervised trainees, interns or associate clinical social workers for at least two years within the five year period immediately preceding any supervision.
The supervisor is required to provide at least one hour of individual or two hours of group supervision in each week where any qualifying experience is gained. The regulations require a five to one ratio for counseling/psychotherapy hours of experience gained by trainees, and one unit (one individual or two group hours) of supervision for the first ten client hours and another unit of supervision for any additional hour above ten in a week gained by registered interns. Applicants for the license must have at least 52 hours of individual supervision (gained in at least 52 separate weeks). The remainder of supervision may be either individual or group. Supervision may not be obtained from one’s spouse or relative, nor may it be obtained from a former therapist or from someone with whom the applicant has a personal relationship which undermines the authority or effectiveness of the supervisor. Interns who work in an exempt setting may receive supervision via videoconferencing. Applicants are required to have their supervisor sign a Supervisor Responsibility Statement before commencing employment or supervision (16 C.C.R § 1833.1.)
The Supervisor Responsibility Statement is intended to make supervisors and supervisees aware of the responsibilities the supervisor has to the supervisees and the licensing board. Additionally, the regulation requires supervisors to take reasonable steps to ensure that a supervisee properly assesses and examines the patient, implements an appropriate treatment plan, and is acting both within the scope of his/her license and competence. The supervisor is required to monitor the quality of counseling/psychotherapy performed by direct observation, audio or video recording, review of progress and process notes or records, or by any other means deemed appropriate by the supervisor.
B. Licensed Clinical Social Workers
The Clinical Social Worker licensing law, in Section 4996.2 of the Business and Professions Code, requires two years of supervised post-graduate experience. Section 4996.23 further defines this requirement by specifying that the applicant must have at least 3,200 hours of experience, which must be completed within a minimum of two years, in providing clinical social work services consisting of psychosocial diagnosis, assessment, treatment (including psychotherapy and counseling), client-centered advocacy, consultation and evaluation. The experience specified must be gained in not less than two years and shall have been gained within the six years immediately preceding the date on which the application for licensure is filed.
CSW students and post-graduate applicants, prior to registration, may work at governmental entities, schools, colleges or universities, nonprofit and charitable corporations and licensed health facilities. Only Registered Associate Clinical Social Workers (ASW) may work in private practice settings, such as practices owned by LCSWs, LMFTs, Psychologists, and Psychiatrists. All required supervised experience must be accrued by the applicant while registered with the Board as an ASW. (Cal. Bus. & Prof. Code § 4996.23.)
To qualify for the CSW license, the law requires a minimum of 2,000 hours of experience in clinical psychosocial diagnosis, assessment, and treatment, including psychotherapy or counseling. Of these 2,000 hours, a minimum of 750 must be face-to-face individual or group psychotherapy. A maximum of 1,200 hours may be gained in client-centered advocacy, consultation, evaluation, and research. No more than 40 hours of experience may be gained in any given week and no more than five hours of supervision may be credited during any single week. ASWs must have at least 52 weeks of individual supervision, thirteen of which must be supervised by an LCSW. (Cal. Bus. & Prof. Code § 4996.23.)
Supervision is defined in Section 4996.23 as “responsibility for, and control of, the quality of clinical social work services being provided.” Similar to the MFT licensing laws, ASWs must keep weekly logs of their hours, and must have their supervisors complete the Supervisor Responsibility Statement. Further, ASWs and supervisors who assume responsibility for providing supervision to those working toward a license as a CSW are required to complete and sign a supervisory plan. (16 C.C.R. § 1870.1.)
To gain hours of experience in a given week, either one hour of individual supervision or two hours of group supervision is required in that week. An ASW must receive one unit (one individual or two group hours) of supervision for the first ten client hours and another unit of supervision for any additional hour above ten in a week. ASWs who work for exempt settings may receive supervision via video-conferencing. Insofar as eligible supervisors are concerned, Section 4996.23 specifies that 1,700 hours of experience must be gained under the supervision of an LCSW, and the remaining 1,500 hours may be gained under the supervision of a licensed mental health professional acceptable to the BBS. These mental health professionals are defined in the Regulations as Licensed Marriage and Family Therapists, Licensed Psychologists or physicians certified in psychiatry by the American Board of Psychiatry and Neurology. These other licensed mental health professionals must be licensed for two years, but LCSW supervisors are not subject to that requirement. (16 C.C.R. § 1874.)
Like the MFT licensing law, supervision may not be obtained from a spouse or relative, nor may it be obtained from someone with whom the applicant has a personal relationship which undermines the authority or effectiveness of the supervision. Unlike the MFT licensing law, however, there is no express prohibition against receiving supervision from one’s former therapist. (Cal. Bus. & Prof. Code § 4996.18(d).)
C. Licensed Professional Clinical Counselors
The Professional Clinical Counselor licensing laws (Cal. Bus. & Prof. Code § 4999.46) require that supervised work experience be gained post-degree. All hours of supervised work experience must be gained while registered as a Professional Clinical Counselor intern, with the exception of one special circumstance and supervised work experience gained out of state. The one exception is the supervised work hours gained immediately after graduation, but prior to registration as a PCC intern. These hours may be credited towards licensure experience requirements if the individual applies for registration within 90 days of the qualifying degree conferral date. The individual actually has to receive the registration number in order to count the hours. Thus, individuals who apply for registration, but do not complete the application requirements within one year of being notified of a deficiency, cannot take advantage of this exception. PCC interns cannot work in a private practice setting until officially registered with the BBS.
Similar to the MFT licensing laws, the PCC licensing laws require PCC interns to complete 3,000 hours of supervised experience in no less than 104 weeks. To gain hours of experience in a given week, either one hour of individual supervision or two hours of group supervision is required in that week. A PCC intern must receive one unit (one individual or two group hours) of supervision for the first ten client hours and another unit of supervision for any additional hour above ten in a week. No more than five hours of supervision may be gained in a given week. Of the 104 weeks of supervision, at least 52 weeks must be weeks in which the intern received at least one hour of individual supervision. A maximum of 40 hours of work experience may be gained in a week. A PCC intern working in a governmental entity, a school, a college, or a university, or an institution that is both non-profit and charitable may obtain the required direct supervisor contact via videoconferencing. The supervised work experience breaks down into several categories: direct counseling work experience (minimum 1,750 hours); individual therapy/counseling (no minimum or maximum); group therapy or counseling (maximum 500 hours); telephone counseling (maximum 250 hours); non-counseling work experience (maximum 1,250 hours); administering and evaluating psychological tests, writing clinical reports, writing progress or process notes (maximum 250 hours); workshops, seminars, training sessions, or conferences (maximum 250 hours); client centered advocacy; and supervision (individual and group). Furthermore, at least 150 hours of clinical experience must be gained in a hospital or community mental health setting. (Cal. Bus. & Prof. Code § 4999.46.)
Experience may not be gained under the supervision of a spouse or relative by blood or marriage. Also, experience that is obtained under the supervision of a supervisor with whom the applicant has had or currently has a personal, professional, or business relationship that undermines the authority or effectiveness of the supervision will not be credited toward licensure. (Cal. Bus. & Prof. Code § 4999.46(f).
The Psychologist licensing law, particularly Section 2914 of the Business and Professions Code, specifies that applicants for the license must complete 3,000 hours of supervised experience, which must be completed within a minimum of two years. At least one year of this experience must be gained after being awarded the doctorate in psychology. A year of supervised professional experience shall consist of not less than 1,500 hours.
The year of supervised experience (1,500 hours) must be completed within thirty consecutive months. When an applicant accumulates all the required experience post- doctorally, it must be completed within a period of sixty consecutive months. With respect to pre-doctoral hours, supervised professional experience may not be accumulated until the applicant has completed 48 semester/trimester or 72 quarter units of graduate level coursework in psychology, educational psychology or the equivalent. (16 C.C.R § 1387.
The 1,500 hours of supervised experience that may be obtained prior to the awarding of the doctorate degree may be obtained in a training program approved by a university, college or school that has a training agreement with the educational institution to provide such supervised experience. If the applicant is enrolled in a doctoral program which includes an internship, the applicant may function as an intern without registration. A formal agreement between the school and the supervisor is required. The applicant is not required to register with the Board if the applicant is employed by an exempt setting, which includes: a school district; an accredited or approved educational institution; a governmental entity; or if the applicant is functioning under a waiver issued by the State of California Department of Mental Health. If the applicant has his or her doctorate and is accruing hours post-doctorally, registration with the Board of Psychology is required unless the applicant is working at one of the exempt settings mentioned above. (16 C.C.R § 1387.
Most post-graduate applicants will need to register with the Board as a Psychological Assistant. A Psychological Assistant may gain hours of experience under employment and supervision of a Psychologist in private practice, or a licensed physician and surgeon who is board certified in psychiatry by the American Board of Psychiatry and Neurology; or any of the above-mentioned exempt settings. (Cal. Bus. & Prof. Code § 2913.) However, if the applicant possesses a doctorate degree with 1,500 hours of supervised experience, and works for a non-profit community agency which receives 25 percent or more of its funding from governmental sources, the applicant must register for employment as a Registered Psychologist. (Cal. Bus. & Prof. Code § 2909(d).
A Psychological Assistant must be under the direction and supervision of a licensed Psychologist or Board-certified Psychiatrist who is employed by the same work setting as the Psychological Assistant and be available to the Psychological Assistant 100 percent of the time the Psychological Assistant is accruing experience hours. The supervisor must provide a minimum of one hour per week of individual face-to-face supervision to the Psychological Assistant. The supervisor must not have a disciplinary action pending against his or her license, is not on probation, has no familial or interpersonal relationship with the supervisee and is otherwise in compliance with the Psychology Licensing Law or the Medical Practice Act and their respective regulations. (16 C.C.R § 1387.)
For Registered Psychologists, the “primary supervisor” is allowed to delegate a portion of the required supervision to another licensed Psychologist or to suitable alternative supervisors, including LMFTs. (16 C.C.R § 1387.)
Supervisors must assure that the services performed by the supervisees are consistent with the supervisees’ training and experience. Supervision must be either individual or group for a minimum of one hour, or ten percent of the actual time worked per week, whichever is greater. Like the MFT licensing law and regulations, a supervisor may not supervise a supervisee who has been a psychotherapy client of the supervisor, and the supervisee must maintain a weekly log of all hours of experience gained toward licensure. (16 C.C.R § 1387.)
With respect to the specific kinds of hours that may be obtained, (i.e., psychotherapy, diagnosis and treatment) the law and regulations do not, in much detail, delineate the required 3,000 hours. The experience gained must, of course, be within the scope of practice of a licensed Psychologist, which is rather broad. For instance, the practice of psychology includes psychological testing and psychological services rendered to organizations (i.e., organizational psychology), and the licensing law specifies that the application of psychological principles and methods is not necessarily restricted to the diagnosis, prevention, and treatment of psychological problems and emotional and mental disorders of individuals and groups.
Additionally, regulations require that the applicant’s supervised professional experience consists of a “planned, structured and administered sequence of professionally supervised, comprehensive clinical training experiences.” The regulations also provide that the professional experience includes “socialization into the profession of psychology and shall be augmented by integrated modalities, including mentoring, didactic exposure, role-modeling, enactment, observational/vicarious learning, and consultative guidance” and “activities which address the integration of psychological concepts and current and evolving scientific knowledge, principles, and theories to the professional delivery of psychological services to the consumer public.” The regulations also provide that the supervised professional experience does not include custodial tasks such as filing, transcribing, or other clerical duties. The lack of specificity as to required kinds of hours permits licensure as a Psychologist without demonstrated experience in the diagnosis and treatment of mental and emotional conditions/disorders. (16 C.C.R § 1387.)
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