I appreciate the opportunity to provide public comment on the proposed APA Model Act for State Licensure of Psychology Professionals. I submit these comments as a Licensed Psychological Associate practicing in North Carolina within an independent private practice that provides psychological evaluations, consultation, and behavioral health services across multiple residential group home settings, including services for geriatric residents affected by traumatic and acquired brain injury.
My comments are grounded in clinical practice experience, workforce realities, and the scientific literature supporting competency-based models of professional practice. While the Model Act reflects important progress in recognizing master’s-level psychology professionals within health service psychology, several provisions raise concerns related to the use of categorical degree-based restrictions, prescriptive supervision requirements, and limitations on representation in regulatory governance.
These concerns are particularly relevant to community and residential care settings, where access to qualified psychological providers is already limited. Policies that are not clearly supported by empirical evidence may inadvertently reduce service availability, create regulatory ambiguity for competent practitioners, and affect continuity of care for medically and cognitively complex populations.
Consistent with the Model Act’s emphasis on competence, ethical practice, and public protection, I encourage consideration of competency-based approaches to scope, supervision, and governance that reflect contemporary training models, interdisciplinary practice realities, and access-to-care needs.
Key Citations Supporting Comments
Below are APA policy, peer-reviewed literature, and workforce reports that align with your arguments.
1. Competency-Based Practice vs Degree-Based Scope Restrictions
Kaslow et al. (2009)
Kaslow, N. J., et al. (2009). Competency assessment toolkit for professional psychology. Training and Education in Professional Psychology, 3(4), S27–S45.
Foundational work describing competency-based education and practice as central to professional psychology across degree levels.
Fouad et al. (2009)
Fouad, N. A., et al. (2009). Competency benchmarks: A model for understanding and measuring competence in professional psychology. Training and Education in Professional Psychology, 3(4), S5–S26.
Establishes competency benchmarks emphasizing training, supervision, and experience rather than degree category alone.
APA Board of Educational Affairs (2013)
APA. (2013). Guidelines for competency-based education and training in professional psychology.
Reinforces competency-based models as core to professional psychology training and practice.
2. Supervision Models and Workforce Development
Borders et al. (2014)
Borders, L. D., et al. (2014). Best practices in clinical supervision: Evolution of a counseling specialty. The Clinical Supervisor, 33(1), 26–44.
Highlights variability and effectiveness of supervision models; supports flexibility rather than rigid hour-based frameworks.
Watkins (2017)
Watkins, C. E. (2017). Clinical supervision in the 21st century: Revisiting pressing needs and impressive possibilities. American Journal of Psychotherapy, 71(1), 1–11.
Emphasizes competency development and supervision quality over quantitative supervision thresholds.
3. Access-to-Care and Workforce Considerations
Health Resources & Services Administration (HRSA, 2023)
HRSA. (2023). Behavioral Health Workforce Projections.
Identifies ongoing shortages in behavioral health providers, particularly in rural and community settings.
Thomas et al. (2009)
Thomas, K. C., Ellis, A. R., et al. (2009). County-level estimates of mental health professional shortage in the United States. Psychiatric Services, 60(10), 1323–1328.
Demonstrates workforce shortages and access disparities relevant to restrictive licensure policies.
4. Community / Interdisciplinary Practice and Neurocognitive Populations
APA Presidential Task Force on Care for Older Adults (2014)
APA. (2014). Guidelines for psychological practice with older adults.
Emphasizes interdisciplinary collaboration and broad psychological roles in geriatric and neurocognitive care.
Silverberg & Millis (2009)
Silverberg, N. D., & Millis, S. R. (2009). Implications of mild traumatic brain injury research for neuropsychological assessment. Journal of the International Neuropsychological Society, 15(1), 1–14.
Supports multidisciplinary assessment roles and functional evaluation approaches in TBI care.
Master’s-level psychologists play a critical role in expanding access to psychological services, particularly in underserved and rural communities. Several provisions within the proposed Model Act — including categorical assessment exclusions and highly prescriptive supervision thresholds — do not appear to be grounded in empirical evidence demonstrating improved competency, public protection, or outcomes.
Licensure frameworks are strongest when they reflect competency-based practice, training pathways, and real-world workforce needs rather than assumptions about degree level alone. Thoughtful public comment can help ensure that the Model Act remains evidence-informed, access-oriented, and representative of the full psychology workforce.