How MFTs Stack Up

II. Supervised Experience

A. Marriage and Family Therapists

The MFT Licensing Law, in Section 4980.40, requires at least two years' experience in interpersonal relationships, marriage and family therapist and psychotherapy. Section 4980.43 further defines this requirement by specifying that two calendar years of supervised experience is required, consisting of at least 3,000 hours obtained over a period of not less than 104 weeks. It also provides that not less than 1,500 hours of experience must be gained subsequent to the granting of the qualifying master's degree (usually as a registered intern). Experience must be gained within the six years immediately preceding the date the application for licensure is filed, except that up to 500 hours of clinical experience gained in the required practicum is exempt from this "six-year rule."

Experience may be gained only when the applicant is employed or volunteering in one of the following five work settings: a governmental entity; a school, college or university; a licensed health facility (licensed pursuant to Sections 1250, 1250.2 or 1250.3 of the Health and Safety Code - a variety of hospitals/facilities licensed by the Department of Health Services and/or the Department of Mental Health); a nonprofit and charitable corporation or a private practice. A private practice setting is defined as employment by a licensed MFT, LCSW, psychologist, physician and surgeon or a professional corporation of any of the licensed professions. Only persons who have received their qualifying master's degree and are registered as interns may work in a private practice setting. Regulations promulgated by the BBS specify the kinds of hours that are permissible, mandated or limited.

For instance, an applicant must have a minimum of 104 hours of supervision (one hour per week for 104 weeks), but may gain many more (an applicant may claim up to three hours of supervision in any week). For those entering degree programs after January 1, 1990, at least 500 hours of experience must be gained in diagnosing and treating couples, families and/or children. The remainder of the counseling/psychotherapy hours may be with individuals. The licensing law and regulations recognize the value of other hours, and thus permits hours to be gained in attending workshops, seminars, training sessions and conferences (no more than 250 hours), counseling or crisis counseling on the telephone (no more that 250 hours), and doing group therapy or counseling (no more than 500 hours) or receiving psychotherapy.

The licensing law permits no more than 100 actual hours of psychotherapy received to be gained by the applicant, and as an inducement to obtain such hours, allows applicants to triple-count each hour of psychotherapy received from a licensed therapist (maximum of 100 hours X 3 = 300 hours). One other form of optional experience one may gain are hours for administering and evaluating psychological tests (up to 250 hours). These optional 250 hours also may include time spent in writing clinical reports and progress/process notes. Applicants for the license must keep weekly logs of all hours of experience gained, and may claim no more than a total of 40 hours of experience in any one week.

With respect to supervision, Section 4980.40 specifies that applicants for the MFT license must be supervised by a licensed MFT, an LCSW, a licensed psychologist, or a physician certified in psychiatry by the American Board of Psychiatry and Neurology. Each of these supervisors must meet additional criteria. The regulations provide that the supervisor must be licensed in California for at least two years prior to commencing any supervision, that his/her license must be in good standing (i.e., his/her license is not on probation or suspension), and that he/she must have practiced psychotherapy for at least two years within the five year period immediately preceding any supervision and averaged at least five patient contact hours per week.

The supervisor is required to provide at least one hour of individual or two hours of group supervision in each week where any qualifying experience is gained. Applicants for the license must have at least 52 hours of individual supervision (gained in at least 52 separate weeks). The remainder of supervision may be either individual or group. Supervision may not be obtained from one's spouse or relative, nor may it be obtained from a former therapist or from someone with whom the applicant has a personal relationship which undermines the authority or effectiveness of the supervisor. Applicants are required to file with the Board a supervisor's responsibility statement within 30 days after commencing employment or supervision (Section 1833.1 of the Regulations).

The supervisor responsibility statement is intended to make supervisors and supervisees aware of the responsibilities the supervisor has to the supervisees. Additionally, the regulation requires supervisors to take reasonable steps to ensure that a supervisee properly assesses and examines the patient, implements an appropriate treatment plan and is acting both within the scope of his/her license and competence. The supervisor is required to monitor the quality of counseling/psychotherapy performed by direct observation, audio or video recording, review of progress and process notes or records, or by any other means deemed appropriate by the supervisor. The supervisor must inform the supervisee of the methods by which the supervisor will monitor the quality of counseling or psychotherapy being performed.

B. Clinical Social Workers

The clinical social worker licensing law, in Section 4996.2, requires two years of supervised post-masters' experience. Section 4996.20 further defines this requirement by specifying that the applicant shall have at least 3,200 hours of experience in providing clinical social work services consisting of psychosocial diagnosis, assessment, treatment (including psychotherapy and counseling), client-centered advocacy, consultation and evaluation. The experience specified must be gained in not less than two nor more than six years and shall have been gained within the six years immediately preceding the date on which the application for licensure is filed. The licensing board is permitted to accept experience older than six years "upon a showing of good cause" or where the applicant is licensed and currently practicing in another state.

With respect to allowable work settings, the clinical social worker licensing law does not specify which settings are permissible (other than private practice settings for registered associate clinical social workers), but it does suggest that governmental entities, schools, colleges or universities, nonprofit and charitable corporations and licensed health facilities are acceptable settings. (The term "private practice setting" is curiously defined as "any setting other than a governmental entity, a school, college or university, a nonprofit and charitable corporation or a licensed health facility.") Unlike the MFT licensing law, the term "licensed health facility" is not defined by reference to any sections of law, and thus it could include licensed facilities that would not qualify for MFT licensure (i.e., community care facilities licensed by the Department of Social Services).

With respect to the kinds of hours permitted and the mandated minimums or maximums of particular kinds of hours (other than supervision hours), there are none. For example, there is no requirement for a particular number of hours in experience doing diagnosis, assessment and treatment. Additionally, the law and regulations applicable to clinical social worker licensing do not require applicants to keep weekly logs of their hours, nor is there a limitation on the number of hours which may be gained in any one week, nor are supervisor responsibility statements required to be filed. "Supervision" is simply defined in Section 4996.20 as "responsibility for and control of the quality of social work services provided."

The law requires at least one hour of supervision for each week of experience claimed. At least one-half of the supervision hours must be individual supervision, the remainder may be individual or group supervision. Insofar as eligible supervisors are concerned, Section 4996.20 specifies that up to 1,000 hours of the required experience may be gained under the supervision of a licensed mental health professional acceptable to the BBS. Such professionals are specified in Section 1874 of the regulations as licensed psychologists, licensed marriage and family therapists, or physicians certified in psychiatry by the American Board of Psychiatry and Neurology. These "other licensed mental health professionals" must be licensed for two years, but LCSW supervisors are not subject to that requirement. Thus, an LCSW may act as a supervisor the day he/she is licensed.

Like the MFT licensing law, supervision may not be obtained from a spouse or relative, nor may it be obtained from someone with whom the applicant has a personal relationship which undermines the authority or effectiveness of the supervision. Unlike the MFT licensing law, however, there is no express prohibition against receiving supervision from one's former therapist.

C. Psychologists

The psychology licensing law, in Section 2914, specifies that applicants for the license must have engaged for at least two years in supervised professional experience under the direction of a licensed psychologist, or such suitable alternative supervision as determined by the Board in regulation. At least one year of this experience must be gained after being awarded the doctorate in psychology. Regulations promulgated by the Board of Psychology specify that a year of supervised professional experience shall consist of not less than 1,500 hours (thus, applicants for the license are required to obtain at least 3,000 hours of experience).

The year of supervised experience (1,500 hours) must be completed within thirty consecutive months. When an applicant accumulates all the required experience post- doctorally, it must be completed within a period of sixty consecutive months. Applicants may not receive credit for more than 176 hours of supervised professional experience in any one month. With respect to pre-doctoral hours, supervised professional experience may not be accumulated until the applicant has completed 48 semester/trimester or 72 quarter units of graduate level coursework in psychology, educational psychology or the equivalent.

The 1,500 hours of supervised experience which may be obtained prior to the awarding of the doctorate degree may be obtained in a training program approved by a university, college or school that has a training agreement with the educational institution to provide such supervised experience. Additionally, the pre-doctoral hours and the post- doctoral hours may be gained as a psychological assistant when employed by a licensed psychologist or psychological corporation, a licensed physician and surgeon who is board certified in psychiatry by the American Board of Psychiatry and Neurology, or a medical corporation, or by specified clinics which provide mental health services. Additionally, these hours may be gained as employees of accredited or approved academic institutions, public schools, governmental agencies, and nonprofit community agencies under specified conditions.

With respect to the specific kinds of hours which may be obtained, (i.e., psychotherapy, diagnosis and treatment) the law and regulations do not delineate the required 3,000 hours in much detail. The experience gained must, of course, be within the scope of practice of a licensed psychologist, which is rather broad. For instance, the practice of psychology includes psychological testing and psychological services rendered to organizations (i.e., organizational psychology), and the licensing law specifies that the application of psychological principles and methods is not necessarily restricted to the diagnosis, prevention, and treatment of psychological problems and emotional and mental disorders of individuals and groups.

Additionally, regulations require that the applicant's supervised professional experience shall be in the same or similar "field of psychology" as is the applicant's education and training, and also require that the supervision provided is in the same or similar "field of psychology" as the education and training of the "qualified primary supervisor." The regulations also specify that supervised professional experience may consist of work in psychological research for specified educational institutions and research organizations. Thus, the lack of specificity as to required kinds of hours permits licensure as a psychologist without demonstrated experience in the diagnosis and treatment of mental and emotional conditions/disorders.

With respect to qualified supervisors, the psychology regulations define a "qualified supervisor" as a licensed psychologist or a board-certified psychiatrist who has no Accusation pending against his/her license, is not on probation, has no familial or interpersonal relationship with the supervisee and is otherwise in compliance with the Psychology Licensing Law or the Medical Practice Act and their respective regulations. Like the MFT Licensing Law and regulations, a qualified supervisor may not supervise a supervisee who has been a psychotherapy client of the supervisor, and the supervisee must maintain a weekly log of all hours of experience gained toward licensure.

The regulations also define a "qualified primary supervisor" as a psychologist who is rendering professional services a minimum of one-half time in the same work setting at the same time as the person supervised is obtaining supervised professional experience. The "qualified primary supervisor" is allowed to delegate a portion of the required supervision to another licensed psychologist or to suitable alternative supervisors.