Protesting Regulations for Article 163 Regarding Marriage and Family Therapy

PETITION TO THE STATE EDUCATION DEPARTMENT

We the undersigned wish to express our deep concern regarding the revised proposed regulations published on December 1, 2004 with respect to the licensing of marriage and family therapists under Article 163 of the New York State Education Law. We are deeply disappointed that many of the recommendations put forth in a previous petition to strengthen the proposed regulations were not included in the revised proposed regulations. These recommendations were made in the interest of protecting the public from practice by individuals who are inadequately trained or unqualified to provide marriage and family therapy. We believe that the regulations as they now stand still do not adequately protect the public.

Below please find our commentary on the revised proposed regulations.

1. Marriage and Family Therapy [52.33]

Curricular Content (Item b)

In our original petition we recommended that programs accredited as leading to licensure in Marriage and Family Therapy include in the coursework the study of multiculturalism, its influence on the organization and functioning of families, and the use of a cultural lens in intervening with families. As we noted, this is very much in keeping with a document entitled Guidelines on Multicultural Education, Training, Research, Practice, and Organization Change for Psychologists which was approved as policy of the American Psychological Association (APA) by the APA Council of Representatives in August 2002. In keeping with the position of this report, we believe that understanding the cultural context of family functioning is critical to competent assessment and intervention with families and should be a required aspect of any training in family therapy.

2. Experience Requirement [79-10.3]

Supervision [79-10.3 (d)]

We welcome the additional requirement that supervisors shall have engaged in the practice of marriage and family therapy for three years or the part-time equivalent. However, there are two items on which we wish to comment.

a) Regarding practitioners licensed as Marriage and Family Therapists, pursuant to Article 163 of the Education Law, we strongly recommend that the three years of engagement in the practice of marriage and family therapy be in addition to the 1500 clinical contact hours required for licensure.

b) Regarding professionals licensed pursuant to Articles 131, 131-b, 139, 153, or 154 of the Education Law, there is no mention of specific training in marriage and family therapy. We recommend that the three years clinical experience practicing marriage and family therapy be subsequent to training in marriage and family therapy.


Setting for the Experience [79-10.3 (e)]

In our previous petition, we indicated that we believed that a private practice setting is not an acceptable setting for graduates of masters or doctoral programs in Marriage and Family Therapy to obtain their 1500 supervised clinical contact hours to be eligible for licensure. We continue to oppose strongly the setting of a private practice for the gaining of this experience under a limited permit because we believe that in the practice of marriage and family therapy, a private practice setting does not provide the clinical experience, breadth of supervisory selection, or range of clients to provide a high quality training experience.

3. Special Provisions [79 10.6]: Alternate Routes Two and Three

As indicated in our previous petition, we expressed a strong position that a baccalaureate degree is not sufficient clinical training for independent work in any mental health field. Maintaining high standards to protect the public in the mental health field is as important as in other fields of human services such as law and medicine. It is contrary to standards in all these fields to have practitioners who have not completed at least a masters level degree. Not only is this minimum training level educationally necessary, but the admission process to post-baccalaureate training programs is essential in identifying individuals who are not suited to the field. We therefore recommend that the regulations for alternate routes two and three be modified to require a masters or higher degree program, rather than a baccalaureate or higher degree program.

We believe that it is in the interest of protecting the public that these recommendations be incorporated into the revised proposed regulations for the masters level license in Marriage and Family Therapy.