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Comments about Statutory Language
The statutory language in Section B.9.b.(8) creates categorical exclusions for Licensed Practitioners of Psychology in multiple assessment and consultation domains (e.g., neuropsychology, forensic assessment, capacity evaluations). This exclusion framework appears inconsistent with the Act’s broader definition of psychological evaluation and with competency-based practice expectations described elsewhere in the Model Act.
The language does not identify a scientific or competency-based rationale for distinguishing these services solely by degree level rather than demonstrated education, training, supervision, and experience. Such categorical scope restrictions may introduce ambiguity for practitioners functioning within documented competence and may create regulatory risk despite adherence to ethical and competency standards.
From a practice perspective, these exclusions could adversely impact service delivery in community and residential settings. In my work as a Licensed Psychological Associate in North Carolina providing evaluations and consultation across multiple group homes, psychological consultation frequently intersects with neurocognitive, behavioral, and functional capacity domains, particularly for geriatric residents with traumatic and acquired brain injury. Rigid exclusions may limit access to qualified providers and disrupt continuity of care without clear public protection benefit.
Comments about the Rationale
The rationale for these exclusions does not appear to reference empirical evidence demonstrating differences in competency outcomes based on degree level alone. The Act otherwise emphasizes competency-based practice and ongoing competence development, suggesting that scope decisions should be guided by training and experience rather than categorical prohibitions.
The absence of a clearly articulated scientific justification raises concern that the exclusions may reflect historical structural distinctions rather than contemporary evidence regarding competency, workforce needs, or access to care.
General
Overall, the exclusion framework may inadvertently restrict access to psychological services, particularly in underserved and residential care settings, while creating uncertainty for master’s-level practitioners practicing within established competency parameters. A competency-based approach would better align with the Act’s stated principles and current professional standards.