Recent data shows that clinical counselors are almost twice as likely to be delinquent in renewing their California registrations compared to clinical social workers. Associate Professional Clinical Counselors (APCCs) are almost three times as likely to be delinquent as MFTs. As of September 2024, more than a quarter of California APCCs hold delinquent APCC registrations.
California data
Here is the most recent data from the California Board of Behavioral Sciences. This looks at the population of associates as of September 23, 2024. (Associates in all professions are post-degree clinicians who have registered with the board so that they can gain supervised clinical experience on the way to full licensure.)
Chart by Ben Caldwell. Data from California Board of Behavioral Sciences.
Why counselors don’t renew
This data is reflective of a longstanding pattern with APCC registrations. It has been typical for years that more APCC registrations have been delinquent than AMFT (Associate Marriage and Family Therapist) or ASW (Associate Clinical Social Worker) registrations.
The reasons seem likely to be related to how LPCC licensure works in the state. It’s fairly common for degree programs to market themselves as making graduates eligible for dual licensure (LMFT and LPCC). The degree requirements for licensure are similar enough that some programs offer students a degree eligible for both license types if the student simply takes a few extra courses.
However, as graduates move ahead in the process, they find some key differences between the license types. AMFTs are required to gain experience with couples, families, and children on the way to licensure. APCCs don’t have that requirement, but face a different obstacle: Unlike MFTs, counselors cannot count any pre-degree experience toward their license.
So, as associates with dual-license-eligible degrees get closer to their clinical exams, they find that counting those pre-degree hours makes it possible for them to achieve licensure as an LMFT months or years before they could achieve LPCC licensure. And the idea of dual licensure, which sounded good years earlier in graduate school, looks a lot less appealing when it means additional months under supervision at the end of the licensure road.
Put more simply, it appears that many people who initially hold both registrations decide to drop the APCC registration and just pursue licensure as an MFT.
Defining the problem, if there is one
Arguably, any delinquent registration is a problem. It indicates that someone on the road to mental health licensure is departing from that road. That may deprive the community of a trained mental health professional. The delinquency rates for MFTs and social workers, both above 10%, are themselves troubling in this light.
Renewing a registration is not burdensome. So the fact that more than one in 10 registrations is delinquent at any given time should raise concerns. State boards should seek to more fully understand the reasons why individuals are late to renew such registrations, or choose not to renew at all.
At the same time, if the high number of APCC delinquencies largely reflects folks who initially held dual registrations dropping just one of them, that may be less of an issue. It would not reflect individuals dropping out of the pathway to becoming a licensed therapist. It would instead leave policymakers with more accurate data about the actual number of people on that pathway.
Possible policy solutions
In prior BBS meetings, counselors have repeatedly stated that they do not want the heavy regulatory burden that would come with allowing counselors to count pre-degree hours toward licensure. They would rather that universities maintain their control over pre-degree experience.
But there is one thing the BBS could do to better understand the issue of delinquent APCC registrations. They could create a process for registrants to voluntarily surrender a registration. This would help ensure that BBS data on the licensure pipeline is current and accurate. It also presents an opportunity for surveys or other research at the time of surrender. This way, the board could better establish why therapists choose to give up their registrations.
At present, there’s no official way for someone to give up an associate registration. They have to just let it lapse into Delinquent status, and then eventually have it designated as Cancelled. But the BBS allows fully licensed clinicians to move a license to Inactive or Retired statuses. Each has its own implications for later restoring that license to Active status. If the board wanted to minimize instances of individuals surrendering a registration and then wanting it back, they could present similar opportunities for registrations to be paused without being fully given up.