Important News for California Psychological Assistants and their Supervisors

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I and a number of other attorneys who work with psychologists in California have noticed a significant trend.  We have become aware of a significant number of Board of Psychology (BOP) denials of supervised professional experience (SPE).

These denials are significant enough in number and scope that it seemed appropriate to author this post to inform the training community of the issue. A large number of psychological assistants (and their supervisors) have been denied SPE hours. This post offers an explanation as to what has happened to many applicants in the hope that others who have yet to apply can avoid the problem that has befallen so many others.

First, an explanation:

Prior to the commencement of supervision a psych assistant and her/his supervisor must sign a supervision agreement detailing the clinical services to be offered and other important information.  The BOP offers a supervision agreement form on its website that captures this information.  Following the completion of supervised experience this form is turned in to the BOP, along with the other required documentation.

Here’s the problem that many are facing:

When applying for licensure some applicants and their supervisors have been unable to locate the form that was signed at the beginning of supervision.  In some cases the form was signed over a year ago and cannot be located.  To remedy this, many applicants have been re-downloading the supervision agreement form from the BOP’s website and filling it in with the same information that was previously filled in; they have tried to re-create the form.  The problem with doing this is that the BOP has made minor changes to the form and is aware that the forms that many applicants are turning in are backdated.  The BOP’s response in many cases has been to deny all hours from supervision agreement forms that are backdated.  In some cases this has meant that over a year’s worth of supervised experience is lost.

What to do:

Every case is different, but it seems clear that you should NOT be backdating  supervision agreement forms.  Those who have done this often have very good reasons for having done so, but the BOP appears to perceive this as an act of dishonesty on the part of both supervisor and psych assistant (i.e., not as an attempt to recreate a lost form that was previously properly signed and completed).  If you or your supervisor(s) have lost the supervision agreement forms, seek guidance from the BOP or from an attorney about what to do.

If you have been denied SPE hours by the BOP because of this issue you may have some options.  The BOP may re-evaluate these denials on a case-by-case basis, and depending on individual facts and circumstances may choose to grant hours that had previously been denied.

This is also a good time to become active in state and local professional associations.  CPA, for example, is aware of this issue and is doing its part to communicate with the BOP.  CPA frequently coordinates activities with local associations, so if you aren’t a member of CPA please contact your local organization to get involved.

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8 Responses to “Important News for California Psychological Assistants and their Supervisors”

  1. Elizabeth S., Ph.D says:

    I have a colleague who is in this situation and was denied her post doc hours because she backdated the form as this has been common practice in our field for quite some time now. Why the BOP chose this year to clamp down on this I am not sure, perhaps for political reasons? In any case, I think this is unconscionable what the BOP is doing to our interns, many who are unemployed and depending on getting licensed to survive. Rather than spending time trying to trap interns why not spend the time and energy informing post doc sites and psychology programs of the BOP’s new stance?

  2. Stuck in a hard place...... says:

    I am in this situation myself.

    The BOP already has possession of my agreement which my supervisor dated incorrectly–this was a predoctoral internship experience from 2 years ago.

    The error was brought to my attention by a fellow intern who applied for licensure–and the BOP TOLD HER TO CREATE A SUBMIT A NEW FORM! Can you believe that? And that was okay for her and she is on her way……!

    When I contacted the BOP to ask about the situation for myself, I was treated horribly and told all my hours would be disallowed for the year. Am I really to believe I will never be able to be licensed and all of this was for nothing? I can’t ever complete more pre-doc hours, I’ve graduated and am a post-doc now!

    My supervisor put the wrong date by her signature-10/30, when it should have been dated the beginning of that September. I understand disallowing the hours I accrued in September and October, but the whole year’s experience? How can they do that?

    It makes me sick that this is BOP I have to deal with. I have my weekly/monthly logs (signed off by both primary and secondary supervisors) for that entire training year documenting my experience, so it would be very easy to demonstrate what hours I accrued when, etc. for them to “disallow” the hours for September and October.

    I just wonder what’s going to happen when I apply for licensure officially. So far it looks like I’m up for a fight, just because my supervisor wrote the wrong date in one place on one form…….CRAZY!

  3. S.R. says:

    I’m glad to hear that the BOP is protecting the general public from these nefarious backdaters. As we all know, backdating is a gateway crime to having sex with clients or stealing from them.

    Has it occurred to anyone that in some cases supervisors are (unconsciously) financially motivated to sabotage their psych assistant’s hours? In many instances, supervisors are making a substantial amount of money from their psych assistants, and it is in their financial best interest to keep us beholden to them. So, the supervisors screw up the dates or lose the form, we psych assistants get punished, and the supervisors extend the amount of time we’re earning money for them. Often, there’s no punishment for the supervisors, only a reward!

    The BOP meets this weekend in San Diego — let your voice be heard on this ridiculous issue.

  4. I think it’s less likely that anyone has nefarious motives here, unconscious or otherwise. It is more likely the case that the BOP has adopted a very strict policy that emphasizes the BOP’s interpretation of the supervised professional experience rule. There are alternative interpretations of this rule, but in order to have them heard it is necessary to go through the administrative review process.

  5. San Francisco Psy.D. says:

    One note to people whose pre-doc hours were affected: the board’s requirement is 3000 supervised hours that must include at least 1500 post doc hours. I believe this means that in theory all of your hours could be post-doctoral. Look into this yourself if you are affected, but I don’t think any hours must be pre-doctoral. So while this new crackdown will painfully slow down people’s licensure processes, it shouldn’t directly stop anyone from eventually being licensed.

  6. W.D. says:

    I am wondering if a class action would be appropriate against the board. The reasoning would be that the moment the board accepts the $40.00 check it receives with the application for psych assistantship together with the psych assistantship application, it acknowledges there is implicit in the application the act of supervision.

  7. JL says:

    I agree with WD. If this documentation is so important, then why doesn’t the board have supervisors and supervisees submit the documentation along with all of the other forms that are required up front? What is the value in waiting until a supervisee has undergone, sometimes years of supervision, to determine whether that person was supervised in accordance with the law? In approving the initial paperwork, the board has greenlighted that person’s work without seeing whether they have agreed to the conditions.

  8. Elle PhD says:

    I am a psychologist and just received a notification that my supervisee and I both backdated a form. I do not recall backdating anything, as it was 2 years ago! However, in the past when the board claimed that they never received one of these forms, I was told (in a very indirect but CLEAR way) to backdate it and send it in anyway if it really only was a matter of a lost form (fortunately I located a copy of the original form). I’m not sure if I will get in trouble for this or not, as the board did request a “response” from me “regarding these allegations.”

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