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Comments about Statutory Language
The statutory language requires 3,000 hours of post-degree supervised experience with highly prescriptive supervision ratios. While supervision is essential for competency development, the fixed thresholds and supervision frequency requirements appear rigid and may not reflect the diversity of training environments or competency-based supervision models.
In practice settings such as private psychological evaluation and consultation services, these requirements may create logistical and financial barriers for both supervisees and supervisors. Such barriers may discourage hiring, delay independent practice readiness, and limit workforce growth.
This impact may be particularly pronounced in residential and geriatric care settings, where timely access to psychological consultation and evaluation is essential for individuals with neurocognitive disorders, TBI, and ABI.
Comments about the Rationale
The rationale does not appear to cite empirical evidence demonstrating that these supervision ratios produce improved competency outcomes relative to flexible or competency-based models. Without such evidence, the requirements may represent structural workforce barriers rather than science-based competency safeguards.
General
A competency-based supervision framework with flexible implementation parameters may better support workforce development while maintaining public protection. Excessively prescriptive supervision thresholds may inadvertently reduce service availability in underserved settings without demonstrable benefit.