Existing law, the Psychology Licensing Law, establishes the Board of Psychology to license and regulate the practice of psychology. Existing law requires each applicant for licensure as a psychologist to take and pass any examination required by the board, except as exempted by the board under existing law. Existing law prescribes additional requirements for licensure, including a requirement that an applicant for licensure have earned a doctoral degree in any of specified fields of study.

This bill would make an applicant for licensure who has completed all academic coursework, as specified, required for such a doctoral degree, as documented by a written certification from the registrar of the applicants educational institution or program, eligible to take any and all examinations required for licensure. The bill would require the board to implement a process to verify any additional eligibility requirements beyond the completion of academic coursework that are imposed by a national licensing examination entity, as specified.

Existing law, the Psychology Licensing Law, establishes the Board of Psychology to license and regulate the practice of psychology. Existing law requires each applicant for licensure as a psychologist to take and pass any examination required by the board, except as exempted by the board under existing law. Existing law prescribes additional requirements for licensure, including a requirement that an applicant for licensure have earned a doctoral degree in any of specified fields of study.

This bill would make an applicant for licensure who has completed all academic coursework, as specified, required for such a doctoral degree, as documented by a written certification from the registrar of the applicants educational institution or program, eligible to take any and all examinations required for licensure. The bill would require the board to implement a process to verify any additional eligibility requirements beyond the completion of academic coursework that are imposed by a national licensing examination entity, as specified.

Existing law, the Psychology Licensing Law, establishes the Board of Psychology to license and regulate the practice of psychology. Existing law requires each applicant for licensure as a psychologist to take and pass any examination required by the board, except as exempted by the board under existing law. Existing law prescribes additional requirements for licensure, including a requirement that an applicant for licensure have earned a doctoral degree in any of specified fields of study.

This bill would make an applicant for licensure who has completed all academic coursework, as specified, required for such a doctoral degree, as documented by a written certification from the registrar of the applicants educational institution or program, eligible to take any and all examinations required for licensure. The bill would require the board to implement a process to verify any additional eligibility requirements beyond the completion of academic coursework that are imposed by a national licensing examination entity, as specified.

Existing law, the Psychology Licensing Law, establishes the Board of Psychology to license and regulate the practice of psychology. Existing law requires each applicant for licensure as a psychologist to take and pass any examination required by the board, except as exempted by the board under existing law. Existing law prescribes additional requirements for licensure, including a requirement that an applicant for licensure have earned a doctoral degree in any of specified fields of study.

This bill would make an applicant for licensure who has completed all coursework academic coursework, as specified, required for such a doctoral degree, as documented by a written certification from the registrar of the applicants educational institution or program, eligible to take any and all examinations required for licensure.

Existing law, the Psychology Licensing Law, establishes the Board of Psychology to license and regulate the practice of psychology. Existing law requires each applicant for licensure as a psychologist to take and pass any examination required by the board, except as exempted by the board under existing law. Existing law prescribes additional requirements for licensure, including a requirement that an applicant for licensure have earned a doctoral degree in any of specified fields of study.

This bill would make an applicant for licensure who has completed all coursework required for such a doctoral degree, as documented by a written certification from the registrar of the applicants educational institution or program, eligible to take any and all examinations required for licensure.

CONCURRENCE IN SENATE AMENDMENTS

CSA1 Bill Id:AB 282

Author:(Aguiar-Curry)

As Amended Ver:August 14, 2023

Majority vote

SUMMARY

Authorizes an applicant for licensure as a psychologist to take all examinations required for licensure when they have completed academic coursework required for a doctoral degree, as specified.

Senate Amendments

Specify that, if a national licensing examination entity approved by the Board of Psychology imposes additional eligibility requirements beyond the completion of academic coursework, the board shall implement a process to verify that an applicant has satisfied those additional eligibility requirements.

COMMENTS

Background. Applicants for a psychologist license must have a qualifying doctorate degree, complete a minimum of 3,000 hours of supervised professional experience, and take and pass the national Examination for Professional Practice in Psychology (EPPP), which is administered by the Association of State and Provincial Psychology Boards (ASPPB) and the California Psychology Laws and Ethics Examination (CPLEE), which is administered by the Board of Psychology. The EPPP and CPLEE are both computer-based examinations. Psychological assistants must earn a qualifying master's degree, must be registered to a licensed psychologist or a board-certified psychiatrist as employees, and may provide limited psychological services under the direct supervision of the psychologist or psychiatrist with whom they are registered. Registered psychologists must earn a qualifying doctoral degree, must complete a specified number of hours of professional experience under supervision, and can only engage in psychological activities at qualifying nonprofit community agencies.

Applicants are eligible to take the EPPP when they complete their doctorate degree and 1500 hours of qualifying professional experience. After they pass the EPPP, the applicant must complete all 3000 hours of supervised professional experience to be eligible for the CPLEE.

Exceptions to the EPPP requirements, but not the CPLEE requirements, are provided for:

1. A California-licensed psychologist who has been licensed for at least five years and has allowed their license to cancel by not renewing the license for at least three years, for an applicant who has been licensed in another state, Canadian province, or U.S. territory for at least two years.
2. An applicant who holds a Certificate of Professional Qualification issued by the ASPPB.
3. An applicant credentialed as a Health Service Provider in Psychology by the National Register of Health Service Providers in Psychology who has been licensed based on a doctoral degree in another state, Canadian province, or U.S. territory for a minimum of two years.
4. An applicant for licensure as a psychologist who is certified by the American Board of Professional Psychology and has been licensed based on a doctoral degree in another state, Canadian province, or U.S. territory. Although the EPPP is waived under this section, an applicant must file a complete application and meet all current licensing requirements not addressed above, including payment of any fees, take and pass CPLEE and not been subject to discipline.

According to the author, ASPPB is in the process of converting the licensure exam into two parts. Part One will focus on clinical knowledge and will be taken after coursework has been completed. Part Two will be experienced-based and taken after completion of the clinical experience required for licensure. The author argues states this could lead to greater wait processing times for licensees, where each step in the licensure process typically took two-four months to process already, where the total wait time often lasts about one year.

ASPPB approved a motion during its June meeting affirming that Part Two of the exam experience cannot, in its view, be taken until Part One of the exam experience, degree conferral, and completion of supervised experience as determined by the jurisdictional licensing or registration authority have all been completed.

During the 2020-2021 sunset review oversight of the board, it was reported that the board has experienced increases in the average time to process complete applications and a significant increase in the average time to process incomplete applications. The number of pending applications had outpaced completed applications. In response to this trend, the board conducted a comprehensive review of its statutes and regulations addressing how licensure can be obtained. The board identified sections it believed creates undue barriers to licensure, or are inconsistent with training environments, education, and new technologies related to the practice of psychology. The board will be pursuing statutory and regulatory changes to enact these proposed changes.

According to the Author

"Current law requires each applicant for licensure as a psychologist to undergo a lengthy process of several consecutive steps resulting in extensive waiting periods for some applications. This causes delays and interruptions to the consumers trying to access mental health treatment and creates a financial burden for the license applicants. This bill will help reduce applicant wait times at the Board of Psychology by streamlining the examination process. These changes will not affect the quality of the licensing process, but will help to remove of delays in the review process and help associate clinicians providing behavioral healthcare and, on the road, to completing their clinical hours required for licensure."

Arguments in Support

The California Psychological Association (sponsor) writes in support, "this bill would make an applicant for licensure eligible to take all examinations required for licensure as soon as all coursework required for such a doctoral degree has been completed, as documented by a written certification from the registrar of the applicant's educational institution or program. This important bill was created in response to the CPA membership survey conducted in 2022 that indicated extremely long wait times at the Board of Psychology. Since the survey was completed and CPA shared the results with the Board of Psychology, wait times have improved. This bill is necessary to create efficiencies at the Board to help avoid long delays in the future."

Arguments in Opposition

None on file

FISCAL COMMENTS

According to the Senate Appropriations Committee, pursuant to Senate Rule 28.8, no significant state costs anticipated.

VOTES:

ASM BUSINESS AND PROFESSIONS: 18-0-1

YES: Berman, Flora, Alanis, Alvarez, Bains, Bonta, Chen, Dixon, Gipson, Grayson, Irwin, Jackson, Lee, Lowenthal, McKinnor, Stephanie Nguyen, Joe Patterson, Ting

ABS, ABST OR NV: McCarty

ASM APPROPRIATIONS: 14-0-2

YES: Holden, Megan Dahle, Calderon, Wendy Carrillo, Dixon, Mike Fong, Hart, Lowenthal, Mathis, Papan, Robert Rivas, Sanchez, Weber, Wilson

ABS, ABST OR NV: Bryan, Pellerin

ASSEMBLY FLOOR: 79-0-1

YES: Addis, Aguiar-Curry, Alanis, Alvarez, Arambula, Bains, Bauer-Kahan, Bennett, Berman, Boerner, Bonta, Bryan, Calderon, Juan Carrillo, Wendy Carrillo, Cervantes, Chen, Connolly, Megan Dahle, Davies, Dixon, Essayli, Flora, Mike Fong, Vince Fong, Friedman, Gabriel, Gallagher, Garcia, Gipson, Grayson, Haney, Hart, Holden, Hoover, Irwin, Jackson, Jones‑Sawyer, Kalra, Lackey, Lee, Low, Lowenthal, Maienschein, Mathis, McCarty, McKinnor, Muratsuchi, Stephanie Nguyen, Ortega, Pacheco, Papan, Joe Patterson, Pellerin, Petrie-Norris, Quirk-Silva, Ramos, Reyes, Luz Rivas, Robert Rivas, Rodriguez, Blanca Rubio, Sanchez, Santiago, Schiavo, Soria, Ta, Ting, Valencia, Villapudua, Waldron, Wallis, Ward, Weber, Wicks, Wilson, Wood, Zbur, Rendon

ABS, ABST OR NV: Jim Patterson

SENATE FLOOR: 39-0-1

YES: Allen, Alvarado-Gil, Archuleta, Ashby, Atkins, Becker, Blakespear, Bradford, Caballero, Cortese, Dahle, Dodd, Durazo, Eggman, Glazer, Gonzalez, Grove, Hurtado, Jones, Laird, Limón, McGuire, Menjivar, Min, Newman, Nguyen, Niello, Ochoa Bogh, Portantino, Roth, Rubio, Seyarto, Skinner, Smallwood-Cuevas, Stern, Umberg, Wahab, Wiener, Wilk

ABS, ABST OR NV: Padilla

UPDATED

VERSION: August 14, 2023

CONSULTANT: Vincent Chee / B. & P. / (916) 319-3301 FN: 0001780

 THIRD READING  

Bill No: AB 282

Author: Aguiar-Curry (D)

Amended: 8/14/23 in Senate

Vote: 21

SENATE BUS., PROF. & ECON. DEV. COMMITTEE: 12-0, 7/3/23

AYES: Roth, Nguyen, Alvarado-Gil, Archuleta, Ashby, Becker, Eggman, Glazer, Niello, Smallwood-Cuevas, Wahab, Wilk

NO VOTE RECORDED: Dodd

SENATE APPROPRIATIONS COMMITTEE: Senate Rule 28.8

ASSEMBLY FLOOR: 79-0, 4/27/23 (Consent) - See last page for vote

SUBJECT: Psychologists: licensure

SOURCE: California Council of Community Behavioral Health Agencies

California Psychological Association

DIGEST:

This bill authorizes an applicant for licensure as a psychologist to take all examinations required for licensure when they have completed academic coursework required for a doctoral degree, as specified.

ANALYSIS:

Existing law:

1. Establishes the Board of Psychology (Board) to license and regulate psychologists. (Business and Professions Code (BPC) § 2920)
   
2. States that no person may engage in the practice of psychology or represent himself or herself as a psychologist without a license issued by the Board, as specified. Defines the “practice of psychology” as rendering or offering to render to individuals, groups, organizations, or the public any psychological services involving the application of psychological principles, methods, and procedures of understanding, predicting, and influencing behavior, such as the principles pertaining to learning, perception, motivation, emotions, and interpersonal relationships, and the methods and procedures of interviewing, counseling, psychotherapy, behavior modification, and hypnosis; and of constructing, administering, and interpreting tests of mental abilities, aptitudes, interests, attitudes, personality characteristics, emotions, and motivations. (BPC § 2903)
   
3. Requires an applicant for licensure to possess an earned doctoral degree in any of a number of specified subjects that is obtained from a college or institution of higher education accredited by a regional accrediting agency recognized by the United States Department of Education. Authorizes the Board to make the final determination as to whether a degree meets these requirements. Requires an applicant for licensure to have engaged for at least two years in supervised professional experience under the direction of a licensed psychologist or under suitable alternative supervision, at least one year of which shall have occurred after the applicant was awarded the qualifying doctoral degree. (BPC § 2914)
4. Requires an applicant for licensure to take and pass any examination required by the board and pay related examination fees. (BPC § 2941)
5. Requires an applicant to successfully take and pass the Association of State and Provincial Psychology Boards' Examination for Professional Practice in Psychology (EPPP) and the California Psychology Laws and Ethics Examination (CPLEE). Specifies that an applicant is eligible to take the EPPP upon completion of a qualifying doctorate degree and 1500 hours of qualifying professional experience. Specifies that an applicant must pass the EPPP and complete all 3000 hours of supervised professional experience prior to being eligible for the CPLEE, whichever is applicable. Provides that upon application, the Board will notify applicants of their eligibility to take the EPPP. (Title 16 California Code of Regulations (CCR) § 1388)

This bill:

1. Authorizes an applicant for licensure who has completed all academic coursework required for a doctoral degree, as specified, and documented by a written certification from the registrar of the applicant’s educational institution or program, to take any and all examinations required for licensure.
2. States if a national licensing examination entity approved by the board imposes additional eligibility requirements beyond the completion of academic coursework, the board shall implement a process to verify that an applicant has satisfied those additional eligibility requirements. 
   
3. States “academic coursework” does not include participation in an internship or writing a dissertation or thesis.

Background

Applicants for a psychologist license must have a qualifying doctorate degree, complete a minimum of 3,000 hours of supervised professional experience, and take and pass the national EPPP, which is administered by the Association of State and Provincial Psychology Boards (ASPPB) and the CPLEE, which is administered by the Board. The EPPP and CPLEE are both computer-based examinations. Psychological assistants must earn a qualifying master’s degree, must be registered to a licensed psychologist or a Board-certified psychiatrist as employees, and may provide limited psychological services under the direct supervision of the psychologist or psychiatrist with whom they are registered. Registered psychologists must earn a qualifying doctoral degree, must complete a specified number of hours of professional experience under supervision, and can only engage in psychological activities at qualifying nonprofit community agencies.

Applicants are eligible to take the EPPP when they complete their doctorate degree and 1500 hours of qualifying professional experience. After they pass the EPPP, the applicant must complete all 3000 hours of supervised professional experience to be eligible for the CPLEE.

Exceptions to the EPPP requirements, but not the CPLEE requirements, are provided for:

• A California-licensed psychologist who has been licensed for at least five years and has allowed their license to cancel by not renewing the license for at least three years, for an applicant who has been licensed in another state, Canadian province, or U.S. territory for at least two years.
• An applicant who holds a Certificate of Professional Qualification issued by the ASPPB.
• An applicant credentialed as a Health Service Provider in Psychology by the National Register of Health Service Providers in Psychology who has been licensed based on a doctoral degree in another state, Canadian province, or U.S. territory for a minimum of two years.
• An applicant for licensure as a psychologist who is certified by the American Board of Professional Psychology and has been licensed based on a doctoral degree in another state, Canadian province, or U.S. territory. Although the EPPP is waived under this section, an applicant must file a complete application and meet all current licensing requirements not addressed above, including payment of any fees, take and pass CPLEE and not been subject to discipline.

According to the author, ASPPB is in the process of converting the licensure exam into two parts. Part One will focus on clinical knowledge and will be taken after coursework has been completed. Part Two will be experienced-based and taken after completion of the clinical experience required for licensure. This, the Author argues, could lead to greater wait processing times for licensees, where each step in the licensure process typically took two-four months to process already, where the total wait time often lasts about one year.

ASPPB approved a motion during its June meeting affirming that Part Two of the exam experience cannot, in its view, be taken until Part One of the exam experience, degree conferral, and completion of supervised experience as determined by the jurisdictional licensing or registration authority have all been completed.

During the 2020-2021 sunset review oversight of the Board, it was reported that the Board has experienced increases in the average time to process complete applications and a significant increase in the average time to process incomplete applications. The number of pending applications had outpaced completed applications. In response to this trend, the Board conducted a comprehensive review of its statutes and regulations addressing how licensure can be obtained. The Board identified sections it believed creates undue barriers to licensure, or are inconsistent with training environments, education, and new technologies related to the practice of psychology. The Board will be pursuing statutory and regulatory changes to enact these proposed changes.

FISCAL EFFECT: Appropriation: No Fiscal Com.: Yes Local: No

SUPPORT: (Verified 8/22/23)

California Council of Community Behavioral Health Agencies (co-source)

California Psychological Association (co-source)

Association of Independent California Colleges & Universities
California Access Coalition
California Alliance of Child and Family Services
Govern for California

Portia Bell Hume Behavioral Health and Training Center
Steinberg Institute
Sycamores

Tessie Cleveland Community Services Corporation

OPPOSITION: (Verified 8/22/23)

Association of State and Provincial Psychology Boards
California Board of Psychology

ARGUMENTS IN SUPPORT: Supporters believe that this bill is necessary to create efficiencies at the Board to help avoid long delays in the future. They note that streamlining the licensure process would significantly reduce applicants' burdensome wait times and improve patient care access, as well as reduce the workload for licensing staff.

ARGUMENTS IN OPPOSITION: The California Board of Psychology requested an amendment to qualify what academic coursework includes and the Association of State and Provincial Psychology Boards believes that licensing boards should determine when applicants can appropriately sit for licensing examinations.

ASSEMBLY FLOOR: 79-0, 4/27/23

AYES: Addis, Aguiar-Curry, Alanis, Alvarez, Arambula, Bains, Bauer-Kahan, Bennett, Berman, Boerner, Bonta, Bryan, Calderon, Juan Carrillo, Wendy Carrillo, Cervantes, Chen, Connolly, Megan Dahle, Davies, Dixon, Essayli, Flora, Mike Fong, Vince Fong, Friedman, Gabriel, Gallagher, Garcia, Gipson, Grayson, Haney, Hart, Holden, Hoover, Irwin, Jackson, Jones-Sawyer, Kalra, Lackey, Lee, Low, Lowenthal, Maienschein, Mathis, McCarty, McKinnor, Muratsuchi, Stephanie Nguyen, Ortega, Pacheco, Papan, Joe Patterson, Pellerin, Petrie-Norris, Quirk-Silva, Ramos, Reyes, Luz Rivas, Robert Rivas, Rodriguez, Blanca Rubio, Sanchez, Santiago, Schiavo, Soria, Ta, Ting, Valencia, Villapudua, Waldron, Wallis, Ward, Weber, Wicks, Wilson, Wood, Zbur, Rendon

NO VOTE RECORDED: Jim Patterson

Prepared by: Dana Shaker / B., P. & E.D. /

8/23/23 14:21:01

**** END ****

SENATE COMMITTEE ON

BUSINESS, PROFESSIONS AND ECONOMIC DEVELOPMENT

Senator Richard Roth, Chair

2023 - 2024 Regular

Bill No: AB 282 Hearing Date: July 3, 2023

Subject: Psychologists: licensure

SUMMARY:

Authorizes an applicant for licensure as a psychologist to take all examinations required for licensure when they have completed academic coursework required for a doctoral degree, as specified.

Existing law:

1. Establishes the Board of Psychology (Board) to license and regulate psychologists. (Business and Professions Code (BPC) § 2920)
   
2. States that no person may engage in the practice of psychology or represent himself or herself as a psychologist without a license issued by the Board, as specified. Defines the “practice of psychology” as rendering or offering to render to individuals, groups, organizations, or the public any psychological services involving the application of psychological principles, methods, and procedures of understanding, predicting, and influencing behavior, such as the principles pertaining to learning, perception, motivation, emotions, and interpersonal relationships, and the methods and procedures of interviewing, counseling, psychotherapy, behavior modification, and hypnosis; and of constructing, administering, and interpreting tests of mental abilities, aptitudes, interests, attitudes, personality characteristics, emotions, and motivations. (BPC § 2903)
   
3. Requires an applicant for licensure to possess an earned doctoral degree in any of a number of specified subjects that is obtained from a college or institution of higher education accredited by a regional accrediting agency recognized by the United States Department of Education. Authorizes the Board to make the final determination as to whether a degree meets these requirements. Requires an applicant for licensure to have engaged for at least two years in supervised professional experience under the direction of a licensed psychologist or under suitable alternative supervision, at least one year of which shall have occurred after the applicant was awarded the qualifying doctoral degree. (BPC § 2914)
4. Requires an applicant for licensure to take and pass any examination required by the board and pay related examination fees. (BPC § 2941)
5. Requires an applicant to successfully take and pass the Association of State and Provincial Psychology Boards' Examination for Professional Practice in Psychology (EPPP) and the California Psychology Laws and Ethics Examination (CPLEE). Specifies that an applicant is eligible to take the EPPP upon completion of a qualifying doctorate degree and 1500 hours of qualifying professional experience. Specifies that an applicant must pass the EPPP and complete all 3000 hours of supervised professional experience prior to being eligible for the CPLEE, whichever is applicable. Provides that upon application, the Board will notify applicants of their eligibility to take the EPPP. (Title 16 California Code of Regulations (CCR) § 1388)

This bill:

1. Authorizes an applicant for licensure who has completed all academic coursework required for a doctoral degree, as specified, and documented by a written certification from the registrar of the applicant’s educational institution or program, to take any and all examinations required for licensure.
   
2. States “academic coursework” does not include participation in an internship or writing a dissertation or thesis.

FISCAL EFFECT:

According to the Assembly Appropriations Committee, the Board projects minor and absorbable costs to implement this bill.

COMMENTS:

1. Purpose. The Sponsors of the bill are the California Psychological Association and the California Council of Community Behavioral Health Agencies. According to the Author, “This bill reduces the required steps of the BOP review process to determine if an applicant qualifies for their exam. By reducing the steps, processing delays will be reduced and applicants will have a clear streamlined process path of licensure.”

The Author cites recent survey data of psychologists conducted by the California Psychological Association as further justification for this measure. The 2022 survey results indicated “significant wait times at each step in the licensing process at the Board of Psychology. Each sequential step in the licensure process typically took 2-4 months to process, for a total wait time often lasting about one year. In addition, almost 60% of respondents reported that the delays created financial hardship and over 30% reported the delays caused interruptions in patient care…Psychologists answered that financial hardship (due to delay in qualify for employment opportunities), difficulty hiring, and interruptions in patient care were some of the top detrimental consequences experienced. In its letter, the California Psychological Association noted that once it made the Board aware of these survey results, wait times have improved.”

According to the Author, “by streamlining the process of licensee applicants to qualify for their licensing exam, this bill will help California’s trained psychologists enter the workforce without delays. Applicants will be permitted to take their exam after they have verified completed their academic coursework.”

According to Sponsors, currently it takes nine months from start to finish the licensing and examination process, largely due to the Board’s processing times.

1. Background.

Board of Psychology. The Board regulates licensed psychologists, registered psychological assistants, and registered psychologists. The Board is funded by license, application, and examination fees, and receives no revenue from California’s General Fund. The Board is comprised of nine members (five licensed psychologists and four public members) who are appointed to four-year terms. In 2021, there were approximately 25,000 licensees under the Board’s jurisdiction.

The Board’s mission is to “protect consumers of psychological services by licensing psychologists, regulating the practice of psychology, and supporting the evolution of the profession.” According to the Board’s strategic plan, the Board focuses on the following areas: protecting the health, safety, and welfare of consumers of psychological services; advocating for the highest standards of professional psychology; and, empowering consumers and licensees through public and professional education.

Applicants for a psychologist license must have a qualifying doctorate degree, complete a minimum of 3,000 hours of supervised professional experience, and take and pass the national Examination for Professional Practice in Psychology (EPPP), which is administered by the Association of State and Provincial Psychology Boards (ASPPB) and the California Psychology Laws and Ethics Examination (CPLEE), which is administered by the Board. The EPPP and CPLEE are both computer-based examinations. Psychological assistants must earn a qualifying master’s degree, must be registered to a licensed psychologist or a Board-certified psychiatrist as employees, and may provide limited psychological services under the direct supervision of the psychologist or psychiatrist with whom they are registered. Registered psychologists must earn a qualifying doctoral degree, must complete a specified number of hours of professional experience under supervision, and can only engage in psychological activities at qualifying nonprofit community agencies.

Applicants are eligible to take the EPPP when they complete their doctorate degree and 1500 hours of qualifying professional experience. After they pass the EPPP, the applicant must complete all 3000 hours of supervised professional experience to be eligible for the CPLEE.

Exceptions to the EPPP requirements, but not the CPLEE requirements, are provided for:

• a California-licensed psychologist who has been licensed for at least five years and has allowed their license to cancel by not renewing the license for at least three years, for an applicant who has been licensed in another state, Canadian province, or U.S. territory for at least two years
• an applicant who holds a Certificate of Professional Qualification issued by the Association of State and Provincial Psychology Boards
• an applicant credentialed as a Health Service Provider in Psychology by the National Register of Health Service Providers in Psychology who has been licensed based on a doctoral degree in another state, Canadian province, or U.S. territory for a minimum of two years
• an applicant for licensure as a psychologist who is certified by the American Board of Professional Psychology (ABPP) and has been licensed based on a doctoral degree in another state, Canadian province, or U.S. territory (f) Although the EPPP is waived under this section, an applicant must file a complete application and meet all current licensing requirements not addressed above, including payment of any fees, take and pass the California Psychology Law and Ethics Examination (CPLEE), and not been subject to discipline.

According to the Author, ASPPB is in the process of converting the licensure exam into two parts. Part One will focus on clinical knowledge and will be taken after coursework has been completed. Part Two will be experienced-based and taken after completion of the clinical experience required for licensure. This, the Author argues, could lead to greater wait processing times for licensees, where each step in the licensure process typically took two-four months to process already, where the total wait time often lasts about one year.

ASPPB approved a motion during its June meeting affirming that Part Two of the exam experience cannot, in its view, be taken until Part One of the exam experience, degree conferral, and completion of supervised experience as determined by the jurisdictional licensing or registration authority have all been completed.

During the 2020-2021 sunset review oversight of the Board, it was reported that the Board has experienced increases in the average time to process complete applications and a significant increase in the average time to process incomplete applications. The number of pending applications had outpaced completed applications. In response to this trend, the Board conducted a comprehensive review of its statutes and regulations addressing how licensure can be obtained. The Board identified sections it believed create undue barriers to licensure, or are inconsistent with training environments, education, and new technologies related to the practice of psychology. The Board will be pursuing statutory and regulatory changes to enact these proposed changes.

1. Arguments in Support. California Psychological Association writes in support: “This bill would make an applicant for licensure eligible to take all examinations required for licensure as soon as all coursework required for such a doctoral degree has been completed, as documented by a written certification from the registrar of the applicant’s educational institution or program. This important bill was created in response to the CPA membership survey conducted in 2022 that indicated extremely long wait times at the Board of Psychology. Since the survey was completed and CPA shared the results with the Board of Psychology, wait times have improved. This bill is necessary to create efficiencies at the Board to help avoid long delays in the future.”

The Association of Independent California Colleges & Universities writes in support: “In short, current practices create cumbersome barriers that delay these trained individuals to begin providing much-needed care in a timelier fashion, without sacrificing quality of services to patients.”

California Access Coalition, California Council of Community Behavioral Health Agencies states that “According to the California Health Care Foundation, one in seven Californians experience a mental health condition. However, the licensure process for psychologists has been fraught with significant delays, as found in a member survey conducted in 2022 by the California Psychological Association (CPA).” The organizations believe that streamlining the licensure process would significantly reduce applicants' burdensome wait times and improve patient care access, as well as reduce the workload for licensing staff at the Board.

California Alliance of Child and Family Services says that nearly 1 in 7 California adults experiences a mental illness, and 1 in 14 children has an emotional disturbance that limits functioning in family, school, or community activities…Children and youth from historically underserved and marginalized communities are in an especially vulnerable position. For California to provide extensive access to mental health treatment, there must be a reduction in applicant wait times during the examination process for psychologists. By shortening extensive waiting periods for applicants, children and families searching for mental health treatment will be able to meet with a licensed psychologist sooner rather than later. This result guarantees better access to care and, in turn, will improve patient outcomes.”

Govern for California writes in support: “As Californians recover from the COVID-19 pandemic, the importance of mental health and access to care has become evident…the Board of Psychology has experienced a notable increase in the average time to process complete applications for licensure and a significant increase in the average time to process incomplete applications for licensure. This bill makes a valuable change to reduce one of the significant delays by allowing applicants who have completed coursework for their doctoral degree to take the required examinations any time with written certification from the registrar instead of requiring step by step approval from the Board. Further, this bill aligns with changes being made by the Association of State and Provincial Psychology Board with the national licensure examination to have one part focusing on clinical knowledge and the second to clinical experience. Removing unnecessary licensing delays will help California’s workforce pipeline for mental health providers.”

Steinberg Institute and Sycamores write in support: “The intent of this legislation is to streamline the licensure process to reduce burdensome wait times for applicants and to improve access to care.”

1. Arguments in Opposition. The California Board of Psychology writes in opposition unless amended: “The Board supports and agrees with the author's intent in granting applicants the flexibility to take the required licensure exams, however, the Board requests the following amendment:

(d) An applicant for licensure shall take and pass the examination required by Section 2941 unless otherwise exempted by the board under this chapter. An applicant for licensure who has completed all academic coursework required for a doctoral degree as required by subdivision (b), as documented by a written certification from the registrar of the applicant’s educational institution or program, shall be eligible to take any and all examinations required for licensure, as specified by the Board. For purposes of this subdivision, “academic coursework” does not include participation in an internship or writing a dissertation or thesis.

The Association of State and Provincial Psychology Boards writes in opposition unless it is amended to include the Board’s requested language. According to the organization, “[EPPP] Part 2 is a skills-based examination assessing an applicant’s competencies in providing psychological services. This exam is intended to be administered after an applicant completes their necessary training and supervised experience. AB 282 as written would allow applicants to take this examination prior to obtaining their advanced training and supervised experience. One of the unintended consequences, if AB 282 were to be adopted in its current form, would likely be a negative impact in that applicants who take the skills part of the licensing examination after completion of academic coursework, but prior to obtaining the necessary training and supervised experience, likely would not pass the examination, since they would not have the requisite knowledge and experience required to pass the EPPP (Part 2 - Skills).” The organization notes that as amended, “California would continue to be consistent with other states in the approach that is taken to allow their licensing boards to determine when applicants can appropriately sit for licensing examinations. This in turn would benefit potential examination candidates from additional costs associated with having to retake the examination due to not having the experience and knowledge that is required.”

1. Policy Comments, Questions, and Amendments.

Process Adjustments. While the effort to decrease licensing processing timeframes at healing arts board is laudable, and the outcome in this particular space, if increased opportunities for behavioral and mental health professionals are available, will certainly benefit patients by providing greater access to critical care, it is important to ask whether adjusting the process will make a meaningful difference or if there are elements of the Board’s process that deserve comprehensive review and updates. Are there other extraneous steps in the existing process that could be condensed for efficiency? Simply allowing licensees to take an exam when they choose may not be the best procedural answer to the question of how to address lengthy license processing times that impact the ability for providers to meet necessary requirements in order to deliver care.

Drafting Challenges and Limitation on Examination Type. This bill authorizes an applicant for licensure to take “any and all examinations required for licensure” upon completion of academic coursework. However current law requires applicant for licensure possess an earned doctoral degree. Would an applicant even be eligible to apply without possession of a degree and simply by virtue of having completed coursework, since this bill does not clarify provisions in existing law related to all licensure requirements and instead only updates one statement outlining the necessity of applicants taking the Board exam?

Further, the authority provided in this bill to take “any and all examinations required for licensure” means that in theory, a person could take Parts One and Two of the national EPPP after they submit proof of academic course completion. The bill proponents assert that an individual would only take and pay for examinations they are ready for, however the lack of clarity in the bill to confirm that the skills-based portion of the national examination is not taken until the applicant has a degree and has completed supervised experience requirements could lead to unintended consequences. In order to ensure that the bill is implementable and does not directly conflict with existing statute and regulations, and in order to ensure that only certain tests may be taken without meeting all licensure requirements, moving forward the Author should consider tasking the Board with reviewing the appropriateness of the steps required for applicant review and should work with the Board to determine necessary changes and steps to achieve the goal of quicker licensing processing timeframes.

SUPPORT AND OPPOSITION:

Support:

Association of Independent California Colleges & Universities
California Access Coalition
California Alliance of Child and Family Services
California Council of Community Behavioral Health Agencies

California Psychological Association
Govern for California
Steinberg Institute
Sycamores

Tessie Cleveland Community Services Corporation

Opposition:

Association of State and Provincial Psychology Boards
California Board of Psychology

-- END --

Date of Hearing: April 19, 2023

ASSEMBLY COMMITTEE ON APPROPRIATIONS

Chris Holden, Chair

ABPCA Bill Id:AB 282

Author:(Aguiar-Curry) – As Amended Ver:March 21, 2023

Urgency: No State Mandated Local Program: No Reimbursable: No

SUMMARY:

This bill allows an applicant for licensure as a psychologist to take the required licensure examinations immediately after completing all academic coursework for the doctoral degree.

FISCAL EFFECT:

The Board of Psychology (Board) projects minor and absorbable costs to implement this bill.

COMMENTS:

1. Purpose. This bill is sponsored by the California Psychological Association (CPA). According to the author:

Current law requires each applicant for licensure as a psychologist to undergo a lengthy process of several consecutive steps resulting in extensive waiting periods for some applications. This causes delays and interruptions to the consumers trying to access mental health treatment and creates a financial burden for the license applicants. This bill will help reduce applicant wait times at the Board of Psychology by streamlining the examination process. These changes will not affect the quality of the licensing process, but will help to remove…delays in the review process and help associate clinicians providing behavioral healthcare and on the road to completing their clinical hours required for licensure.

1. Board Licensing Process. To obtain a psychology license from the Board, an applicant who has a qualifying doctoral degree must: apply to take, and subsequently register and complete two examinations sequentially, complete specified prelicensure courses, complete 3,000 hours of supervised professional experience, request initial licensure, and obtain a criminal history background check. Board fees required at four steps of the process add up to more than $1,400. In the past three fiscal years, the Board has experienced a notable increase in the average time to process applications for licensure. In response, Board staff reviewed all statutory and regulatory sections related to pathways to licensure and compiled a list of proposed improvements. The Board subsequently engaged with stakeholders, hosting review meetings with professional associations, schools, training directors, and applicants, to get feedback on the proposed changes.
   
   The CPA conducted a member survey in 2022 and found significant wait times at each step in the Board’s licensing process. Each sequential step in the licensure process typically took 2-4 months to process, for a total wait time often lasting close to one year. Almost 60% of respondents reported that the delays created financial hardship and over 30% reported the delays caused interruptions in patient care. The Steinberg Institute explains this bill will allow applicants for psychology licensure to take the required examinations at any time after completing qualifying coursework, rather than in a set sequence, with the intent of streamlining the licensure process to reduce burdensome wait times for applicants and to improve access to care.

Analysis Prepared by: Allegra Kim / APPR. / (916) 319-2081

Date of Hearing: March 28, 2023

ASSEMBLY COMMITTEE ON BUSINESS AND PROFESSIONS

Marc Berman, Chair

ABPCA Bill Id:AB 282

Author:(Aguiar-Curry) – As Amended Ver:March 21, 2023

SUBJECT: Psychologists: licensure.

SUMMARY: Allows an applicant for licensure as a psychologist to take the required examinations immediately after completing qualifying coursework.

EXISTING LAW:

1. Establishes the Board of Psychology (board) within the Department of Consumer Affairs (DCA), responsible for the licensure and regulation of psychologists, and prohibits a person from engaging in the practice of psychology or representing oneself as a psychologist without a license issued by the board, unless specifically exempted. (Business Professions Code (BPC) § 2900 et seq.)
2. Defines the practice of psychology as rendering or offering to render to individuals, groups, organizations, or the public any psychological service involving the application of psychological principles, methods, and procedures of understanding, predicting, and influencing behavior, such as the principles pertaining to learning, perception, motivation, emotions, and interpersonal relationships. (BPC § 2903(a))
3. Provides that the application of these principles and methods includes, but is not restricted to: assessment, diagnosis, prevention, treatment, and intervention to increase effective functioning of individuals, groups, and organizations. (BPC § 2903(b))
4. Describes the use of psychological methods in a professional relationship to assist a person or persons to acquire greater human effectiveness or to modify feelings, conditions, attitudes, and behaviors that are emotionally, intellectually, or socially ineffectual or maladaptive. (BPC § 2903(c))
5. Clarifies that nothing in the Psychology Licensing Law restricts activities and services of a graduate student or psychology intern enrolled in a doctoral program leading to one of the degrees listed in subdivision (b) of Section 2914 or a trainee in a post-doctoral placement approved by the American Psychological Association, the Association of Psychology Postdoctoral and Internship Centers, or the California Psychology Internship Council. (BPC § 2911)
6. Requires by January 1, 2020, an applicant for licensure shall possess an earned doctoral degree in any of the following: (BPC § 2914(a))

(a) Psychology with the field of specialization in clinical, counseling, school, consulting, forensic, industrial, or organizational psychology.

(b) Education with the field of specialization in counseling psychology, educational psychology, or school psychology.

(c) A field of specialization designed to prepare graduates for the professional practice of psychology. (BPC § 2914(b)(1))

1. Requires that an applicant for licensure shall have engaged for at least two years in supervised professional experience under the direction of a licensed psychologist, the specific requirements of which shall be defined by the board in its regulations, or under suitable alternative supervision as determined by the board in regulations duly adopted, at least one year of which shall have occurred after the applicant was awarded the qualifying doctoral degree. (BPC § 2914(c)(1))
2. Stipulates that supervision by a licensed psychologist may be provided in real time, which is defined as through in-person or synchronous audiovisual means, in compliance with federal and state laws related to patient health confidentiality and also requires the supervising licensed psychologist submit verification of the experience to the trainee as prescribed by the board. (BPC § 2914(c)(1))
3. Requires that an applicant for licensure take and pass the examination unless exempted by the board. (BPC §2914(d))
4. Requires an applicant for licensure complete coursework or provide evidence of training in the detection and treatment of alcohol and other chemical substance dependency. (BPC §2914(e))
5. Requires that an applicant for licensure shall complete coursework or provide evidence of training in spousal or partner abuse assessment, detection, and intervention. (BPC § 2914(f))

THIS BILL:

1. Authorizes an applicant for licensure who has completed all academic coursework required for a required doctoral degree to be eligible to take any and all examinations required for licensure.
2. Requires the completion to be documented by a written certification from the registrar of the applicant’s educational institution or program,
3. Defines academic coursework as not including participation in an internship or writing a dissertation or thesis.

FISCAL EFFECT: Unknown; this bill is keyed fiscal by the Legislative Counsel.

COMMENTS:

Purpose.

This bill is sponsored by the California Psychological Association. According to the author, “Current law requires each applicant for licensure as a psychologist to undergo a lengthy process of several consecutive steps resulting in extensive waiting periods for some applications. This causes delays and interruptions to the consumers trying to access mental health treatment and creates a financial burden for the license applicants. This bill will help reduce applicant wait times at the Board of Psychology by streamlining the examination process. These changes will not affect the quality of the licensing process, but will help to remove of delays in the review process and help associate clinicians providing behavioral healthcare and, on the road, to completing their clinical hours required for licensure.”

Background.

The board has experienced a notable increase in the average time to process complete applications for licensure and a significant increase in the average time to process incomplete applications for licensure in the past three fiscal years. Additionally, the number of pending applications has outpaced completed applications. In response to this trend, board staff began in 2015 to review all statutory and regulatory sections related to pathways to licensure and compiled a list of proposed improvements. The board subsequently engaged with stakeholders, hosting review meetings that included professional associations, schools, training directors, and applicants, to get feedback on the board’s proposed changes.

This measure is sponsored by the California Psychological Association (CPA) in response to a 2022 survey of its professional membership. The 2022 member survey suggested significant wait times at every step during the licensing process at the Board of Psychology, which resulted in delays to consumers accessing treatment. Each sequential step during the licensure process typically took two to four months to process. In the end, the survey reported that individuals working toward licensure typically experience a wait time lasting about one year. In addition, CPA’s 2022 survey of its professional membership, almost 60% reported that the delays created financial hardship and over 30% reported the delays caused interruptions in patient care.

Earlier this year, the board examined CPA’s 2022 survey of its membership and acknowledged significant delays for some applicants. The Board noted that there were exorbitant delays for some applicants, who reported 120-day plus waiting periods for some applications. The Board has improved the current wait times, but this bill may help to avoid elongated wait times in future years.

Prior Related Legislation.

AB 2754 (Bauer-Kahan), Chapter 163, Statutes 2022, permits the supervision of a psychologist licensure applicant, and of a registered psychological associate, to be provided through in-person or synchronous audiovisual means and takes effect immediately.

SB 801 (Archuleta), Chapter 647, Statutes 2021, made various changes to the regulation of a number of licensed professionals by the Board of Behavioral Sciences (BBS) and to the Board of Psychology (BOP) intended to improve oversight of licensees stemming from the joint sunset review oversight of the BBS and BOP.

ARGUMENTS IN SUPPORT:

The California Psychological Association, the bill’s sponsor, states that “this bill would make an applicant for licensure eligible to take all examinations required for licensure as soon as all coursework required for such a doctoral degree has been completed, as documented by a written certification from the registrar of the applicant’s educational institution or program. This important bill was created in response to the CPA membership survey conducted in 2022 that indicated extremely long wait times at the Board of Psychology. Since the survey was completed and CPA shared the results with the Board of Psychology, wait times have improved. This bill is necessary to create efficiencies at the Board to help avoid long delays in the future.”

The Steinberg Institute writes in support that “they are pleased to support this bill to modify the licensure process at the Board of Psychology to reduce delays in taking the required licensing examinations and becoming licensed as a psychologist. To reduce delays, this bill would allow applicants for psychology licensure to take the required examinations at any time after completing a qualifying coursework, rather than in a set sequence. The intent of this legislation is to streamline the licensure process to reduce burdensome wait times for applicants and to improve access to care. Amidst the behavioral health workforce shortage, it is critical to do all we can to get new clinicians into the field quickly and efficiently.”

The Association of Independent California Colleges and Universities support the bill and add that “the need for mental health services is tremendous. According to data from the Kaiser Family Foundation, nearly one-third of California adults reported symptoms of anxiety and/or depressive disorder in February 2023, yet 28.5% of adults reporting these symptoms had an unmet need for counseling or therapy. More must be done to help individuals receive the care that they need, and the bill is an important proposal that helps streamline the onramp for new graduates to enter the workforce.”

ARGUMENTS IN OPPOSITION:

None on file.

REGISTERED SUPPORT:

California Psychological Association (Sponsor)

Association of Independent California Colleges and Universities

California Access Coalition

California Council of Community Behavioral Health Agencies

Steinberg Institute

REGISTERED OPPOSITION:

None on file.

Analysis Prepared by: Annabel Smith / B. & P. / (916) 319-3301