Wisconsin ... We Have A Problem

Hopefully, you recognize the play on the famous line from Apollo 13. I am also hopeful this situation will ultimately be resolved.

It all started with a meeting that members of the WPA Advocacy Cabinet Licensure Workgroup had scheduled with the Psychology Examining Board this past fall (including me, Tegan Corrigan, Justin Kuehl, Jessie Schroeder and Sarah Bowen). You may recall that we have been working on a proposal for quite some time that would facilitate the licensure process for new grads, given the present day challenges presented by the required postdoctoral year of supervised experience. We had our ducks neatly in a row, and we made our best pitch. To our surprise, the Board was polite, asked a few questions, but didn’t seem that interested, and thanked us for coming. Since this was a proposal that the Board had asked us to prepare, we were at least a little puzzled. Since there were agenda items of interest regarding potential changes to the Administrative Code, we hung around to listen. It was a very good thing that we did!

We learned that ALL of the licensing boards have been charged with the task of revising their codes to bring them into close correspondence with the statutes upon which they were based. Basically, if a requirement isn’t authorized by the statute, it can’t be in the code, and the code cannot embellish the statute. So, if the code requires something that isn’t clearly supported by the statute, that requirement cannot be enforced. Our more senior members may recall that the present statute passed in the 90s was intentionally composed so that the specifics could be fleshed out in the code. This allowed for flexibility in the particular licensing rules so they could be adapted as needed. This is no longer the philosophy in our state government.

So, what are the implications of this? The Board is still in the process of evaluating the “enforceability” of the code, but a few things are clear.

  1. A predoctoral internship can no longer be required for licensure. In fact, no predoctoral clinical experience can be required, and the requirement of an “internship” is expressly forbidden in the statute. Further, per the statute, predoctoral clinical experience is irrelevant to licensure.

  2. The educational requirement is simply a doctorate in psychology from a college or university that is regionally accredited (note that the graduate program itself need not be accredited, only the college or university) “…or have had other academic training or specialized experience, which in the opinion of the board is equivalent thereto.” The current code specifies some requirements for the program and that it include particular elements. It is expected that these requirements will be unenforceable.

  3. Initially, it seemed that the only enforceable requirement for supervised clinical experience would be a year of postdoctoral supervised experience. Both the content of this experience and nature of the supervision are very vague in the statute. However, a more recent opinion suggests that it may not be clear whether this experience must be post-doctoral.

With the passage of the “Practice Act” in the early 1990s, Wisconsin moved from having one of the weakest licenses in the country to one of the strongest. Prior to the anticipated changes above, our license had been at least as strong as all but a very few states. However, with these likely changes in code, our license will again be among the weakest. This has implications for portability. If our licensure requirements are below the standards of our neighboring states (which they now will be), it is feasible that the Wisconsin license may not be recognized by payors in neighboring states and certainly not by national payors. Indeed, prior to enactment of the Practice Act, many of us obtained listing on the National Register so as to better document our qualifications with employers and third-party payors, given the questionable standards of the Wisconsin license at that time.

You may wonder if this is happening in other states. Well, I recently attended my first meeting of the APA Council of representatives. (You probably forgot that you elected me to that job.) While there, I was able to discuss our situation with staff of ASPPB (Association of State and Provincial Psychology Boards) and the APA Practice Organization (APAPO). I’m not sure if this is good or bad news, but we seem to be the only state having this problem.

So, what is being done?

  1. The Advocacy Cabinet has pulled together an excellent workgroup to plan a course of action. This group includes a former WPA president, the president elect of ASPPB, three former members of the Examining Board, liaisons from the current Examining Board, and two training directors. We hope to engage additional training directors for their input, as well as large employers of psychologists. This group might be considered a bit of a hybrid: while it began with the Advocacy Cabinet, it reaches beyond WPA to include non-member psychologists who have a vested interest in licensure. 

  2. The next step is informing our members as well as psychologists outside of WPA. We recently presented these issues at the WPA Convention. This article is being published in the WPA newsletter and posted on our website. We are planning to contact training directors at UW-Milwaukee, UW-Madison and Marquette, as well as local internship programs. We will also be working with contacts at the Marshfield Clinic and the Milwaukee Area Psychological Association. I’m sure the list will grow as we move forward.

  3. We are strongly encouraging psychologists to consider obtaining a CPQ (Certificate of Professional Qualification in Psychology) through ASPPB (the Association of State and Provincial Psychology Boards, http://www.asppb.net) or to seek listing on the National Register of Health Service Providers in Psychology (http://www.nationalregister.org). As the Wisconsin license loses credibility, these credentials should serve to document your qualifications.

  4. A subgroup is working on drafting a new statute that will bring our state up to par with our neighbors. We intend that it will also be more applicable to the current (and rapidly evolving) world of health care and will address issues that are facing us, such as telehealth, online degrees and specializations such as health psychology and I-O. We hope also to address the status of predoctoral interns as well as postdoctoral trainees, such that they are differentiated from master’s level providers.

  5. We will be organizing psychologists to contact their legislators to discuss the issue of licensure and concern about the effects of our diminished license. This will include providing psychologists with background information and talking points.

A large and sustained organizational effort will be required to pass a statute. It will be vital to engage as many members as possible from all over the state. It will also be important for psychologists to develop relationships with legislators from both parties. WPA members will be receiving an email that includes a brief survey regarding any legislative contacts you may have, as well as your interest in participating in this effort. This email will also include material you can use when you discuss the issue with your legislators and when you provide us with feedback on what you learned in your discussions.

Greg Jurenec, PhD