Inclusion of Master's Psychologist in the APA: Open Letter of Support

Why I’m Publishing This

The APA Model Licensing Act will shape who gets to practice psychology, how care is delivered, and whether psychology remains a coherent scientific profession in a rapidly changing mental-health system. These decisions are not abstract. They affect access to care, workforce stability, assessment and diagnosis, and the future of the profession itself.

I’m publishing this critique publicly because these issues extend well beyond internal committees or technical policy language. Psychology is already a multilevel profession. Master’s-level psychologists are practicing across the country right now. The question is whether regulation will align with that reality—or continue to restrict scope, fragment professional identity, and push core psychological functions into adjacent fields by default.

This piece focuses on three inseparable issues: who is recognized as a psychologist, what that title means, and whether full scope of practice is granted based on demonstrated competence—including assessment and supervision.

Permission to Reuse

You are welcome to copy, quote, or adapt any part of this text for public comment, advocacy, or discussion. Attribution is optional. The goal is clarity, not ownership.

What’s at Stake

If psychology does not align regulation with workforce reality and competence, it will lose influence—not through error, but through inaction. What follows is a good-faith critique of the Model Licensing Act, offered in the interest of access, coherence, and the long-term integrity of psychology as a scientific profession.

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LETTER

Introduction

The American Psychological Association’s work on the Model Licensing Act reflects a meaningful effort to modernize psychology’s regulatory framework in response to longstanding structural pressures within the profession. By revisiting pathways to licensure and scope of practice, the Act signals an intention to better align psychology with public need, workforce reality, and the profession’s own competency-based foundations.

Psychology today is already a multilevel profession. Nearly 160,000 master’s-level psychologists are currently practicing across the United States, providing psychological services in healthcare systems, educational settings, public agencies, and community-based environments. These clinicians are not emerging participants in the field; they are an established part of the psychological workforce, delivering care, conducting assessment, and supporting complex systems every day. Any model of licensure must therefore begin from the reality that psychology’s workforce is already diversified in training level and function.

The central task of reform is not to create inclusion where none exists, but to bring regulatory structure into alignment with existing practice. When clinicians are recognized as psychologists in function but limited in title, authority, or scope, the result is not protection of standards—it is misalignment between how psychology operates in practice and how it defines itself in statute. Over time, such misalignment weakens coherence, complicates workforce planning, and obscures psychology’s role in the broader behavioral health landscape.

For many years, restrictive and sequential training pathways have constrained entry into the profession, disproportionately affecting individuals from historically underrepresented and economically disadvantaged backgrounds. Addressing these bottlenecks is not a departure from rigor; it reflects a renewed commitment to competence, access, and public service. The question is not whether psychology should remain a high-standard profession, but whether its regulatory structures reflect how competence is actually developed, demonstrated, and sustained.

Other health and scientific disciplines have confronted similar inflection points. Medicine, for example, resolved longstanding workforce and access challenges not by fragmenting professional identity, but by maintaining a unified title while differentiating roles through training and function. Psychology now faces a comparable opportunity to clarify its structure in a way that supports growth without sacrificing scientific integrity.

Modernizing licensure is therefore less about expansion than coherence. A regulatory framework that recognizes psychologists across training levels, preserves a shared professional identity, and aligns scope of practice with demonstrated competence strengthens the profession’s credibility, improves access to care, and supports long-term workforce stability. In that sense, the Model Licensing Act represents not a departure from psychology’s values, but a chance to articulate them more clearly in a changing professional landscape.

Competence

Psychology’s authority has never rested on ordination or title alone. It has rested on proven proficiency. From its earliest professional standards to its contemporary accreditation and ethics frameworks, the field has defined scope of practice through skills that can be taught, supervised, evaluated, and refined over time. This is not an abstract philosophical stance; it is the practical and scientific logic that has guided psychology’s development as a profession.

APA’s own competency model makes this principle clear. Professional authority emerges from training, supervised experience, and evidenced skill within a defined domain of practice. When a function can be reliably taught, supervised, evaluated, and strengthened through training, it is properly understood as a competency. Psychology does not treat authority as innate, nor does it transform skill into privilege by attaching it to a particular degree title. Authority in psychology is acquired, practiced, and verified.

This distinction matters because even evidence-based professions are shaped by the assumptions of their time. Psychology’s history offers reminders—valuable ones—of how easily tradition can be mistaken for evidence.

One of my earliest supervisors as a pre-licensed psychologist was a woman in her nineties who had completed all of the academic and clinical requirements of a psychology program. Despite meeting those standards, her institution declined to confer a psychology degree. Instead, her credential was issued through another college within the university. At the time, this decision was not framed as exclusion. It was presented as scientific understanding. It was widely believed—by respected psychologists—that women were inherently incapable of treating individuals with serious mental illness. Her capability was recognized in practice, even as it was denied in title.

With the benefit of hindsight, the mistake is clear. The exclusion was not grounded in data or outcomes, but in assumptions that had been granted scientific authority without evidence. What is notable is not only that such beliefs existed, but that they were once considered professionally reasonable within psychology’s own regulatory logic.

The profession ultimately corrected course—not by lowering standards, but by bringing them back into alignment with evidence, outcomes, and verified skillsets. That capacity for self-correction is one of psychology’s enduring strengths. It remains a defining feature of the field today.

Competence-based regulation is neither novel nor untested. Across much of Europe, psychology is organized as a fully clinical profession at the master’s level. Master’s-trained psychologists are authorized to provide the full range of psychological services, including psychotherapy, diagnosis, and comprehensive psychological assessment. They also supervise trainees and play a central role in educating the next generation of clinicians. Clinical authority in these systems is grounded in training and demonstrated competence, not in possession of a doctoral degree.

Doctoral training serves a distinct and narrower function. Pursuing a PhD adds research specialization and academic capacity; it does not expand clinical scope, treatment authority, diagnostic responsibility, or supervisory role.

The distinction between a master’s degree and a doctorate in European psychology is therefore not about who may treat the public. It is about who is trained to produce research.

Vermont provides a parallel example within the United States. For nearly forty years, the state has operated under a model in which master’s-level psychologists practice independently, provide assessment and diagnostic services, and comprise approximately half of the psychologist workforce. This structure has supported strong patient reach, workforce stability, and consistent quality, without any evidence of public harm. The result has been extraordinary. Vermont now has the highest per-capita concentration of psychologists in the country, with a thriving professional ecosystem that delivers broad public access, sustains clinical excellence, and meaningfully advances the discipline of psychology.

Both examples point to an additional principle essential to a healthy profession: clear and coherent pathways for advancement. Regulatory systems that recognize proficiency at each level while allowing clinicians to build forward—rather than requiring them to start over—promote retention, continuity, and professional growth. They also serve the public by keeping experienced practitioners within psychology, rather than pushing them toward companion fields.

Competence-based regulation is not a departure from psychology’s values. It is their most faithful expression—and a foundation on which the profession can continue to grow with confidence, credibility, and integrity.

Restriction Causes Displacement, Not Protection

The effects of restrictive scope definitions are no longer theoretical. They are already reshaping who provides assessment and diagnostic services across the country. When psychology limits the participation of its own workforce, services do not disappear. They relocate.

Licensed Clinical Social Workers and Licensed Professional Counselors are increasingly assuming assessment and diagnostic roles because demand is outpacing the pathways psychology currently offers to meet it. This is not a referendum on psychology’s science. It is a workforce response to unmet need.

This pattern appears consistently in legislative chambers and regulatory conversations. Across committees, caucuses, and policy briefings, legislators return to the same priorities: access, continuity, and scale. They want providers who can practice where need exists, who will serve publicly insured populations, and who can expand capacity responsibly. When psychology presents narrow or fragmented pathways, policymakers do not see rigor. They see a profession struggling to deploy its full workforce.

Other professions have responded differently. Social work, in particular, has framed scope expansion as a practical workforce solution—accessible pathways and an explicit readiness to meet demand. As a result, legislators increasingly turn to those models when drafting statutes related to diagnosis and behavioral health access. This shift is not ideological. It is operational.

Professions function within labor markets whether they acknowledge it or not. Scope definitions do not determine whether services are needed; they determine who is authorized to provide them. When psychology restricts master’s-level clinicians, assessment does not vanish. It migrates into statutes governing other disciplines, often with less explicit grounding in psychological measurement and theory. Over time, this distances assessment from the psychologist brand itself.

From a policy standpoint, this outcome is entirely predictable. Legislators are not tasked with preserving professional hierarchies. They are tasked with ensuring service availability. When one profession presents itself as internally constrained and another presents itself as scalable and solution-oriented, the latter will shape statute.

There is also a branding consequence. Psychology has long been trusted for rigor, ethics, and scientific depth. In a workforce crisis, pairing those strengths with visible leadership and openness matters. When psychology demonstrates that it can expand responsibly without sacrificing standards, it reinforces its standing as the discipline most closely associated with sound assessment and diagnostic reasoning.

A profession that actively deploys its competencies preserves them. A profession that hesitates risks losing them. If psychology intends to remain the field most closely identified with scientific assessment, measurement-based decision-making, and diagnostic clarity, assessment authority must be granted to master’s-level psychologists with full, unrestricted scope. Anything less will not protect psychology’s role. It will simply drive assessment practice—and the clinicians trained to provide it—into adjacent professions.

Assessment as Psychology’s Empirical Hallmark

Assessment is psychology’s public signature as a science. It is where the discipline’s core methods—measurement, norming, hypothesis testing, and integrative clinical reasoning—are translated into decisions that shape education, disability determination, treatment planning, and public policy. When psychology is understood as more than a helping profession, assessment is what anchors that distinction.

From a public-service perspective, psychological assessment is also one of the most sought-after and most underprovided services in the mental health system. Schools, courts, healthcare systems, and families face growing backlogs for diagnostic clarification and neurocognitive screening. Waitlists extend for months or years. This is not a marginal problem. It is a structural one.

Treating assessment as a guarded subspecialty rather than a foundational professional function is therefore a strategic error. Psychology’s unique contribution has never been therapy alone. It has been disciplined measurement applied to complex human functioning. When assessment capacity is artificially constrained, the result is not higher standards. It is unmet public need.

The draft definitions reveal internal inconsistency. Master’s-level psychologists are permitted to administer and interpret intelligence and achievement tests—the core instruments underlying most neuropsychological and diagnostic evaluations—while being prohibited from conducting or naming certain categories of assessment. Yet the constructs being measured do not change with terminology. Processing speed, working memory, and executive functioning are not doctoral-only phenomena. The science does not shift based on labels.

Allowing clinicians to use assessment tools while preventing them from fully owning or naming the services those tools constitute does not enhance safety or clarity. It fragments professional identity and weakens psychology’s visibility as the discipline most closely associated with scientific assessment.

Confusion is often reinforced by misinterpretation of publisher-defined access levels. These categories are frequently cited as evidence that master’s-level psychologists should not conduct assessment. That interpretation is incorrect.

Publisher access levels are not educational or clinical judgments. They are jurisdictional and contractual conventions. Test publishers do not hold the position that master’s-level psychologists are incapable of learning, administering, or interpreting complex instruments. Publishers operate from a training- and competency-based model. When jurisdictions authorize assessment within scope, publishers grant access accordingly.

The “level restriction” argument commonly invoked against master’s-level assessment authority reflects a misunderstanding of what these access categories represent. It is not a stance taken by publishers, nor is it supported by psychometric evidence. When used to justify restriction, it reflects confusion within the profession rather than external limitation imposed by the assessment community.

Clarifying this point is essential. Publisher access follows licensure authority. It does not dictate it. When licensing boards authorize assessment based on competence, publishers align. Claims that publisher standards require restricting assessment at the master’s level are factually inaccurate.

What psychology needs is not tighter restriction, but expansion: more psychologists trained and authorized to assess, clearer pathways into assessment practice, and reimbursement structures that recognize psychological evaluation as a core health service. Assessment is time-intensive and central to downstream decision-making, yet reimbursement has not kept pace with its value.

If psychology does not expand assessment capacity decisively, other professions will continue to fill the gap—not because they are better suited to the work, but because systems require someone to do it. Once assessment migrates into adjacent licensure frameworks, reclaiming it becomes extraordinarily difficult.

Assessment is not peripheral. It is psychology’s empirical hallmark, its public signature, and one of its most essential service obligations. Treating assessment as foundational rather than exceptional strengthens psychology’s identity, meets urgent public need, and ensures that the discipline most grounded in measurement remains the primary steward of assessment in modern healthcare.

Ethics, Economics, and Professional Integrity

Scope-of-practice debates do not arise in a neutral context. They unfold within concrete economic and structural conditions that shape reimbursement, access to work, professional stability, and entry into the field itself. The intensity of concern expressed in response to the Model Act—particularly regarding master’s-level psychologists—cannot be understood solely as a question of safety or competence. It reflects a broader convergence of workforce strain, economic uncertainty, and longstanding structural features of the profession.

Psychology today is composed largely of small and mid-sized practices operating under increasing pressure. Reimbursement has lagged behind inflation. Administrative and compliance demands have expanded. Entry into the profession has become longer, more expensive, and more precarious. In this environment, questions about scope and title are inevitably experienced not only as regulatory issues, but as questions of professional viability and future security.

When economic pressure intensifies, professions often gravitate toward protective language. Historically, this has taken the form of emphasizing safety, risk, and standards at moments when boundaries feel threatened. This pattern is well documented across fields. It is not a moral failing; it is a predictable organizational response to perceived scarcity. However, when economic and structural anxieties are expressed primarily through safety-based arguments that are not clearly grounded in outcome data, regulatory clarity suffers.

This dynamic has particular implications for psychology because it intersects with an unresolved access problem. Psychology remains one of the least socioeconomically diverse health professions. Extended periods of unpaid or underpaid clinical labor, coupled with long training timelines and high educational cost, have functioned as structural barriers for individuals without independent financial support. For decades, access to the profession has implicitly favored those with intergenerational wealth or financial insulation. This has limited not only who enters psychology, but who remains in it.

Importantly, when these barriers have been addressed—rather than defended—the results have been constructive. Vermont’s long-standing competency-based licensure model has expanded workforce capacity without evidence of public harm, while supporting a more accessible entry pathway. Similarly, medicine’s transition away from exclusionary training bottlenecks produced not diminished quality, but a larger, more diverse, and more resilient workforce. In each case, initial concerns about safety and dilution accompanied reform, and in each case those concerns were not borne out by outcomes.

Within psychology, resistance to master’s-level inclusion frequently consolidates around safety language at the precise point where structural change would redistribute opportunity. This does not mean that safety concerns are insincere. It means that safety discourse is being asked to carry multiple functions at once: clinical, economic, and cultural. Over time, that conflation weakens the profession’s credibility with policymakers, who are increasingly attentive to workforce realities and outcome data rather than internal hierarchy.

Professional integrity depends on the ability to distinguish these threads clearly. Evidence-based safety concerns deserve careful consideration and empirical grounding. Structural anxieties about access, reimbursement, and professional identity deserve open acknowledgement. When those domains are collapsed into a single argument, neither is well served.

Psychology has historically demonstrated the capacity to recalibrate when its regulatory structures drift out of alignment with evidence and public need. The current moment presents a similar opportunity. Addressing scope, title, and inclusion transparently—without attributing structural fear to clinical risk—strengthens the profession’s ethical standing rather than undermining it. A field grounded in evidence best preserves its authority by ensuring that its regulatory judgments reflect outcomes, competence, and access, rather than inherited assumptions about who should hold professional power.

Title and the Future of the Profession

The word psychologist is one of the strongest brands in mental health. It conveys scientific rigor, clinical expertise, and public trust in a single term. Patients recognize it immediately. Policymakers understand it. Insurers operationalize it without confusion. Preserving that clarity is a strategic necessity for the profession’s future.

Professional titles function as labor-market signals. Introducing alternative or secondary titles fragments that signal. Labels such as “Licensed Practitioner of Psychology” do not improve public safety; they dilute recognition and force clinicians to explain their legitimacy in every professional context. In a competitive mental-health marketplace, clarity accelerates retention. Confusion suppresses it.

Licensure titles also shape the talent market. Psychology is competing—directly and visibly—with social work and counseling for students and early-career clinicians. People do not choose professions based on historical prestige alone. They choose based on time to practice, debt burden, role clarity, and professional standing. A unified professional title signals opportunity and long-term viability.

A diversified profession does not weaken its identity by sharing a title—it strengthens it. Medicine preserved a single professional identity while differentiating roles by training. Nursing did the same. Both expanded. Psychology gains strength when it presents itself as a coherent field with differentiated roles, rather than as a collection of stratified labels.

Preserving the title psychologist across training levels also supports workforce growth. When clinicians are asked to accept unfamiliar titles, they predictably migrate toward professions with clearer branding and broader recognition. That movement does not reduce demand for psychological services—it redirects it outside psychology’s regulatory framework.

The future of psychology depends on visibility and confidence in the public square. A shared professional identity makes the field easier to enter and easier to sustain. It tells students that psychology is a profession with room to grow and an identity worth investing in.

From a marketing standpoint, the conclusion is straightforward. Strong brands expand. Divided brands contract. Preserving psychologist as a unified professional title is not about tradition—it is about relevance, growth, and ensuring psychology remains a destination profession in a competitive landscape.

Inclusion or Integration: The Opportunity Section B Can Realize

More than 150,000 master’s-level psychologists are currently practicing across the United States. They are not future possibilities; they are already delivering psychological services every day—often in resource-strained systems, in roles requiring sophisticated clinical judgment and interdisciplinary coordination. The current provider landscape has already answered the question of whether they belong in psychology.

The question Section B now has the opportunity to address is how that workforce is integrated. The Model Act can either bring master’s-level psychologists fully into psychology through clear, competency-based regulation—or it can incorporate them in a way that limits authority and fragments professional identity despite their essential contributions.

Professional stratification rarely announces itself outright. More often, it emerges through design choices: secondary titles, scope definitions that narrow with credential tier rather than proficiency, or advancement structures that require clinicians to start over. These mechanisms do not exclude practitioners, but they can signal that their role is provisional rather than integral.

That distinction matters, because psychology’s strength has always been its coherence as a scientific profession. Inclusion works best when it is structural—when clinicians are empowered to practice to the full extent of their evidenced skill, not to the margins of a credential category. Sustainable professions build ladders, not ceilings. They create pathways that support growth and long-term investment in the field.

Master’s-level psychologists are highly adaptable professionals. When pathways within psychology are clear and future-oriented, they stay and deepen their contribution. When pathways are narrow, they seek licensure in companion professions that offer clearer scope and advancement. That movement simply shifts psychological work into regulatory frameworks that are less explicitly grounded in psychological science.

Section B therefore represents a genuine moment of choice. It can affirm master’s-level psychologists as full participants in a unified scientific profession, regulated by competence and accountable to shared ethical standards. Done well, this strengthens psychology’s workforce, stabilizes its pipeline, and reinforces its public identity.

Closing

Psychology’s future is being determined now—not by external pressure, but by internal design choices. The profession is not keeping pace with other allied health fields, and this is not a mystery. Professions grow when their regulatory structures reflect workforce reality, public need, and clear professional identity. When they do not, growth slows, talent migrates, and influence erodes.

Other health disciplines have already resolved this tension. They expanded by creating accessible entry points, maintaining unified professional titles, and differentiating roles by function rather than fragmenting identity. Psychology can do the same without compromising scientific rigor or ethical standards. In fact, doing so is the only way to preserve them at scale.

Scientific authority is not sustained through restriction or insulation. It is sustained through relevance, visibility, and public trust. Professions that align regulation with demonstrated competence expand their reach and their influence. Professions that cling to internal hierarchy in the face of workforce demand are bypassed.

Recognizing master’s-level psychologists as psychologists, with full scopes of practice grounded in demonstrated competence—including assessment and supervision—is not a symbolic gesture. It is a necessary workforce decision. Shared professional identity strengthens public understanding, stabilizes pipelines, and reinforces psychology’s role as the discipline most closely associated with scientific assessment and diagnostic clarity. Nurses are nurses. Physicians are physicians. Psychology does not benefit from fragmenting its own name.

Prospective clinicians are already making choices. They compare professions based on clarity, dignity, time to practice, and long-term viability. A profession that presents itself as coherent and inclusive attracts talent. A profession that presents itself as internally stratified does not. No amount of regulatory nuance overrides those signals.

Halfway measures will fail. Incorporation without full integration—titles without authority, inclusion without scope—will discourage entry, accelerate exit, and weaken psychology’s collective voice. Integration grounded in competence does the opposite: it expands capacity, strengthens advocacy, and positions psychology as a field prepared to meet modern demand.

For policymakers, the calculus is straightforward. They are looking for professions that arrive unified, scalable, and solution-oriented. Internal hierarchy debates do not advance access to care. Professions that resolve them internally and present coherent structures are the ones that shape policy.

The question is therefore not whether to protect psychology’s history. It is whether psychology will secure its future—by affirming a unified professional identity, aligning scope with competence, and ensuring that the field remains the primary steward of psychological science in the decades ahead.

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