Last week, the Association of State and Provincial Psychology Boards (ASPPB) announced that they are pausing plans to require member boards to use the EPPP Part 2 as a condition of Psychologist licensure. They had faced fierce resistance to the mandate, including a recent Federal Trade Commission complaint and a coalition of states looking at developing an alternative exam.
A brief history of the EPPP Part 2
The EPPP (Examination for the Professional Practice of Psychology) Part 2 has been a long time coming. In 2015, ASPPB initially announced plans to develop Part 2 as a second, skills-based assessment intended to work alongside the existing knowledge-based assessment that would become Part 1.
Even then, many states and psychologists balked at the plan. They argued that the proposed Part 2 test was not necessary, was not adequately validated, and would represent a significant additional cost for those seeking to become Psychologists.
Each attempt at the EPPP Part 2 costs $450. ASPPB says that “a two-part examination will not create new barriers to practice. Rather, it promises to smooth the road to licensure.” A newly-required additional clinical exam, at an additional cost of several hundred dollars, is by definition a new barrier to practice.
Still, ASPPB pressed on with the plan. In 2018, they paused mandatory implementation in the face of resistance from member boards. However, as some of those boards made clear they would not implement an optional second test, ASPPB chose in 2022 to mandate its adoption. Essentially, ASPPB was holding the regular EPPP hostage, telling boards they would no longer be allowed to continue using the existing EPPP unless they also adopted the EPPP Part 2. ASPPB gave states until January 1, 2026 to adopt the new, 2-part exam.
Boards fight the mandate
State boards again pushed back. Once it became clear that simply voicing their concerns directly to ASPPB was not working, several states decided to go further.
California passed legislation in 2023 making prelicensed Psychologists eligible to take “any and all” required licensing exams upon completion of the academic coursework required in their doctoral degree programs. The person would not even have to have graduated; the bill specifically excluded internship and dissertation.
Texas, meanwhile, fired off a letter in June 2024 complaining to the Federal Trade Commission. The Texas State Board of Examiners of Psychologists accused ASPPB of violating antitrust laws by creating an unnecessary, additional barrier to Psychologist licensure and mandating that all states adopt the new test. ASPPB disagreed, and hired a powerful law firm in preparation for a possible FTC response.
Texas also brought media attention to the dispute, and proposed amendments to ASPPB bylaws [starting on page 11] that would allow member boards to opt out of anything ASPPB produced going forward.
Finally, a coalition of states led by Texas had started the steps of potentially developing an alternative exam for Psychologist licensure. The Texas Tribune noted that other states including California, Florida, New York, and Oklahoma had supported these initial efforts.
ASPPB finally relents, mostly
In its statement announcing the change of course last week, ASPPB said they were rescinding the 2026 mandate. They reported that they would immediately begin work instead on a “single-session” exam that would integrate the existing knowledge test (Part 1) with the kind of skill assessment done in the currently-optional Part 2.
The statement suggests that ASPPB continues to believe in skills-based assessment, but recognizes that the internal fight developing over the Part 2 mandate was not worth the cost.
What the debate reveals
It is no secret that clinical exams for mental health licensure are highly problematic. No mental health clinical exam has ever been correlated with actual future safety or effectiveness in practice, so they do not serve the public-protection mission of licensing boards in any demonstrable way. However, they do consistently show disparate outcomes on the basis of race and ethnicity, raising serious questions about their fairness. And my own work shows that mental health clinical exams do not appear to be developed and used in ways that meet industry standards for testing.
But they do give the appearance of high professional standards, and they tend to make their developers a lot of money. The Association of Social Work Boards (ASWB), which develops exams for social workers at the bachelor’s, master’s, and clinical levels, reported more than $40 million in assets in ASWB’s most recent federal filing. Roughly $19 million of its $21 million in annual revenue came from testing fees.
Licensing boards are often in a difficult position where testing is concerned. Even if the tests have no actual value for protecting the public, testing is typically mandated by state law. There are not usually viable alternative exams available if a board doesn’t like or trust the one it is using. And because boards often make up the associations that develop the tests, those boards are acting as both the buyer and seller of the exam — a clear conflict of interests. (The one major mental health profession for which this is not true in the US is counseling, as the independent National Board of Certified Counselors develops the counseling exams states typically use.)
Pushback can win
Perhaps most importantly, this episode demonstrates that real pushback against unnecessary and expensive testing can work. In this case, we do not know much about the internal decision-making at ASPPB, but we can speculate about three potentially important factors:
- The Federal Trade Commission complaint was a real threat. Texas had complained to the FTC that the effort to mandate the EPPP Part 2 amounted to an unfair restraint on boards’ decision-making. ASPPB made clear that they didn’t agree with that assessment. But had the FTC chosen to move forward with an investigation, ASPPB’s legal costs would have been significant, and there is no guarantee they would have won in court. They may have chosen not to take the risk.
- Lots of member boards were agitating against the new exam. It’s one thing if one or two members of an association of boards don’t like the decisions of the association. It’s quite another thing if several boards work together in opposition to those decisions. ASPPB saw that the debate was creating meaningful division in the organization. That’s something they would understandably want to minimize.
- Those opposing boards were going to develop an alternative. If there’s one thing that exam developers in mental health care seem allergic to, it’s competition. ASWB, for example, has been very active in fighting proposals in several states to create alternative pathways to social work licensure. Interestingly, John Bielamowicz, the presiding member of the Texas psychology board, told the Texas Tribune that ASPPB’s decision to back off from the two-part exam may not end the state’s efforts to develop an alternative.
Clinical exams for mental health licensure are a costly and after-60-years-still-unproven mechanism for protecting the public from incompetent mental health care. They constrict the licensee population at a time of dire mental health care shortages around the country.
The pushback against the EPPP Part 2 shows that resistance to these exams can work. That resistance appears to work best when it is loud, widespread, and willing to directly threaten exam developers’ pocketbooks.