In September 2015, Governor Jerry Brown signed Senate Bill 620, a Board of Behavioral Sciences-sponsored bill that will change how MFT intern hours are counted toward licensure. What is the new law, and why is it happening? This explainer is meant to answer the most common questions about the changes. (Ed. note: This was originally posted in November 2014 when the changes were just a proposal. It’s been updated in October 2015 to reflect the law as adopted.)
What is being changed?
Starting January 1, 2016, there will be two different structures for counting hours of experience for licensure — the “old” structure, which is what is in effect now in 2015, and the “new” structure. Those applying for license exam eligibility before December 31, 2020, can use whichever structure they prefer. More on that below, but it’s perhaps the single most important thing to know: Most people will likely be better off under the new structure, but if you’re concerned that you would be disadvantaged by it, you don’t have to use it as long as your hours will be done before the end of 2020.
The new hours structure will eliminate many of the different categories of hours of experience for licensure — “buckets,” as the BBS calls them. Instead of the current structure, which includes nine minimums and maximums and four combined maximums, MFTs will simply have two buckets: clinical hours and non-clinical.
Clinical hours (minimum 1,750) will be client contact, with individuals, couples, families, and group. The requirement of 500 couple/family/child hours will be kept and will be part of the 1,750 total clinical hours. Non-clinical hours (maximum 1,250) include other forms of experience: Supervision, workshops, client-centered advocacy, and so forth.
Personal psychotherapy, which currently is triple-counted toward licensure, will no longer be counted under the new structure. The current double-counting of up to 150 couple and family hours, which was framed as a temporary incentive for research purposes when it was instituted a few years ago, is also discontinued in the new structure. Couple and family hours will still count as clinical hours, of course, it is only the doubling that will be removed.
Even with those two removals, I expect that the overwhelming majority of candidates will be better off under the new system than the old one. Most of us didn’t stop doing hours in a certain category once we hit the maximum for that category. We just stopped being able to count them. That’s part of why, as AAMFT-CA noted, it currently takes MFTs longer to get from graduation to licensing exams than it takes clinical social workers — even though social workers have to do 3,200 total hours, and they have to do them all post-degree. MFTs can count up to 1,300 pre-degree hours.
When will it take effect?
The bill becomes law as of January 1, 2016. As noted above, it includes a five-year phase-in period (from January 1, 2016, through December 31, 2020), during which time applicants for license exam eligibility can apply under either the current (“old”) standards or the new framework, whichever one works better for them. This way interns who have been gaining personal psychotherapy or couple/family incentive hours in good faith will likely not need to give them up. Again, I expect the new framework will be better for almost all applicants.
Who proposed this?
The BBS Supervision Committee held public meetings around the state in 2014. Formally, the BBS proposed the change. However, they were responding to strong urging from AAMFT-CA and CAMFT, who worked collaboratively on the issue. I represented AAMFT-CA in our work on this. We produced this white paper in 2014 on the difficulty in getting licensed as an MFT in California; one of the specific problems we cited in that paper was the complicated hours structure.
Why was this proposed?
The current (“old”) structure of MFT intern hours includes a bunch of categories that, while sensible by themselves, together create a Frankenstein’s monster of a process. MFT interns do a great deal of work they can’t count because they’ve already “maxed out” that category, but their workplace still requires them to do it as part of their job. When the BBS is evaluating MFT applications for licensure, they have to make sure all of our hours fit within the many minimums and maximums, making the evaluation process take much longer than it does for other professions — part of the reason why the BBS sometimes gets backlogged. Other professions don’t have anything close to the California MFT level of complexity, and there is no evidence that the varied minimums and maximums make consumers safer or therapists more effective. All they seem to do is make it harder to get licensed.
Are the changes good?
In a word, yes. The new structure will be more consistent with other mental health professions in California, and more consistent with MFT standards around the rest of the country. It will ultimately improve portability and streamline the path to licensure without compromising public safety or the overall level of training required to become an MFT.
The bill was the product of a year of public BBS committee meetings and a lot of work by the BBS and professional associations. Some amendments were made along the way, but they didn’t fundamentally alter the proposal. In my mind, it’s great.
I liked the personal psychotherapy incentive. Why does this bill do away with that?
Surely some folks will be bothered by the removal of personal psychotherapy hours, but two key concerns were noted with that category at the November 21, 2014 BBS meeting. 1, Those hours don’t prepare you for licensing *exams* in the way that other forms of experience do. There will be no exam questions on your personal experience in psychotherapy. 2, Other states don’t count those hours, which can create significant portability problems for people who reached 3,000 hours of experience in California through the use of that category. This portability issue was reiterated in the February 2015 BBS meeting, where the board rejected requests from the professional associations to add the personal psychotherapy category back in.
Of course, it’s still important for therapists to do their own work in therapy, and many universities and supervisors will continue to strongly encourage, if not require, such experience.
What happens now?
The BBS will have updated information, including forms for documenting experience under the new hours structure when applying for licensure, available on its web site around the end of 2015. Applications under the new structure will be accepted starting January 1, 2016; applications under the old structure will be accepted through the end of 2020.
One of the nice things about that five-year phase-in period is that it gives the BBS and professional associations time to see how well it’s working. While most applicants for licensure in 2016 and 2017 will probably come in under the old system just because that’s how they’ve been documenting and counting their hours, if it turns out that in 2019 most applicants are still coming in under the old system, we’ll all know that we’ve got some more work to do — and there will be time to do it before the new system becomes a requirement.