The time period between completing a graduate degree and obtaining an Associate registration number from the BBS can feel like a strange state of limbo. You’re no longer a trainee (or, for social workers, an intern), but you’re not yet a registered associate either. Thankfully, hours of supervised experience gained in that time can still count toward LMFT, LPCC, or LCSW 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.
For MFTs as well as PCCs and CSWs, 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 — can count toward licensure, with some caveats.
By allowing those hours to count, the pathway to licensure is shortened, at least a little bit. It also means that recent graduates who have been obtaining pre-degree experience 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 post-degree hours can count toward licensure. But there’s an important caveat on that rule that applies to anyone who completed their graduate degree on or after January 1, 2020.
What changed 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 was a new requirement: For those who completed 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.)
Are there places where you cannot gain hours under the 90-day rule?
Yes. Clinicians under the BBS cannot gain hours of experience in a private practice setting until they actually have their registration number in hand, regardless of when they applied for it.
Is the rule specific to MFTs?
No. Prior to 2019, Professional Clinical Counselors had a similar rule, and since 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 professions can count pre-degree experience toward licensure.
Originally published February 5, 2018. Last updated May 5, 2023.