AMENDMENT TO THE REGULATIONS OF THE
COMMISSIONER OF EDUCATION
Pursuant to sections 207, 210, 6501, 6504,
6507, 6508, 8403, 8409, and 8411 of the Education Law.
1.
Section 52.33 of the Regulations of the Commissioner of Education is
added, effective February 3, 2005, as follows:
52.33 Marriage and family therapy.
In addition to meeting all applicable
provisions of this Part, to be registered as a program recognized as leading to
licensure in marriage and family therapy, which meets the requirements of
section 79-10.1 of this Title, the program shall:
(a) be a program in marriage and family
therapy leading to a master's or doctoral degree, which includes at least 45
semester hours, or the equivalent, of study;
(b) contain curricular content that includes
but is not limited to each of the following content areas:
(1) the study of human development,
including individual, child and family development, at least three semester
hours;
(2) marriage and family therapy clinical
knowledge, including but not limited to psychopathology, at least twelve
semester hours;
(3) marriage and family therapy theoretical
knowledge, at least six semester hours;
(4) family law;
(5) research, at least three semester hours;
and
(6) professional ethics, at least three
semester hours; and
(c) include a supervised practicum in
marriage and family therapy of at least 300 client contact hours.
2.
Subpart 79-10
of the Regulations of the Commissioner of Education is added, effective February
3, 2005, to read as follows:
Subpart
79-10
Marriage and Family
Therapy
79-10.1 Professional study of marriage and
family therapy.
(a) As used in this section, acceptable
accrediting agency shall mean an organization accepted by the department as a
reliable authority for the purpose of accrediting marriage and family therapy
programs, having accreditation standards that are substantially equivalent to
the requirements for programs registered as leading to licensure in this field
pursuant to section 52.33 of this Title, and applying its criteria for granting
accreditation of programs in a fair, consistent, and nondiscriminatory manner.
(b) To meet the professional education
requirement for licensure as a marriage and family therapist, the applicant
shall present satisfactory evidence of completing:
(1) a master's or doctoral program in
marriage and family therapy registered as leading to licensure in this field,
pursuant to section 52.33 of this Title, or a master's or doctoral program in
marriage and family therapy that is accredited by an acceptable accrediting
agency, or a master's or doctoral program in marriage and family therapy that is
substantially equivalent to such a registered or accredited program, as
determined by the department; or
(2) a graduate degree program in an allied
mental health field acceptable to the department, including but not limited to a
graduate degree program in social work, psychology, and mental health
counseling, and additional graduate level coursework, if needed, which together
are determined by the department to provide the substantial equivalent
professional educational preparation as that obtained from a master's or
doctoral program in marriage and family therapy registered as leading to
licensure in this field, pursuant to section 52.33 of this Title; or
(3) a program located outside the United
States and its territories that is recognized by the appropriate civil
authorities of the jurisdiction in which the program is located as a program
that prepares an applicant for the professional practice of marriage and family
therapy, has been verified in accordance with subdivision (c) of section 59.2 of
this Title, and which is determined by the department to be substantially
equivalent to a master's or doctoral program in marriage and family therapy
registered by the department as leading to licensure in this field, pursuant to
section 52.33 of this Title, or to a master's or doctoral program in marriage
and family therapy accredited by an acceptable accrediting agency.
79-10.2 Professional licensing
examinations.
(a) Each candidate for licensure as a
licensed marriage and family therapist shall pass an examination:
(1) that is offered by an organization
determined by the department to have satisfactory administrative and
psychometric procedures in place to offer the licensing examination; and
(2) that the department determines
adequately tests marriage and family therapy proficiency at the master's degree
level and adequately measures the candidate's knowledge concerning practice as a
licensed marriage and family therapist as defined in subdivision (1) of section
8403 of the Education Law.
(b) Requirements for admission to
examination for licensure as a licensed marriage and family therapist. To be
admitted to the licensing examination, the candidate shall be required to:
(1) file an application for licensure with
the department;
(2) pay the fee for the initial license and
the fee for the first registration period, as prescribed in section 8403(3)(g)
of the Education Law;
(3) present satisfactory evidence of having
met the education requirement for licensure as a licensed marriage and family
therapist, as prescribed in section 79-10.1 of this Subpart, including receipt
of the degree.
(c) Passing score. The passing score for the
examination for licensure as a licensed marriage and family therapist shall be
determined by the State Board for Mental Health
Practitioners.
79-10.3 Experience
requirement.
(a) An applicant for licensure as a licensed
marriage and family therapist shall meet the supervised experience requirement
set forth in this section.
(b) An applicant who has met the education
requirement prescribed in section 79-10.1 of this Subpart through completing a
master's or doctoral program registered by the department as leading to
licensure in this field or an equivalent program in marriage and family therapy
shall complete at least 1,500 client contact hours of supervised clinical
experience in a setting acceptable to the department. That experience may include supervised
client contact clock hours completed as part of the program in marriage and
family therapy or after completing such program, in accordance with the
requirements of section 52.33 of this Title.
(c) An applicant who has met the education
requirement prescribed in section 79-10.1 of this Subpart through completing a
graduate degree program in an allied mental health field and additional graduate
level coursework, if needed, shall complete at least 1,500 client contact clock
hours of supervised clinical experience at a setting acceptable to the
department, which all must be completed after completing the graduate degree
program in the allied mental health field.
(d) Supervision of the experience. The experience shall be supervised in
accordance with the requirements of this subdivision.
(1) Supervision of the experience shall
consist of contact between the applicant and supervisor during
which:
(i) the applicant apprises the supervisor of
the assessment and treatment of each client;
(ii) the applicant’s cases are discussed
with the supervisor;
(iii) the supervisor provides the applicant
with oversight and guidance in the application of marriage and family therapy
theories, techniques and supervisory processes to assist the applicant in
developing skills necessary to practice marriage and family therapy, which
emphasizes the treatment of relational, systemic dynamics in therapy and focuses
on special training and techniques required for treating more than one person in
therapy; and
(iv) the supervisor provides an average of
one hour per week or two hours every other week of in-person individual or group
supervision.
(2) Qualifications for supervisors of the
required experience. The supervisor
of the experience shall meet each of the following
requirements:
(i) The supervisor shall have completed a
master's or higher degree program
in marriage and family therapy, in the subject of the field in which the
supervisor is licensed as prescribed in subparagraph (iii) of this paragraph, or
in another field related to the field of marriage and family therapy as
determined by the department.
(ii) The supervisor shall have engaged in
the practice of marriage and family
therapy for three years or the part-time equivalent. For purposes of this subparagraph,
practice on a full-time basis shall mean 960 clock hours in the practice of
marriage and family therapy, earned over a 52-week period;
(iii) The supervisor shall be licensed and
registered in New York State to practice marriage and family therapy, medicine,
as a physician assistant, psychology, licensed clinical social work, or as a
registered professional nurse or nurse practitioner, pursuant to Articles 163,
131, 131-b, 139, 153, or 154 of the Education Law, respectively; or be an
individual with equivalent qualifications as determined by the department; or
for applicants who apply for licensure in marriage and family therapy on or
before December 31, 2007, be an individual with certification or registration by
an acceptable national certifying or registering body for marriage and family
therapists as a clinical supervisor.
To be acceptable to the department, the national certifying or
registering body must be recognized nationwide as an organization that certifies
or registers marriage and family therapists throughout the United States based
upon a review of their qualifications to practice marriage and family therapy
and must have adequate standards for the review of the applicant's
qualifications for practicing marriage and family therapy, as determined by the
department. Such standards must
include standards for the review of the applicant's education and experience for
practicing marriage and family therapy and may include an examination
requirement.
(e) Setting for the experience. For a
setting for the clinical experience to be acceptable to the department, it shall
meet the following requirements:
(1) The setting shall be a location at which
legally authorized individuals provide services that constitute the practice of
marriage and family therapy, as defined in section 8403(1) of the Education
Law.
(2) The setting in which the experience is
gained shall be responsible for the services provided by individuals gaining
experience for licensure.
(3) The setting shall not be a private
practice owned or operated by the applicant.
79-10.4 Limited permits. As authorized by section 8409 of
the Education Law, the department may issue a limited permit to practice
marriage and family therapy in accordance with the requirements of this
section.
(a) An applicant for a limited permit to
practice marriage and family therapy shall:
(1) file an application for a limited permit
with the department and pay the application fee, as prescribed in section
8409(3) of the Education Law;
(2) meet all requirements for licensure as a
marriage and family therapist, except the examination and/or experience
requirements; and
(3) be under the supervision of a supervisor
acceptable to the department in accordance with the requirements of section
79-10.3 of this Subpart.
(b) The limited permit in marriage and
family therapy shall be issued for specific employment setting(s), acceptable to
the department in accordance with the requirements of section 79-10.3 of this
Subpart.
(c) The limited permit in marriage and
family therapy shall be valid for a period of not more than 12 months, provided
that the limited permit may be extended for an additional 12 months at the
discretion of the department if the department determines that the permit holder
has made good faith efforts to successfully complete the examination and/or
experience requirements within the first 12 months but has not passed the
licensing examination or completed the experience requirement, or has other good
cause as determined by the department for not completing the examination and/or
experience requirement within the first 12 months, and provided further that the
time authorized by such limited permit and subsequent extension shall not exceed
24 months total.
79-10.5 Classifications systems. A licensed marriage and family
therapist may use accepted classifications of signs, symptoms, dysfunctions and
disorders, such as the Diagnostic and Statistical Manual of Mental Disorders,
published by the American Psychiatric Association, or an equivalent
classification system as determined by the department, provided that such use is
consistent with the practice of marriage and family therapy as defined in
section 8403(1) of the Education Law.
79-10.6 Special
provisions.
(a)
Alternative requirements. In
accordance with section 8411(2)(a) of the Education Law, an applicant who does
not meet the requirements for licensure as a marriage and family therapist as
prescribed in section 8403(3) of the Education Law, may qualify for a license as
a marriage and family therapist through meeting the alternative requirements
prescribed in either paragraphs (1), (2), or (3) of this subdivision, provided
that the applicant meets all such requirements on or before January 1,
2006.
(1) Alternative route one. An applicant may qualify for a license
as a marriage and family therapist through meeting the following alternative
requirements. The applicant
shall:
(i) file an application for licensure by
January 1, 2006 and pay the fee for the initial license and the fee for the
first registration period, as prescribed in section 8403(3)(g) of the Education
Law;
(ii) be of good moral character as
determined by the department;
(iii) be at least 21 years of
age;
(iv) have completed a master's or higher
degree program in marriage and family therapy or in a related field such as
social work, psychology, or mental health counseling that is registered by the
department pursuant to Part 52 of this Title, or is an equivalent program as
determined by the department, provided that the program includes:
(a) coursework that contains curricular
content in the study of:
(1) human development, including individual,
child and family development;
(2) marriage and family therapy clinical
knowledge;
(3) marriage and family therapy theoretical
knowledge;
(4) research; and
(b) a supervised practicum in marriage and
family therapy; and
(v) after completing the master's or higher
degree program prescribed in subparagraph (iv) of this paragraph, have engaged
in the practice of marriage and family therapy, as defined in section 8403(1) of
the Education Law, for at least 1,500 clock hours.
(2) Alternative route two. An applicant may qualify for a license
as a marriage and family therapist through meeting the following alternative
requirements. The applicant
shall:
(i) file an application for licensure by
January 1, 2006 and pay the fee for the initial license and the fee for the
first registration period, as prescribed in section 8403(3)(g) of the Education
Law;
(ii) be of good moral character as
determined by the department;
(iii) be at least 21 years of
age;
(iv) have completed a baccalaureate or
higher degree program in marriage and family therapy or in a related field such
as social work, psychology, or mental health counseling, that is registered by
the department pursuant to Part 52 of this Title, or is an equivalent program as
determined by the department, provided that the applicant demonstrates the
completion of coursework within such a program that contains curricular content
in the study of human development, marital and family therapy, and research;
(v) after completing the baccalaureate or
higher degree program prescribed in subparagraph (iv) of this paragraph, have
engaged in the practice of marriage and family therapy, as defined in section
8403(1) of the Education Law, on a full-time basis for seven years of the
immediately preceding ten years prior to application for licensure. For purposes of this subparagraph,
practice on a full-time basis shall mean 960 clock hours in the practice of
marriage and family therapy, earned over a 52-week period;
(vi) have submitted certifications from
three individuals endorsing the applicants good professional ethics and clinical
competence to practice of marriage and family therapy. Such certifications shall be
submitted on forms prescribed by the department. The individual making the certification
shall meet the qualifications for supervisors of the experience requirement, as
prescribed in section 79-10.3(d)(2), except that such individual may be
certified or registered by a national certifying or registering body for
marriage and family therapists instead of being specifically certified or
registered as a clinical supervisor by such body; and
(vii) have met one of the following three
requirements:
(a) after completing the baccalaureate or
higher degree program prescribed in subparagraph (iv) of this paragraph, have
three years of supervised experience in the practice of marriage and family
therapy, which may be part of the seven years of experience required in
subparagraph (v) of this paragraph.
The supervisor of the experience must meet the qualifications for a
supervisor of required experience prescribed in section 79-10.3(d)(2) of this
Subpart, or
(b) be certified or registered by a national
certifying or registering body for marriage and family therapy, acceptable to
the department. To be acceptable to
the department, the national certifying or registering body must be recognized
nationwide as an organization that certifies or registers marriage and family
therapists throughout the United States based upon a review of their
qualifications to practice marriage and family therapy and must have adequate
standards for the review of the applicant's qualifications for practicing
marriage and family therapy, as determined by the department. Such standards must include standards
for the review of the applicant's education and experience for practicing
marriage and family therapy and may include an examination requirement;
or
(c) complete an acceptable
post-baccalaureate program in marriage and family therapy or a related field
from an institute chartered by the Board of Regents, or an institution
authorized by its charter or by the Board of Regents to confer degrees in New
York State, or the equivalent as determined by the department, provided that
such program contains curricular content in the study of:
(1) human development, including individual,
child and family development;
(2) marriage and family therapy clinical
knowledge;
(3) marriage and family therapy theoretical
knowledge; and
(4) research.
(3) Alternative route three. An applicant may qualify for a license
as a marriage and family therapist through meeting the following alternative
requirements. The applicant
shall:
(i) file an application for licensure by
January 1, 2006 and pay the fee for the initial license and the fee for the
first registration period, as prescribed in section 8403(3)(g) of the Education
Law;
(ii) be of good moral character as
determined by the department;
(iii) be at least 21 years of
age;
(iv) have completed a baccalaureate or
higher degree program in marriage and family therapy or in a related field such
as social work, psychology, or mental health counseling, that is registered by
the department pursuant to Part 52 of this Title, or is an equivalent program as
determined by the department, provided that the applicant demonstrates the
completion of coursework within such a program that contains curricular content
in the study of human development, marital and family therapy, and research;
(v) after completing the baccalaureate or
higher degree program prescribed in subparagraph (iv) of this paragraph, have
engaged in the practice of marriage and family therapy, as defined in section
8403(1) of the Education Law, on a full-time basis for 10 years of the
immediately preceding 15 years prior to application for licensure. For purposes of this subparagraph,
practice on a full-time basis shall mean 960 clock hours in the practice of
marriage and family therapy, earned over a 52-week period;
(vi) have submitted certifications from five
individuals endorsing the applicants good professional ethics and clinical
competence to practice marriage and family therapy. Such certifications shall be
submitted on forms prescribed by the department. The individual making the certification
shall meet the qualifications for supervisors of the experience requirement, as
prescribed in section 79-10.3(d)(2), except that such individual may be
certified or registered by a national certifying or registering body for
marriage and family therapists instead of being specifically certified or
registered as a clinical supervisor by such body.
(b) In accordance with section 8411(2)(b) of
the Education Law, an applicant who meets all requirements for licensure as a
marriage and family therapist as prescribed in section 8403(3) of the Education
Law, except for the examination requirement, may qualify for a license as a
marriage and family therapist through meeting the requirements of this
subdivision, provided that the applicant meets these requirements on or before
January 1, 2006. The applicant
shall:
(1) file an application for licensure by
January 1, 2006 and pay the fee for the initial license and the fee for the
first registration period, as prescribed in section 8403(3)(g) of the Education
Law;
(2) meet all requirements for the license
as a marriage and family therapist prescribed in section 8403(3) of the
Education Law, except the examination requirement; and
(3) either:
(i) have certification or registration by a
national certifying or registering body for marriage and family therapists,
acceptable to the department. To be
acceptable to the department, the national certifying or registering body must
be recognized nationwide as an organization that certifies or registers marriage
and family therapists throughout the United States based upon a review of their
qualifications to practice marriage and family therapy and must have adequate
standards for the review of the applicant's qualifications for practicing
marriage and family therapy, as determined by the department. Such standards must include standards
for the review of the applicant's education and experience for practicing
marriage and family therapy and may include an examination requirement. For use under this subdivision, such
certification or registration need not be current but shall not have been
revoked for misconduct and/or unethical activities. For documentation of the
applicant's certification or registration status to be sufficient, the national
certifying or registering body must submit documentation verifying the
applicant's certification or registration status directly to the department; or
(ii) if there is no national certifying or
registering body for marriage and family therapists acceptable to the department
as prescribed in subparagraph (i) of this paragraph, have engaged in the
practice of marriage and family therapy, as defined in section 8403(1) of the
Education Law, on a full-time basis for five years of the immediately preceding
eight years prior to application for licensure. For purposes of this subparagraph,
practice on a full-time basis shall mean 960 clock hours in the practice of
marriage and family therapy, earned over a 52-week period.
PROPOSED PROMULGATION OF SECTION 52.33 AND
SUBPART 79-10 OF THE REGULATIONS OF THE COMMISSIONER OF EDUCATION PURSUANT TO
SECTIONS 207, 210, 6501, 6504, 6507, 6508, 8403, 8409, and 8411 OF THE EDUCATION
LAW RELATING TO PROFESSIONAL LICENSURE IN MARRIAGE AND FAMILY
THERAPY
ASSESSMENT OF
iSSUES RAISED BY pUBLIC cOMMENT
Since publication of the proposed rule in
the State Register on August 25, 2004, the State Education Department (SED)
received the following comments:
COMMENT: The 36-semester hour requirement in
section 52.33 for registered programs leading to licensure should be 45 semester
hours with increased clinical content.
RESPONSE: In response, the regulations have
been revised to increase the program to at least 45 semester hours with at least
12 semester hours of clinical content.
COMMENT: Section 52.33(c) should be revised
to clarify that the required practicum includes supervised in-person client
contact providing marriage and family therapy.
RESPONSE: The regulation is consistent with
statute and the Department does not believe that the suggested change is
necessary.
COMMENT: Several individuals commented that
the requirement in Part 52.33(c) for a 300-hour supervised practicum should
specify marriage and family therapy, not counseling and that it should be clear
that the supervised practicum is integrated with the curricular
content.
RESPONSE: The use of "counseling" was a
typographical error and the regulations is revised to replace counseling with "
marriage and family therapy". The
regulation is clear that the program must include a supervised practicum.
COMMENT: Family law, as specified in Part
52.33(b)(4) is not a legal course but involves practicing marriage and family
therapy within legal requirements and should be included in the content area of
professional ethics (Part 52.33(b)(6)).
RESPONSE: The authorizing statute lists
"family law" as required course content, separate from professional ethics or
other identified curricular areas.
COMMENT: Identify in section 79-10.1(2) all
the course work and clinical training required for licensure as a marriage and
family therapist.
RESPONSE: Section 79-10.1(2) requires an
applicant to demonstrate an education that includes a master's or higher degree
from a program registered as leading to licensure in marriage and family therapy
under section 52.34 of the Commissioner's Regulations or its equivalent. Section 52.34 contains specific
information on the curricular content, supervised practicum, and other criteria
that must included in a registered program.
COMMENT: The regulations are not strong
enough and do not differentiate between social work and marriage and family
therapy to protect the public in their choice of one or the
other.
RESPONSE: The regulations implement
statutory requirements that prescribe the scope of practice and specify
qualifying requirements for licensure.
COMMENT: The regulations do not define
practice outside the boundaries of competence, as defined in paragraph 1 of
section 8407 of the Education Law.
Specific language should define the consultation required with a
physician when the marriage and family therapist is treating a patient with
serious mental illness.
RESPONSE: The proposed
regulations define the qualifications for licensure as a marriage and family
therapist. The Department will
consider addressing this issue, within the bounds of our statutory authority, in
future amendments to the definition of unprofessional conduct.
COMMENT: Several individuals opposed section
79.10-1(2) that would allow an individual with a graduate degree in another
field to take one course in marriage and family therapy and meet the education
requirement for licensure.
RESPONSE: The comment is incorrect. The applicant who meets the education
requirements through completion of a graduate degree program in an allied mental
health field must complete professional educational preparation that is
substantially equivalent to a registered program in marriage and family
therapy.
COMMENT: Several individuals interpreted
section 79-10.3(b) to require that an applicant for licensure complete 1,800
hours of supervised experience in marriage and family
therapy.
RESPONSE: In response, the regulation has been
clarified to provide that the applicant must complete 1,500 client contact
hours, which may be completed within a program in marriage and family therapy or
after completing such a program.
COMMENT: The curricular content for marriage
and family therapy should include multiculturalism, its influence on the
organization and the functioning of families, and the use of a cultural
lens.
RESPONSE: The proposed course content the
content prescribed in the Education Law and the accreditation standards for
marriage and family therapy programs. This requirements does not
preclude a program from including additional course work in other areas such as
multiculturalism.
COMMENT: Training programs for marriage and
family therapy should require that supervisors and faculty are licensed and
authorized to supervise candidates seeking licensure as marriage and family
therapists.
RESPONSE: Part 52 of the Commissioner's
Regulations require that faculty in a registered program must be qualified by
training and experience. It is
unnecessary to further specify the qualifications of supervisors and faculty in
regulation. Such qualifications
will be examined during the Department's registration review of the
program.
COMMENT: Section 79-10.3(c) does not
establish supervisor qualifications for an applicant who has met the education
requirement through a graduate degree in an allied field.
RESPONSE: The comment is incorrect. All requirements for supervised
experience, including supervisor qualifications, apply regardless of education
route.
COMMENT: There is a strong discriminatory
language against private practice in the regulations and the document should
value those of use who pursued licensure through private
practice.
RESPONSE: The limited permit allows the
individual to gain experience for licensure, under supervision, in an agency or
private setting. The private
setting, however, may not be owned or operated by the applicant.
COMMENT: A registered professional nurse,
nurse practitioner or physician's assistant should be prohibited from
supervising the applicant's experience required for
licensure.
RESPONSE: The professions identified in the
comment are named as exempt under Article 163 and authorized to practice
marriage and family therapy under the exemption. In response to comments from the
field and in consultation with the State Board for Mental Health Practitioners,
the regulations have been revised to require master's level education and
experience in the field of marriage and family therapy. Individuals licensed in the
above-referenced professions that meet the prescribed education and experience
requirement will be able to supervise the experience. Such individuals will however continue
to be governed by the practice requirements of their profession, including
supervision requirements.
COMMENT: It was suggested that the number of
supervised hours required for licensure should be increased to 1,750 hours over
three years, to be consistent with other jurisdictions.
RESPONSE: Education Law requires that
applicant to complete at least 1,500 client contact hours of supervised
experience for licensure. This number is adequate.
COMMENT: Section 79-10.3(d)(2) should require the
supervisor of the required experience to be licensed as a marriage and family
therapist and designated an approved clinical supervisor by the American
Association of Marriage and Family Therapists.
RESPONSE: The regulations have been strengthened
to increase requirements for supervisors of the applicant's experience. Such individuals are required to have
master's level education and three-year's experience in the practice of marriage
and family therapy. In addition,
they must be licensed in New York State in specified fields, which permit them
to practice marriage and family therapy in New York State, or meet equivalent
qualifications.
COMMENT: Applicants may not be able to
complete the 1,500 client contact hours of supervised experience during the
two-year limited permit period.
RESPONSE: Education Law authorizes the Department
to issue a one-year limited permit so an applicant can compete the experience
and/or examination requirement, and may extend it for one year. The Department
is without statutory authority to extend the duration of the limited permit by
regulation.
COMMENT: Section 79-10.3(e) appropriately
restricts the applicant from gaining experience in a private practice because
this does not provide the breadth of clinical experience, supervision and range
of clients required for a quality experience.
RESPONSE: The proposed regulation does not
prohibit the applicant from gaining experience for licensure in a private
setting. It only prohibits
the setting from being a private practice owned or operated by the
applicant.
COMMENT: We encourage the Department to
adhere to the exact wording of section 8411(3) of the Education Law requiring
use of a classification system
approved by the department .
RESPONSE: The proposed regulation is
consistent with the statute and no change is required.
COMMENT: Many older practitioners with
little academic training have enriched our field and we should honor their
experience by allowing them to become licensed
practitioners.
RESPONSE: The proposed regulations would
allow individuals who meet alternative requirements and apply by January 1, 2006
to be licensed. In accordance with
Education Law, these applicants will still have to meet requirements that are
substantially equivalent to the requirements for licensure established in the
regular route.
COMMENT: The minimum education requirement
for licensure should be completion of a master's degree in marriage and family
therapy.
RESPONSE: In accordance with Education Law section
8411(2)(a), the regulation establishes three alternative routes to
licensure. The alternatives
permit individuals with appropriate education and experience to be licensed, and
would permit baccalaureate education applicants to be licensed. In response to comments from the field
and after consultation with the State Board for Mental Health Practitioners, the
Department strengthened the alternative requirements to require certifications
from qualified individuals endorsing the applicants' good professional ethics
and clinical competence, and that the applicant to meet additional requirements
relating to experience and/or training.
