PETITION FOR A PSYCHOLOGY LICENSE EXAM ALTERNATIVE IN TEXAS (P.L.E.A.T.)

 

We, the undersigned, are stakeholders in the Texas mental health industry who are concerned about the significant difficulties and barriers to become licensed psychologists in Texas.

 

We include professionals who:

 

1.    Have completed the two-year post-doctoral supervised experience and are unable to practice, even under supervision, and must pass the Examination for Professional Practice in Psychology (Part 1 - Knowledge), or EPPP, to become fully licensed;

 

2.    Are currently working as a post-doctoral or pre-doctoral intern, and must pass the EPPP to become fully licensed;

 

3.    Are current or future doctoral student in psychology, and must eventually pass the EPPP to become fully licensed;

 

We also include: 

 

1.    Licensed Psychologists in Texas with a doctorate (PhD/PsyD);

 

2.    And members of the general public concerned with the mental health industry in Texas. 

 

 

OVERVIEW:

Currently, Texas is experiencing a serious mental health and substance abuse crisis and does not have enough licensed psychological providers available to serve its population. The current path to independent licensure for psychology in Texas is difficult, requiring a doctoral degree, and many clinical hours resulting in years of internships, supervision experience, etc. Tuition and possible student loans for several degrees, additional education and training result in a financial struggle for many people who might not have socioeconomic privilege or access. The final step to become a licensed psychologist is to pass the EPPP, which has proven to be difficult for a large amount of those who sit for the exam. And yet, the recent, inflexible demands of the ASPPB (Association of State and Provincial Boards) poses new and additional barriers for Texas with their mandated EPPP (Part 2 – Skills).

 

 

CURRENT STRUGGLE:

Most post-docs have invested thousands of dollars and hundreds of hours studying for the EPPP, especially those who have failed multiple times. Time studying means time away from our families, communities, or focusing on improving our clinical skill set. We cannot ethically accept and treat the populations we seek to serve who require treatment for mental health struggles if we do not have the specific skills necessary, and the emotional bandwidth to hold space for them. Those who fail multiple times may experience "imposter syndrome", wondering if they are truly able to help members of the public due to the possible decline in confidence and overall psyche.

 

Some have sought specific accommodations for the exam, such as additional time due to disability, prescriptions such as ADHD stimulants, and anxiety medications which are sometimes filled only for the period of time dedicated to studying and taking the EPPP. In fact, there are those who have taken other difficult mental health professional and/or licenses examinations without these accommodations and have passed.

 

 

PROBLEMS WITH ASPPB & EPPP:

We call your attention to five significant issues with the ASPPB and EPPP:

 

 

1.    Research published this year by Saldana, Callahan, and Cox, (footnote 1) suggests there are “methodological and analytic weaknesses in the EPPP development approach”, and varied scores between white non-Hispanic and Hispanic individuals. The ASPPB representatives themselves admitted to the Texas State Board of Examiners of Psychologists (TSBEP) at the public meeting on April 11, 2024, "the EPPP itself does not determine quality of the provider specific to the requirements necessary for licensure".

 

2.    Topics that are unrelated to what is necessary for a license have created a large barrier for accessibility towards licensure. One example of is the topic of Industrial Organizational Psychology, which is not a required course in many doctoral programs. Additional examples are areas of research and evaluation; a doctoral degree in Education, Statistics, etc. does not require any standardized national exam to conduct a program evaluation, to be an author for research published in peer-reviewed journals, or even to create assessment tools to for mass consumer or clinical use. Yet, these are topics which appear on the EPPP, and are expected to be answered correctly for a passing score. Texas licensed psychologists should not need to conform to an invented standard other states and Canadian providences hold, and these non-clinical topics are clearly barriers toward becoming licensed in Texas.

 

3.    A frustrating and illogical component of the subsection on assessments is to be asked details of specific assessment tools that candidates are not privy to seeing beforehand. An example of this is the MMPI-II, as specific questions on the various clinical scales and their T-scores. The minutia of details required to memorize is unnecessary for real-world, applicable use. The same goes for psychopharmacology, as brand name and generic medication names of current and older/less commonly used medications, classifications, side effects, etc. is unrealistic for non-prescribers. In fact, Texas pharmacists are required by law to have a reference library "in hard copy or electronic format" (Texas State Board of Pharmacy, Board Rules, p. 183) (footnote 2) with such information, yet psychologists are required to memorize this same information!   

 

4.    In Texas, those who fail the EPPP three times automatically are denied for their application and must pay TSBEP and other third parties to reapply, as well as pay for additional opportunities to sit for the exam. These are additional costs on top of what has already spent in terms of tuition for the educational degrees, continuing education, tutoring company fees, etc., and at a time when the post-doctoral period of two years may have ended thereby not allowing any clinical practice to earn any income. This is a person with a doctoral degree, a pre-doctoral and post-doctoral clinical experience, with real patients/clients/students who want to continue to see their provider the State saw acceptable to practice under supervision not long before.

 

5.    There is no consensus on what studying material to use, which results in confusion of what to study, and opportunists taking advantage of those desperate for help in the form of advertised tutoring, studying programs, and practice tests. Many candidates fall victim to those claiming to help the vulnerable test takers who spend enormous amounts of money and time in a desperate attempt to figure out how to pass the exam. The ASPPB does not hesitate to state the “ASPPB does not endorse or recommend” (footnote 3) any commercial companies with a study program, nor does the ASPPB offer their own specific study content. Instead, the ASPPB simplifies the core content topics without giving specifics on what is relevant within these topics. Additionally, the ASPPB falsely states that the education test takers received should suffice. If this were true, there would be a near perfect passing rate.

 

 

COMPARISION TO OTHER PROFESSIONAL LICENSING:

Other examinations required for licensure, such as the USMLE for medical doctors and the UBE for lawyers, both offer study materials as well as a question bank to study from. There should be something similar for the field of psychology. In addition to helping to study for the EPPP, these materials would have a bonus advantage of usefulness in clinical settings and sharpening our skillset at the same time. Instead, those studying for the EPPP are forced to memorize endless information under the assumption it might appear on the exam, but will never be utilized in clinical practices. Perhaps this is a sign that such content is not necessary to appear on the exam, as it is clearly not applicable for purposes which a license is necessary.

 

When the ASPPB considers “security” of their exam, it translates to no test-taker having the ability to learn from their mistakes as it is unknown what was answered correctly or incorrectly. This is antithetical to the field of psychology, as our profession promotes learning and growth from mistakes and not by hiding behind the “security” of an examination through the monopoly of ASPPB.

 

To the anti-trust conversation, there are licensing boards where alternative exams exist. As an example, to become a Licensed Professional Counselor in Texas, there is the National Counselor Examination as well as the National Clinical Mental Health Counselor Examination; both are acceptable towards licensure. If the ASPPB will not allow the board of psychology in Texas the autonomy to act in its own interests, perhaps it is time to make way for an alternative examination to be considered, regardless of what other states may or may not have tried. In fact, Texas has our own Jurisprudence exam, so it is possible!

 

 

TEXAS:

Texas is being forced into a position by the ASPPB to accept the ASPPB's own, possibly biased data and demographics, which is problematic in and of itself. The ASPPB refuses to allow an independent third party to investigate any of its data. The ASPPB is acting as a functional monopoly on trade in Texas. 

 

There is also a deeper conversation to consider regarding the accessibility of taking and passing the exam itself, specifically for underserved populations and geographical areas of our state. Texas does not have enough licensed psychological providers available as it is, and we are in a serious mental health and substance abuse crisis.

 

NO ONE is suggesting NOT to have an exam for licensing in Texas. However, the purpose of the exam for licensing is to 1) protect the public, and 2) ensure quality providers. The problem is that the EPPP does neither. By definition, every single licensee who has had ethics complaints filed and sanctions against them has passed the EPPP. General protection of the public is certainly important, but to hide behind a false hypervigilance feels almost accusatory that our field (and our board) is full of maliciousness and manipulation. It doesn't make sense for anyone to put themselves through years of education only to work in a field with an incredibly low income in comparison to other fields with this level of education. The reason most of us put in so much effort to our education and studying is because we are genuine about helping others in our communities, to guide them to live better, healthier, and more fulfilling lives. In fact, the American Psychological Association compels us to work pro bono when possible, and many of us find such opportunities in addition to some form of volunteer work. Protecting the public is important for those seeking licensure in psychology in Texas, because we live in that same public!

 

Unless there is another license to practice under, such as counseling, marriage and family therapy, or social work, many are unable to work to provide for themselves and their families. In fact, some colleagues who are unable to practice and earn income due to failing the EPPP multiple times have now approached other boards under BHEC (Behavioral Health Executive Council), such as counseling, to take other exams, such as the National Counselor Examination (NCE) – and are passing them. These people are redoing internships to obtain other licenses and thereby exiting the field of psychology.

 

Please recognize that this can mean a large group of marginalized individuals in Texas, including those with language, learning and/or cultural differences, may now decide not bothering to pursue the education, training, and license in psychology anymore, thereby widening the gap of diverse providers available across Texas. As an example, the need for bilingual (English/Spanish) psychologists is higher than ever, but graduates from any of the six APA accredited doctoral programs in Puerto Rico are not offered to take the EPPP in Spanish. Yet, the EPPP does offer the exam in French, presumably for the French-Canadian provinces. 

 

Perhaps Texas can consider the "spirit" of the rules and recognize the need for equitable access towards licensure in our state. If the ASPPB recommends a passing score of 500 at the doctoral level, is that really the best thing for Texas? Perhaps an alternative is for Texas to lower the score, say to 400 like Alabama, or 350 like Michigan, to obtain a master’s level license (LPA), or to continue the doctoral status of provisionally licensed requiring supervision for a longer period than two years in order to at least continue to practice and earn an income providing psychological services while continuing to retest in the hopes of obtaining a 500 for independent licensure at the doctoral level.

 

The Texas board has been instrumental in its inquiry of all positions since the announcement of the mandatory changes. The special session held in March 2024 was open to the public, as well as the ASPPB's visit with presentation at the April 2024 board meeting. The board's transparency of allowing the public to witness these conversations, as well as allowing members of the public to voice concerns, has felt empowering to those of us who feel hopeless. One member of the Texas board of psychology identified the feeling of being held "hostage" by the ASPPB in their “authoritative mandate”; these words in quotes are a direct quote of a member of TSBEP. Imagine how it feels to be a potential licensee with a personal life, professional career, patients/clients/students, and others to hold space for.

 

The stated mission of the ASPPB is “to support member jurisdictions in fulfilling their responsibility of public protection” (footnote 4). According to the Texas Health and Human Services' December 2023 "All Texas Access Report (footnote 5), "98 percent of the 254 counties in Texas are considered mental health professional shortage areas". How is the ASPPB or the Texas board of psychology reducing barriers to gain additional providers? 

 

In the April 2024 board meeting, staff estimated there are an average of 800 applicants each year in Texas, and that approximately one third of those applicants are not passing the EPPP. That is outrageous! 

 

 

SUGGUESTIONS FOR CHANGE:

In the post-pandemic era, and in the aftermath of Uvalde, Governor Gregg Abbott has prioritized mental health and behavioral services in Texas. 

 

We urge the Texas board of psychology to consider the integrity of a Texas license in psychology as applicable to Texas residents - not to other states, not to Associations of other state boards. Texas only. Those who wish to pursue licensure in other states or PSYPACT (Psychology Interjurisdictional Compact) will have to abide by those rules and regulations. However, in Texas our focus should only be to lower and/or remove barriers to obtain independent licensure at the doctoral level, including costs, content, language, and others.

 

We urge the Texas board of psychology not to be bullied by the ASPPB's functional monopoly on our trade in Texas. Do not allow an outside body to restrain our autonomy in Texas.

 

We urge the Texas board of psychology to offer an independent licensing exam with content specific only to knowledge that is required for licensure in Texas in order to preserve our profession and communities!

 

 

References:

 

Footnote 1: Saldana, S., Callahan, J.L., & Cox, R.J. (2024). The Examination for the Professional Practice of Psychology: An examination of construct validity. Training and Education in Professional Psychology, 18(1), 42-48.

 

Footnote 2: Texas State Board of Pharmacy, Board Rules (March 7, 2024). Retrieved April 2024, from https://www.pharmacy.texas.gov/files_pdf/TSBP%20Rules_MASTER%20FILE.pdf

 

Footnote 3: Association of State and Provincial Psychology Boards, EPPP Myths vs. Reality, Retrieved April 2024, from https://www.asppb.net/page/epppmyths

 

Footnote 4: Association of State and Provincial Psychology Boards, Mission, Values, and Vision, Retrieved April 2024, from https://www.asppb.net/page/Mission

 

Footnote 5: Texas Health and Human Services, All Texas Access Report (2023). Retrieved April 2024, from https://www.hhs.texas.gov/sites/default/files/documents/all-texas-access-report-dec-2023.pdf