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New Hampshire Association of School Psychologists (NHASP) |
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American Psychological Association’s Proposed Revision of
the Model Licensure Act: Important Links: The Model Licensure Act is a policy document developed as a prototype for drafting state legislation regulating the practice of psychology. APA encourages state legislatures to use the language of this document as the model for their own state licensure law. The Model Act for State Licensure was first developed in 1955 and has been revised twice, most recently in 1987. In all previous versions, school psychology was exempted from the requirement that the term psychologist be restricted to doctoral level professionals. If the current revision passes, this will change. Current wording: It is recognized that school psychologists who are certified by the state education agency are permitted to use the term school psychologist or certified school psychologist as long as they are practicing in the public schools. Proposed Revision: Only those persons who are credentialed by state education agencies to provide psychoeducational services and who possess a doctoral degree in psychology from a regionally accredited institution may use the title “school psychologist” or “certified school psychologist.” Such persons shall be restricted in their practice and in the use of such title to those settings under the purview of the state education agency. This provision is not intended to apply to licensed psychologists. What does this mean for the practice of school psychology in New Hampshire?
What can you do to voice your opinion regarding this proposed revision? Contact the American Psychological Association [http://forms.apa.org/practice/modelactlicensure/] to submit your comments or visit the NASP website [http://www.nasponline.org/standards/apamla.aspx] to use the materials they have prepared. Alternatively, model letters appear on the NHASP website (www.nhaspweb.org) that you may consider sending as is or adapting to your needs. The may be sent to the American Psychological Association, 750 First Street, NE, Washington, DC 20002-4242. Your response must be received by APA no later than June 5, 2009. It is time to take action. This is an important issue with implications y for the practice of school psychology in New Hampshire, but more importantly for the students in New Hampshire schools. MLA Letter #1 To whom it may concern, I am writing to express my profound concerns with several changes in the new Model Licensure Act (MLA) draft. I list these concerns below by section. I am a practicing school psychologist in NH and a member of my state association of school psychologists and the National Association of School Psychologists. Section J: Exemptions I strongly oppose the proposed change to section J of the MLA that removes the exemption for specialist level school psychologists to use their titles. I urge APA to strike this change from the proposed revisions and reinstate the long-held exemption for all school psychologists. Implementing this change would inevitably have a negative impact on children and their education. Specialist and doctoral level school psychologists are experts in psychology and education. This proposed change in the MLA exemption would unjustly remove the rights of more than 75% of practicing school psychologists (20,000+) to use the title for which they are legitimately credentialed and qualified. Section B: Definitions The definition of the “practice of psychology” seeks to clarify the breadth of specific services rendered by psychologists. Within this definition, all of the services provided by school psychologists are addressed in whole or in part. This portion of the Model Act defines psychological practice and essentially removes the right of non-doctoral school psychologists legitimately credentialed by State Education Agencies to engage in these practices. This removal constitutes a restraint of trade (or professional practice), which could put states in violation of interstate commerce law and place them at risk for civil litigation. Section G: Limitations of Practice; Maintaining and Expanding Competence I strongly oppose the proposed revision that changes school psychology from an area of specialization to a foundation of psychology. By maintaining that school psychology is an area of specialization, the public is protected from being provided school psychological services by a professional that is not adequately trained in school psychology. Preamble and Section A. Declaration of Policy I strongly oppose language in the APA MLA that would potentially limit and change the practice of school psychologists without empirical or evidentiary grounds. I urge APA to revise the proposed changes in the MLA that may cause this problem, including the Preamble and the Declaration of Policy. Sincerely,
MLA Letter #2 To whom it may concern, I am writing to express my profound concerns with several changes in the new Model Licensure Act (MLA). I list these concerns below by section. I am a practicing school psychologist in NH and a member of my state association of school psychologists and the National Association of School Psychologists. Section J: Exemptions I strongly oppose the proposed change to section J of the MLA that removes the exemption for specialist level school psychologists to use their titles. I urge APA to strike this change from the proposed revisions and reinstate the long-held exemption for all school psychologists. Implementing this change would inevitably have a negative impact on children and their education. Specialist and doctoral level school psychologists are experts in psychology and education. These specialized professionals are highly valued in the schools because of the unique combination of rigorous graduate training (in psychology and education) that they work diligently to attain, and the subsequent invaluable services that they are able to provide. This proposed change in the MLA exemption would unjustly remove the rights of more than 75% of practicing school psychologists (20,000+) to use the title for which they are legitimately credentialed and qualified. This needless change in the MLA exemptions, especially at this time of great need in schools, and the untenable removal of a title most associated with school-based practice has a high risk of hurting children, families, and schools by creating barriers to receiving services. This is in direct violation of APA’s Ethical Principles of Psychologists and Code of Conduct, which under Principle A: Beneficence and Non-Malfeasance states that psychologists “take care to do no harm.” Section B: Definitions the Definitions Section (B) of the of the Model Act describes precisely the activities that school psychologists are trained and qualified to do in their daily work with children, educators, and families to enhance the school performance and mental health of children and youth and are practices for which school psychologists are credentialed by state boards of education. The definition of the “practice of psychology” seeks to clarify the breadth of specific services rendered by psychologists. Within this definition, all of the services provided by school psychologists are addressed in whole or in part. This portion of the Model Act defines psychological practice and essentially removes the right of non-doctoral school psychologists legitimately credentialed by State Education Agencies to engage in these practices. This removal constitutes a restraint of trade (or professional practice), which could put states in violation of interstate commerce law and place them at risk for civil litigation. Accordingly, these recommended revisions should be reversed. It is for the reasons stated above that I strongly advise the APA to reinstate the exemption for specialist level school psychologists in the Model Act. Section G. Limitations of Practice; Maintaining and Expanding Competence I strongly oppose the proposed revision to section G (Limitation of Practice; Maintaining and Expanding Competence) of the MLA that changes school psychology from an area of specialization to a foundation of psychology. I strongly urge the APA to reject this proposed change and maintain that school psychology is an area of specialization. By maintaining that school psychology is an area of specialization, the public is protected from being provided school psychological services by a professional that is not adequately trained in school psychology. Allowing professionals who lack proper specialization to work in schools with the vulnerable population of children is in direct violation of APA’s Ethical Principles of Psychologists and Code of Conduct, which under 2.01 Boundaries of Competence states that, “(a) Psychologists provide services, teach, and conduct research with populations and in areas only within the boundaries of their competence, based on their education, training, supervised experience, consultation, study, or professional experience.” Preamble I strongly oppose language in the APA MLA that would potentially limit and change the practice of school psychologists without empirical or evidentiary grounds, and I urge APA to revise the proposed changes in the MLA that may cause this problem, including the Preamble. Section A. Declaration of Policy I strongly oppose language in the APA MLA that would potentially limit and change the practice of school psychologists without empirical or evidentiary grounds, and I urge APA to revise the proposed changes in the MLA that may cause this problem, including Section A, Declaration of Policy. This section states that, “...the intent of legislation for state licensure of psychologists is to ensure the practice of psychology in the public interest. The consumer should be assured that psychological services will be provided by licensed and qualified professionals…” While many claim that the MLA is primarily an act that is focused on standards for professional titles (i.e., psychologist), the Preamble clearly states that, “This is the fifth set of guidelines for state legislation regulating the practice of psychology that has been developed by the American Psychological Association (APA).” In light of the potentially harmful impact on children and education resulting from proposed changes to the Model Act specific to school psychologists and the failure of APA to adequately document or support any benefits of their proposed change, I strongly suggest the APA strike these revisions, and specifically reinstate the exemption for all school psychologists. Furthermore, as many of these revisions would limit and change the practice of school psychologists without compelling justification, I strongly recommend that APA revise the MLA in a manner that conserves and respects highly qualified, skilled, and dedicated school psychologists and the psychological services that they provide in order to improve the outcomes of children and families. Sincerely, To download these letters in WORD format go to these links
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