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Comments about Statutory Language
The statutory requirement that professional board membership include no more than one-third Licensed Practitioners of Psychology does not appear to be supported by evidence demonstrating improved regulatory effectiveness or public protection. Board composition varies across jurisdictions, and fixed ratios may limit meaningful representation of master’s-level practitioners.
Given that master’s-level psychologists provide substantial direct services across healthcare and community settings, limiting representation may reduce perspective diversity in regulatory decision-making.
Comments about the Rationale
The rationale does not clearly explain why restricting representation of Licensed Practitioners of Psychology is necessary for public protection or board functioning. Without empirical or regulatory justification, this provision may reflect structural hierarchy rather than evidence-based governance principles.
General
Balanced representation that reflects workforce composition and service delivery realities may enhance regulatory decision-making and policy relevance. Limited representation of master’s-level practitioners may contribute to rules that do not fully consider community practice contexts, including residential and geriatric care settings.