[AVAPL Members] Re: licensure question as it related to supervision
- From: "Goldberg, Robert W. (VHACLE)" <Robert.Goldberg2@xxxxxx>
- To: "Rookey, Craig P" <CRAIG.ROOKEY@xxxxxx>, "Hsu, Jeanette" <Jeanette.Hsu@xxxxxx>, "McCutcheon, Stephen R." <Stephen.McCutcheon@xxxxxx>, "Putnam, Katherine M." <Katherine.Putnam@xxxxxx>, "Shaw, Keith" <Keith.Shaw@xxxxxx>, "Siegel, Wayne" <Wayne.Siegel@xxxxxx>, "Zeiss, Robert A." <Robert.Zeiss@xxxxxx>, "Crema, Kathryn C." <Kathryn.Crema2@xxxxxx>, "VHA Psychology Internship Directors" <VHAPID@xxxxxxxxxxx>, "members1@xxxxxxxxx" <'members1@xxxxxxxxx'>
- Date: Wed, 29 Dec 2010 08:42:16 -0500
I'd start off by consulting with the Wisconsin licensing board, if that
has not already been done.
From: Rookey, Craig P
Sent: Tuesday, December 28, 2010 3:56 PM
To: Hsu, Jeanette; McCutcheon, Stephen R.; Putnam, Katherine M.; Shaw,
Keith; Siegel, Wayne; Zeiss, Robert A.; Crema, Kathryn C.; VHA
Psychology Internship Directors; 'members1@xxxxxxxxx'
Subject: RE: licensure question as it related to supervision
The question may come down to where is the responsibility being placed
by the licensing board. If the three year requirement is on the
supervisor, not on the intern, the supervisor must conform in order to
be a primary supervisor. If the responsibility is being placed on the
intern, the State of WI would not accept supervised hours for any intern
who was not supervised in WI, or at least would be checking to see if an
intern supervised in another place was only supervised by psychologists
who meet WI's supervisor requirements. It would seem that checking with
the state licensing board would be appropriate to see if they are making
those types of inquiries of applicants.
Craig P. Rookey, Ph.D.
Director of Training
Chief, Vocational Rehabilitation
Central Arkansas Veterans Healthcare System
(501) 257-1672
From: Hsu, Jeanette
Sent: Tuesday, December 28, 2010 2:46 PM
To: Rookey, Craig P; McCutcheon, Stephen R.; Putnam, Katherine M.; Shaw,
Keith; Siegel, Wayne; Zeiss, Robert A.; Crema, Kathryn C.; VHA
Psychology Internship Directors; 'members1@xxxxxxxxx'
Subject: RE: licensure question as it related to supervision
Just to clarify my understanding a bit - there are two different issues
here. The first is the ability of a psychologist to practice, including
providing supervision. VA psychologists licensed in any state can
legally practice and supervise within the VA system since VA is federal.
The second issue is the ability of pre-licensed trainees (e.g., interns)
to obtain supervised hours that meet requirements for obtaining a
license in a given state. Each state has the right to determine those
requirements; federal law does not determine state licensure. Licensure
applicants receiving supervision that does not meet that state's
requirements may not be able to obtain that state's license. There is
the possibility of appealing a state board's decision, or seeking an
exception to these regulations. As Steve indicated, it's best to be
familiar with your own state board's regulations and fully inform
interns if the supervision your program provides does not meet the
requirements of that state. And it's always a good idea to contact your
state licensure board if you have questions they can clarify for you.
Jeanette
Jeanette Hsu, Ph.D.
Training Director, Psychology Service
VA Palo Alto Health Care System
From: Rookey, Craig P
Sent: Tuesday, December 28, 2010 12:08 PM
To: McCutcheon, Stephen R.; Hsu, Jeanette; Putnam, Katherine M.; Shaw,
Keith; Siegel, Wayne; Zeiss, Robert A.; Crema, Kathryn C.; VHA
Psychology Internship Directors; 'members1@xxxxxxxxx'
Subject: RE: licensure question as it related to supervision
I see it a bit differently. We are each expected to practice by the laws
governing our licenses from where they are issued. We actually practice
in Federal lands, not in really in a state at all. To that effect - each
licensed individual may supervise as is regulated by their license as
regulated by the state the license was issued in. For example, a person
licensed in Illinois can practice and supervise here at our VA in
Arkansas as it is federal ground. Further, they can supervise even
though the State of Arkansas has an add on to licenses that someone can
supervise. The person with the Illinois license cannot get the Arkansas
add on as they do not have an Arkansas license. They supervise legally
as regulated by their license as issued. As for the interns - yes they
were supervised by legal supervisors and can claim it just as if they
were supervised in Illinois by that same supervisor.
Craig P. Rookey, Ph.D.
Director of Training
Chief, Vocational Rehabilitation
Central Arkansas Veterans Healthcare System
(501) 257-1672
From: McCutcheon, Stephen R.
Sent: Tuesday, December 28, 2010 12:53 PM
To: Hsu, Jeanette; Putnam, Katherine M.; Shaw, Keith; Siegel, Wayne;
Zeiss, Robert A.; Crema, Kathryn C.; VHA Psychology Internship
Directors; 'members1@xxxxxxxxx'
Subject: RE: licensure question as it related to supervision
My understanding of this requirement is similar to Jeanette's. I'd only
add that this is one of those questions which it's important to directly
ask your state licensing board, since there's so much variability in
state laws and regulations. For example, in Washington, there's no
provision to allow 'primary' vs. 'secondary' supervision - a supervisor
is either qualified or is not. Such hours presumably wouldn't count
toward licensure here. Because of such variability across jurisdictions,
I make it a point at the beginning of the training year that interns and
fellows should familiarize themselves with the licensure requirements of
those states in which they might seek licensure (by reviewing the
regulations on the ASPPB website), and to collaborate with me to ensure
that their training year fulfills these requirements. I make it my
responsibility to be on top of WA state law, but have to rely on them to
keep informed about requirements in other states. It's been an easy
thing to do and has given trainees peace of mind.
Steve
Steve McCutcheon, PhD
Director, Psychology Training
VA Puget Sound, Seattle
From: Hsu, Jeanette
Sent: Tuesday, December 28, 2010 10:34 AM
To: Putnam, Katherine M.; Shaw, Keith; Siegel, Wayne; Zeiss, Robert A.;
Crema, Kathryn C.; VHA Psychology Internship Directors;
'members1@xxxxxxxxx'
Subject: RE: licensure question as it related to supervision
Hello Kathy,
You are right that psychologists working within VA who are currently
licensed in any state are qualified and can be credentialed to practice
within VA. Such appropriately credentialed psychologists can also
supervise interns (e.g., be the designated provider for encounters and
co-signer of notes). APA Guidelines and Principles for accreditation
also allow supervisors within VA to be licensed in another state.
But when you state that WI law requires that primary supervisors have 3
years post-licensure experience, I assume that you mean that interns
need to be supervised by WI's definition of supervision by an
appropriately qualified supervisor in order to receive their hours for
licensure in WI. Since each state has the right to regulate their state
licensure laws, this situation could pose problems for your interns
seeking future licensure within WI as the interns' supervised experience
may not meet WI's requirements. Similarly, states like FL and CA also
require that pre-licensure hours be supervised by psychologists licensed
within the state the internship is located, no matter that such
psychologists are appropriately credentialed by VA to practice within a
federal system.
I hope this answers your question and helps you in considering the
hiring of your new psychologist. Others may have something else to add
to this discussion.
Jeanette
Jeanette Hsu, Ph.D.
Training Director, Psychology Service
VA Palo Alto Health Care System
From: Putnam, Katherine M.
Sent: Tuesday, December 28, 2010 10:00 AM
To: Shaw, Keith; Siegel, Wayne; Zeiss, Robert A.; Crema, Kathryn C.; VHA
Psychology Internship Directors; members1@xxxxxxxxx
Subject: licensure question as it related to supervision
Hello Internship Training Directors et al. ,
Please pardon me for this long-winded question. We are on a fast
time-line as we need to hire a new psychologist. We found someone who is
excellent, however, there may be a licensing/supervision glitch which I
will try to explain succinctly below.
I am aware that VA Psychologists can practice in any VA with any current
state license. I am also aware that we have to adhere to the regulations
of our own licensing boards per our state license. However, I have a
question concerning the state in which one practices in the VA.
WI (where our VA is located) requires that a primary psychology
supervisor must have 3 years post-licensure experience. A "secondary"
supervisor only needs to be licensed. However, the "secondary"
supervisor must be supervised by a primary. This means that the primary
supervisor must meet with the "secondary" supervisor weekly -it also
means that the interns and Veterans under the "secondary" supervisors
are the responsibility (legally and training-wise) of the primary. This
is a lot of responsibility, and our program is new and it is small.
My hope is that since this gentleman is licensed in MD -the WI statute
would not apply -that the federal and MD law would override the WI
3-year requirement and that he could then be a primary supervisor.
Can anyone help with this issue? Thank you very much.
Kathy
Katherine M. Putnam, Ph. D.
PTSD / SUD Specialist
Director of Psychology Training
Wm. S. Middleton Memorial Veterans Hospital
2500 Overlook Terrace
Madison, WI 53705-2286
Messages: (608) 280-7073
Fax: (608) 280-7296
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