Texas Psychology Board Under State Scrutiny, Recommends Eliminating ASPPB Anti-Competitive Practices

The following is the Executive Summary with Issues and Recommendations of the Texas State Board of Examiners of Psychologists Staff Report.
“The Board unnecessarily limits entry into the profession”
Issue 1: The Board’s Oral Examination Is an Unnecessary Requirement for Licensure.

The oral examination is an outdated licensing requirement that offer little value in assessing candidates’ minimum competency to practice psychology. Licensure as a psychologist already requires a doctoral degree, passage of a national written examination and jurisprudence examination, and completion of 3,500 hours of supervised experience. In addition to concerns about the fairness and consistency of the exam administration, conducting an oral exam twice a year puts an undeniable strain on agency staff and resources, while creating a bottleneck to entry into the profession. Nationally, the psychology profession has moved away from using oral examinations. With only eight states continuing to use an oral exam to assess competency, this exam prevents psychologists from easily moving their practice to Texas to help meet the state’s mental health provider shortage.

Recommendation: Eliminate the statutory authority for the psychology board to administer an oral exam.


Issue 2: Requiring a Year of Post-Doctoral Supervision Is an Unnecessary Hurdle to Licensure, Potentially Contributing to the Mental Health Care Provider Shortage in Texas.

Psychologist candidates must complete two years of supervised work experience before becoming fully licensed. Statute requires half of this experience to be completed after candidates receive their Ph.D. Current doctoral degree programs include substantially more practical experience than at the time Texas enacted this post-doctoral supervision requirement. Recognizing the change in doctoral education and training, the national trend has begun shifting away from requiring a set number of hours be completed in a post-doctoral setting. Today, 15 states and the American Psychological Association have adopted policies that do not distinguish between pre-doctoral and post-doctoral work experience. Requiring candidates to often repeat hours of experience earned during their degree program adds minimal protection and delays licensure of psychologists at a time when Texas faces a shortage of mental health care providers.

Recommendation: Remove the statutory requirement for psychologists to earn half of their supervised work experience after receiving their doctoral degree.


Issue 3: Key Elements of the Board’s Licensing and Regulatory Functions Do Not Conform to Common Licensing Standards.

Sunset staff found some of the board’s licensing and enforcement processes do not match model standards or common practices observed in other regulatory agencies. Specifically, requirements to apply for a provisional license and to submit letters of recommendation make the process for becoming a licensed psychologist overly burdensome. The board also lacks certain tools, such as issuing remedial non-disciplinary sanctions and ordering show-cause hearings regarding competency, necessary to effectively enforce the psychology statute and board rules.

Recommendations Remove the requirement for a separate provisional psychologist license and instead authorize the board to grant provisional status to applicants for full licensure.

Authorize the board to issue remedial plans to resolve minor complaints.

Clarify the agency’s authority to require physical or mental evaluations for those suspected of impairments and hold related hearings for noncompliance.

Direct the board to remove the requirement for letters of reference.

Direct the board to prohibit a board member from participating in both the investigation and resolution of a complaint.


Issue 4: Texas Should Continue Regulating Psychologists, but Decisions on the Structure of the Texas State Board of Examiners of Psychologists Await Further Review.

Texas has a continuing need to regulate the practice of psychology. Licensed psychologists provide a wide range of psychological services such as individual and group therapy to vulnerable populations. Treatment often occurs without supervision in otherwise unregulated settings, and psychologists apply a considerable amount of judgment in treatments and therapies. However, as a small, independent agency with limited resources and high staff turnover, the board faces hurdles to providing effective regulation and consistent service to the public.

These hurdles raise the question whether the agency’s functions should continue in a stand-alone or consolidated organization. Several health licensing agencies are under Sunset review at this time. rough these reviews, Sunset is considering the benefits of consolidation, such as enhanced administrative efficiencies and increased available time to perform critical licensing and regulatory functions. Sunset staff will complete the analysis of these benefits in mid-November 2016.

Recommendations: Continue the regulation of psychologists, but postpone the decision on continuation of the Texas State Board of Examiners of Psychologists until completion of the Sunset reviews of other health licensing agencies.


Nice to see state officials taking action into outdated licensing matters in psychology, that only benefit private financial interests of a few greedy psychologists. For a Full Sunset Review Report.

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