The time period between completing a graduate degree and obtaining an MFT Associate registration number can feel like a strange state of limbo. You’re no longer a trainee, but you’re not yet a registered associate either. Thankfully, hours of supervised experience gained in that time can still count toward licensure — if you fall within the 90-day rule. What is the 90-day rule, and why does it matter so much?
What’s the rule?
First, a quick explanation of what the 90-day rule actually is. If you’re an MFT in California, you can gain up to 1,300 hours toward your licensure requirement while enrolled in your master’s degree program. That experience, typically called a practicum or a traineeship, is overseen by both a clinical supervisor and your university.
After you graduate, you apply to the state for an Associate registration (formerly known as an Intern registration). If you apply for Associate registration within 90 days of your degree posting date, hours of supervised experience you gain between that degree posting date and the date that your registration is granted — no matter how long it actually takes the BBS to review your file — also count toward licensure.
By allowing those hours to count, the pathway to licensure is shortened, at least a little bit. It also means that recent MFT graduates who have been working as trainees in a clinic where they intend to keep working post-registration can continue seeing clients at that clinic while awaiting their registration number, knowing those hours will count toward licensure. But there’s an important new caveat on that rule for anyone who will complete their graduate degree on or after January 1, 2020.
What is changing with the 90-day rule?
Assembly Bill 93 (2018) made a number of changes to supervision standards in those mental health professions governed by the BBS. Among the changes is a new requirement: For those who complete their graduate degrees on or after January 1, 2020, for any hours of experience to count under the 90-day rule, they must be gained at an employer that requires Live Scan fingerprinting as a condition of employment. (In other words, fingerprinting has to be completed before any hours of experience are gained with that employer.)
If you’re wondering why that change was made, a legislator expressed concern that the time between graduation and registration was time when MFTs would be working both outside of the supervision of a university and without a background check performed by the state. The Live Scan requirement was added to alleviate that concern.
Is the rule specific to MFTs?
No. Prior to 2019, Professional Clinical Counselors had a similar rule, and as of January 1, 2019, the 90-day rule applies to Clinical Social Workers as well. (This was also part of AB93.) It should be noted, though, that neither of those professional groups can count pre-degree experience toward licensure.
Originally published February 5, 2018. Updated May 30, 2019.