Hello, Board of Psychology

Thank you for taking the time to read my post. I am writing you today to request that rules implemented during COVID-19 become permanent. As you know, the government’s role is to serve its people. The courts have ruled for years that licensure is only appropriate to the extent that it protects people from harm. 

Many states have a different paths to licensure. Some examples include the following:

• Direct Application - The typical application by which someone applies if they are new to the field. (See: https://www.lawinsider.com/dictionary/occupational-licensure)

• Reciprocity - Where two states recognize each other out of state licenses. (See: https://www.lawinsider.com/dictionary/reciprocal-license)

• Endorsement - Where a state recognizes any state’s license. (See: https://code.dccouncil.gov/us/dc/council/code/sections/3-1205.07)

• Universal - Where a state grants a license after someone has been licensed for a specific time in another state. (https://www.ncsl.org/research/labor-and-employment/universal-licensure-recognition.aspx)

• Temporary - Where a state issues a temporary license based on an out-of-state license holder. (See: https://licensing.csg.org/covid-policy-responses/temporary-licensure/)

• Telehealth - Where a state issues a license to practice telehealth based on an out-of-state license.

(See: South Carolina - https://llr.sc.gov/cou/behavioral_telehealth.aspx)

(See: Vermont - https://sos.vermont.gov/opr/about-opr/covid-19-response/telehealth-out-of-state-expired-license-registration/)

(See: Florida - https://flhealthsource.gov/telehealth/)

(See: Indiana - https://www.in.gov/pla/telehealth-home/)

(See: Delaware - https://dprfiles.delaware.gov/documents/Medical%20Personnel%20Request%20Form%20post%20HB%20348.pdf)

(See: New Jersey - https://dohlicensing.nj.gov/telehealthtelemedicine/)

(See: Alaska - https://www.commerce.alaska.gov/web/cbpl/ProfessionalLicensing/TelemedicineBusinessRegistry.aspx)

(See Arizona - https://psychboard.az.gov/psychologist-behavior-analyst-telehealth-registry)

The Virginia General Assembly has already signaled that they are going this route. See: HB 537. According to § 54.1-3605. Powers and duties of the Board has to “Promulgate regulations establishing the requirements for licensure of clinical psychologists that shall include appropriate emphasis in the diagnosis and treatment of persons with moderate and severe mental disorders.”

While a license is required by statute, there are exemptions to licensure that apply under § 54.1-3601. Exemption from requirements of licensure. However, some individuals are licensed in other states that would rather be under the jurisdiction of the board rather than practice under a qualified exemption. If the board denies the request, it creates multiple issues:

First, psychologists may practice under an exemption outside the board’s jurisdiction. Second, the need for mental health treatment in Virginia goes critical. Finally, Virginia signals to the other states that it believes their requirements are not good enough.

It is time for Virginia to get on the same page as the many other states and allow its mental health crisis to be addressed by qualified practitioners.