Policy No. 10-001

The Board is issuing this statement of policy to clarify some of the principles that have guided a number of its recent decisions.

Licensure and Health service Provider Certification. Licensure and Health Service Provider (HSP) certification are two different credentials. A license in Psychology in Massachusetts does not, in itself, permit a Psychologist to provide health services independently. According to the Massachusetts General Laws (M.G.L.), Chapter 112, Section 118, "Health services" involve "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."This includes psychotherapy, psychological testing, and the supervision of these services. A licensed Psychologist without HSP certification may only perform health services under the supervision (collaboration) of an HSP certified licensed Psychologist while accruing hours toward HSP certification. The supervisor is legally responsible for the services provided.

"Unlicensed Psychologist." In Massachusetts , it is not permissible for an individual without a license in Psychology to use the term "Psychologist" to describe his/her professional status, no matter what educational credentials that individual possesses. M.G.L. c. 112, §122. Thus, the term "unlicensed psychologist" is a contradiction and may not be used. For example, a person who has a doctorate in Psychology from a Designated Doctoral Program,* but is not yet licensed in Massachusetts as a Psychologist, may NOT call him/herself an "unlicensed psychologist." To do so is a violation of state law, subject to discipline.

"License Eligible Psychologist". This term has a restricted meaning in Massachusetts. It may only be used to describe a person who has applied to the Board of Registration of Psychologists, met all requirements for licensure as determined by the Board (including passing both exams), but has not yet paid the licensure fee or received a license number. The Board (not the individual) must determine that all requirements for licensure have been met in order for the individual to use the term "license eligible" to describe his/her status.

Persons with a Doctorate in Psychology Practicing Independently as Psychotherapists. Unlicensed individuals who have a doctoral degree in Psychology from a Designated Doctoral Program*, who practice independently under the title of "psychotherapist," are considered by the Board of Registration to be practicing Psychology without a license. The Board regards such action as an attempt to circumvent the Psychology licensing law and subject to discipline.

Use of the Term "Psychologist" in Higher Education Settings and by State Government Employees. Individuals who work in colleges and universities, as well as state employees, are not exempt from the Psychology licensing law. Regardless of their training or job position, no person may use the title "Psychologist" in Massachusetts without being licensed by the Board of Registration of Psychologists. To do so is to hold oneself out as a Psychologist without a license, which is a violation of state law and subject to discipline.

*Designated Doctoral Program in Psychology. The Association of State and Provincial Psychology Boards (ASPPB) in collaboration with the National Register in Psychology, designates doctoral programs in Psychology that meet specified criteria as providing adequate preparation for licensure. Most states will issue a license only to those individuals who have doctoral degrees from a designated doctoral program. In Massachusetts, the Board has required since September 2000 that the doctoral degree must be granted by a program that has been designated at the time the degree is granted or within two years thereafter (215 CMR 3.03(1)(b)).

Unlicensed Persons Accumulating Supervised Clinical Hours Toward Licensure. Supervisees are responsible for verifying that their direct supervisors are, in fact, licensed Psychologists (with HSP certification if in Massachusetts). This information is available on the Board's website: www.mass.gov/dpl. Persons who supervise trainees without these credentials will be disciplined by the Board. Individuals accruing hours towards licensure at the post-doctoral level may use such titles as "post-doctoral trainee", "post-doctoral fellow", "trainee", "fellow" or other such title that clearly designates their training status.

Unlicensed Persons who Supervise Trainees under the Oversight of a Licensed HSP Psychologist. The Board will not accept clinical hours toward licensure or HSP certification if those hours have been supervised by an unlicensed person whose supervision has been supervised by a licensed HSP Psychologist. Supervisees accruing hours towards licensure are responsible for verifying that their direct supervisors are licensed Psychologists (with HSP status if in Massachusetts). Persons who supervise trainees without these credentials, as well as the licensed supervisor of such supervision, may be subject to discipline by the Board. Please note, however, that the Board does not regulate supervision that occurs in practicum settings, as these hours are not used for licensure.