What you should know
By a 1987 amendment to Mass. General Laws Chapter 112, sections 118-129A (the laws governing the licensure of psychologists), the requirement of "Health Service Provider certification" for independent clinical practice was added to the licensing laws. This statutory change inserted several important definitions to existing law, including "health service", "health service training program", and "supervised health service experience". Most importantly, M.G.L. c.112 s. 120 was amended to state:
Any licensed psychologist who independently provides or offers to provide to the public, health services, shall be certified as a health service provider by the board. The board shall certify as a health service provider applicants who shall demonstrate that they have at least two years full time of supervised health service experience, of which at least one year is post doctoral and at least one year of which is in a health service training program.
In the Board's promulgated regulations, health service provider qualifications and the certification process were further described (251 CMR 3.08).
Health service provider certification commenced, although the "HSP" designation may not have appeared on licenses until 1991, and wall certificates (due to processing delays) may show a date in 1993.
So what does it all mean? The HSP certification requirement means that a psychologist who is licensed, but does not have the additional designation of health service provider certification, cannot independently practice as a clinician and cannot bill third party insurers for payment. Independent practice without such certification is a statutory, regulatory, and ethical violation. Many people ask about why one would want licensure without HSP or what one can do with it. The answer is that one can use the title "psychologist", and there are individuals whose work is not clinical who may benefit from such a license. There are, however, very few individuals licensed in Massachusetts without Health Service Provider certification (less than 1%).
What must an applicant document in order to obtain Health Service Provider certification?
- Completion of a doctoral program in psychology and coursework which adequately prepares one to practice, e.g. clinical, counseling psychology. If one's doctoral program in psychology is not in an area of practice, the applicant must complete a re-specialization program.
- A 1600 hour internship (health service training program). Noteworthy are the following requirement for this health service training program:
- You must have at least one hour of supervision (individual or in groups no larger than three) for every sixteen hours of work.
- At least half of the supervision must be from a licensed psychologist.
- The program must provide training in a range of assessment and treatment interventions conducted directly with clients seeking health services.
- At least 25% of the trainee's time must be in direct contact with clients seeking assessment or treatment. This means face-to-face contact with clients/patients.
- The internship must be post-practicum.
- The program must have provided at least four hours in structured learning activities on issues related to racial/ethnic bases of behavior with a focus on people of color.
- The training agency must have a minimum of two psychology interns at the internship level of training during an applicant's training period.
- The internship must be the first of the two years of supervised health service experience (251 CMR 3.08(5)(b)8).
- The applicant must complete 1600 hours of supervised post-doctoral experience in a setting in which health services are normally provided, with which the applicant has a formal relationship, and where the applicant is supervised at least one hour for every 16 hours of training, at least half of which is provided by a psychologist licensed by the board. At least 25% of the applicant's time must be in direct client contact.
To highlight the issues in the post-doctoral year:
- Academic positions in which the responsibilities include teaching, research, and possibly supervision of students DO NOT meet this requirement, because they are not in a health service setting and they do not include at least 25% of the time in direct client contact.
- Working in a hospital may meet the "setting" requirement, but if the applicant is conducting research, he/she does not meet the requirement for health service experience, which is defined as "the delivery of direct, preventive, assessment and therapeutic intervention services to individuals whose growth, adjustment, or functioning is actually impaired or may be at risk of impairment". If the client is directly benefiting from the service the applicant is providing, that is health service. If the client is really the research program, and the face-to-face data collection serves the research but is not for the direct benefit of the client, this does not qualify.
- The applicant must be supervised at least half the time by a licensed psychologist.
- The applicant must work in the health service setting at least 16 hours a week, for a minimum of four months. The applicant can complete two part-time positions, but each one must meet these minimums.
- The requirements of 251 CMR 3.08 (5)(b) do not apply to the post-doctoral year.
- If the applicant is in a "fee-for-service" position, the applicant may count only up to one hour of indirect time for each hour of direct service provided (as per Board policy adopted 3/10/95). That means that your direct contact must be a minimum of 50% of your time.
- While completing the post-doctoral year of training, the applicant CANNOT use the title "psychologist". The title "psychologist" may only be used by currently licensed individuals. Board regulations (251 CMR 3.04 (10) state that the position must be designated as a "psychologist-in-training" (e.g. intern, resident, fellow, etc. positions).
- Answers to other frequently asked questions about the post-doctoral year:
- Board regulations (251 CMR 3.05) require that supervisors and collaborators be on the premises where the trainee renders service during the time such service is rendered. What this means is that no unlicensed individual may offer clinical services in a setting where they are essentially working independently, e.g. home-based services, satellite clinics, etc. However, the Board interprets this regulation to mean that a licensed person must be on site at all times that services are delivered, but the supervisor may designate another licensed person to function in this capacity if the supervisor is not present all the time. The "licensed" person can be a psychologist, LICSW, or psychiatrist. The supervisor is responsible for designating such a person, and insuring that their supervisee is never practicing independently (without a licensed person on site).
- Board regulations (251 CMR 3.04(10)) require that both the pre- and post-doctoral clinical experience be completed in positions designated as "psychologist-in-training". What this means is that all clients/patients must be aware that the individual is not licensed and is in training to become a psychologist. Some individuals inquire about whether they can accrue post-doctoral hours if they are billing under an LMHC license. Although Board regulations do not address billing issues, the individual's title and presentation to the public must be in conformance with Board regulations.