The National Association of School Psychologists (NASP) strongly opposes the proposed revisions to the American Psychological Association's (APA) Model Act for State Licensure of Psychologists. Specifically, the proposed model act calls for limiting the provision of psychological services and use of the title "psychologist" to only those individuals with a doctoral degree in psychology or licensed by a state psychology licensure board. This would seriously curtail the practice of the majority of school psychologists and the provision of necessary services to children, families, and schools.
The current 30-year old model act includes an appropriate and necessary exemption for school psychology. Currently, the exemption from licensure restrictions extends to school psychologists who have completed training at the specialist (typically 60 hours or more of an integrated program of graduate studies in school psychology) and doctoral levels and are credentialed by the state board of education. The exemption acknowledges that the training and qualifications of school psychologists in these categories are appropriate for psychological services provided with the purpose of improving students' academic and mental health outcomes.
APA has removed this exemption in the proposed model act for nondoctoral school psychologists and for doctoral school psychologists working outside of public schools, universities, and research facilities. This removal is without cause or evidence of public benefit. A primary purpose of a professional model licensure act should be to ensure access to effective services provided by qualified professionals in order to protect and promote the public welfare. Far from accomplishing this goal, APA's proposed removal of the 30-year-old exemption for nondoctoral school psychologists credentialed by their state board of education has no basis in evidence that the current practice of school psychology causes public harm, nor that removing the exemption will promote the public welfare.
The practice of school psychology is well established in law and regulation. Federal and state statutes and regulations refer to the practice of school psychology and the title of "school psychologist" for important services for children in general and special education. More than 90% of state boards of education use the title "school psychologists" for credentialing of professionals in public schools. Further, a number of cases have affirmed the right and benefit to the public of school psychologists credentialed by their state board of education to practice in schools.
The proposed model act, if enacted as written, could cause unnecessary, disruptive conflict at the state level. Adoption of the proposed APA model act would put state statute in conflict with state boards of education credentialing laws and regulations regarding certification or similar credentialing processes for positions providing psychological services (as described in the model act) and/or that include the words "school psychologist," "psychological," or "psychology" This could distract public officials and educators from more important issues and jeopardize schools' ability to provide needed school psychological services.
The proposed model act may cause public harm by disrupting and limiting access to services. Most school psychologists serve in public schools and are credentialed by their state boards of education, not the state psychology licensure board. Adoption of the proposed model act as written could eliminate the ability of the majority of school psychologists to continue providing services and/or use the title "school psychologist." There is already a shortage of school psychologists, and it would take states and the profession years to overcome the disruption in service.
The proposed model act creates public confusion because it permits licensed psychologists working in any setting, including schools, to refer to themselves as "school psychologists" without having met state or national credentialing requirements for school psychologists. …