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THE STATE EDUCATION DEPARTMENT / THE UNIVERSITY OF THE STATE OF NEW YORK / ALBANY, NY 12234

TO:	The Honorable the Members of the Board of Regents
FROM:	Johanna Duncan-Poitier
COMMITTEE:	Higher Education and Professional Practice
TITLE OF ITEM:	Proposed Promulgation of Regulations of the Commissioner of Education Relating to Requirements for Licensure in Psychoanalysis
DATE OF SUBMISSION:	January 4, 2005
PROPOSED HANDLING:	Approval
RATIONALE FOR ITEM:	To Implement Statute
STRATEGIC GOAL:	Goals 2 and 3
AUTHORIZATION(S):

SUMMARY:

Attached for approval is a proposed addition of section 52.35 and Subpart 79-12 to the Regulations of the Commissioner of Education, relating to requirements for licensure in psychoanalysis. Supporting materials for the proposed regulation are available upon request from the Secretary to the Board of Regents.

The purpose of the proposed regulation is to implement the provisions of Article 163 of the Education Law by establishing education, experience, and examination requirements for licensure in the new licensed profession of psychoanalysis, requirements for limited permits to practice this profession, and standards for registered programs leading to licensure in this field. Psychoanalysis is one of four new professions, under the State Board for Mental Health Practitioners, established by Chapter 676 of the Laws of 2002.

The Higher Education and Professional Practice Committee discussed the proposed regulation at its September and December 2004 meetings. A Notice of Proposed Rule Making concerning the regulation was published in the State Register on August 25, 2004. In response to public comments, the proposed regulation was revised in the areas of education, experience, and special provisions for licensing prior to January 1, 2006, and a Notice of Revised Rule Making was published in the State Register on December 1, 2004. An Assessment of Issues Raised by Public Comment since the publication of the revised rule making is attached.

I recommend that the Board of Regents take the following action:

VOTED: That section 52.35 and Subpart 79-12 of the Regulations of the Commissioner of Education be added, as submitted, effective February 3, 2005.

Attachments

AMENDMENT TO THE REGULATIONS OF THE COMMISSIONER OF EDUCATION

Pursuant to sections 207, 210, 6501, 6504, 6507, 6508, 8405, 8409, and 8411 of the Education Law.

1. Section 52.35 of the Regulations of the Commissioner of Education is added, effective February 3, 2005, as follows:

52.35 Psychoanalysis.

In addition to meeting all applicable provisions of this Part, to be registered as a program recognized as leading to licensure in psychoanalysis, which meets the requirements of section 79-12.1 of this Title, the program shall meet the requirements of this section.

(a) The program shall be offered by a psychoanalytic institute chartered by the Board of Regents, or an institution authorized by its charter or by authorization of the Board of Regents to confer degrees in New York State. The program shall lead to a certificate of completion, which shall be conferred upon students who successfully complete the program.

(b) In order to be admitted into the program, the program shall require the student to have completed a master's or higher degree program in any field registered by the department pursuant to this Part, or a substantially equivalent program.

(c) The course of study shall include coursework substantially equivalent to coursework required in a master's degree program in a health or mental health field of study. The course of study shall include a total of at least 1,350 clock hours of study, distributed as set forth in this subdivision in the following four categories: coursework, personal psychoanalysis, supervised analysis, and clinical experience.

(1) Coursework. The program shall include at least 45 clock hours of classroom instruction in each of the following areas, totaling at least 405 clock hours of classroom instruction:

(i) personality development;

(ii) psychoanalytic theory of psychopathology;

(iii) psychoanalytic theory of psychodiagnosis;

(iv) sociocultural influence on growth and psychopathology;

(v) practice technique (including dreams and symbolic processes);

(vi) analysis of resistance, transference, and countertransference;

(vii) case seminars on clinical practice;

(viii) practice in psychopathology and psychodiagnosis; and

(ix) professional ethics and psychoanalytic research methodology.

(2) Personal psychoanalysis. The program shall require the student to complete at least 300 clock hours of personal psychoanalysis.

(3) Supervised analysis. The program shall include at least 150 clock hours of supervised analysis of the student's psychoanalytic cases. The supervised analysis shall include:

(i) 50 clock hours of individual supervision with one supervisor working on one case; and

(ii) at least 100 clock hours of individual supervision with another supervisor working on one or more additional cases.

(4) Clinical experience. The program shall require the student to complete at least 300 clock hours of supervised clinical experience in the practice of psychoanalysis, as defined in section 8405(1) of the Education Law. The clinical experience shall meet the requirements set forth in section 79-12.3 of this Title. In addition, if the setting for the clinical experience is not within the institution offering the program itself, a written contract or agreement shall be executed between the institution and clinical facility which is designated to cooperate in providing the clinical experience, which shall set forth the responsibilities of each party, and shall be signed by the responsible officer of each party.

2. Subpart 79-12 of the Regulations of the Commissioner of Education is added, effective February 3, 2005, to read as follows:

Subpart 79-12

Psychoanalysis

79-12.1 Professional study.

(a) As used in this section, acceptable accrediting agency shall mean an organization accepted by the department as a reliable authority for the purpose of accrediting psychoanalysis programs, having accreditation standards that are substantially equivalent to the requirements for programs registered as leading to licensure in psychoanalysis pursuant to section 52.35 of this Title, and applying its criteria for granting accreditation of programs in a fair, consistent, and nondiscriminatory manner.

(b) To meet the professional education requirement for licensure as a psychoanalyst, the applicant shall present satisfactory evidence of:

(1) having received a master's or higher degree through completing a program in any field that is registered by the department pursuant to this Part, or the substantial equivalent; and

(2) either:

(i) completing a program in psychoanalysis that is registered as leading to licensure in this field pursuant to section 52.35 of this Title or a program in psychoanalysis that is accredited by an acceptable accrediting agency, or a program in psychoanalysis that is substantially equivalent to such a registered or accredited program, as determined by the department; or

(ii) completing a program that is located outside the United States and its territories that is recognized by the appropriate civil authorities of the jurisdiction in which the program is located as a program that prepares an applicant for the professional practice of psychoanalysis, has been verified in accordance with subdivision (c) of section 59.2 of this Title, and which is determined by the department to be substantially equivalent to a program in psychoanalysis registered by the department as leading to licensure in this field, pursuant to section 52.35 of this Title, or to a program in psychoanalysis accredited by an acceptable accrediting agency.

79-12.2 Professional licensing examination.

(a) Each candidate for licensure as a psychoanalyst shall pass one of the following examinations:

(1) an examination that is offered by an organization determined by the department to have satisfactory administrative and psychometric procedures in place to offer the licensing examination, and that the department determines adequately tests psychoanalytic proficiency at the master's degree level and adequately measures the candidate's knowledge concerning the practice of psychoanalysis, as defined in subdivision (1) of section 8405 of the Education Law; or

(2) a scored assessment of case narratives, which shall meet the following requirements:

(i) The case narratives shall be submitted to the department in a form prescribed by the department.

(ii) The case narratives shall describe the assessment and treatment in two cases. The narratives shall demonstrate the relationships among the presenting problems, the background material, a formulation of case dynamics, a diagnosis formulation, the phases of the psychoanalytic process, an assessment of patient functioning, and supervisory issues.

(iii) The case narratives shall be scored by the State Board for Mental Health Practitioners. Failing examinations may be revised and resubmitted only once.

(b) Requirements for admission to examination for licensure as a psychoanalyst. To be admitted to the licensing examination, the candidate shall be required to:

(1) file an application for licensure with the department;

(2) pay the fee for initial licensure and the fee for the first registration period, as prescribed in section 8405(3)(g) of the Education Law; and

(3) present satisfactory evidence of having met the education requirement for licensure as a psychoanalyst, as prescribed in section 79-12.1 of this Subpart, including receipt of the master's degree and the certificate of completion.

(c) Passing score. The passing score for the examination for licensure as a psychoanalyst shall be determined by the State Board for Mental Health Practitioners.

79-12.3 Experience requirement.

(a) An applicant for licensure as a psychoanalyst shall meet the experience requirement for licensure as a psychoanalyst by submitting sufficient documentation of having completed a supervised experience of at least 1,500 clock hours providing psychoanalysis in a setting acceptable to the department, all in accordance with the requirements of this section.

(b) All or part of the supervised experience may be obtained within the education program required for licensure as a psychoanalyst, as prescribed in section 79-12.1 of this Subpart.

(c) Supervision of the experience. The experience shall be supervised in accordance with the requirements of this subdivision.

(1) Supervision of the experience shall consist of contact between the applicant and supervisor during which:

(i) the applicant apprises the supervisor of the treatment of each client;

(ii) the applicant’s cases are discussed with the supervisor in conformity with federal and state laws regarding the confidentiality of patient-identifiable information;

(iii) the supervisor provides the applicant with oversight and guidance in developing skills as a psychoanalyst, including but not limited to, the analysis of resistance, transference, counter-transference, and unconscious processes in the practice of psychoanalysis; and

(iv) the supervisor provides an average of one hour per week or two hours every other week of in-person individual or group supervision. Supervision may be provided in formats other than in-person only with the approval of the department upon a showing of good cause, including but not limited to, inability to locate a sufficient number of qualified supervisors to perform in-person supervision and an acceptable plan to provide the supervision through an alternative format.

(2) Qualifications for supervisors of the required experience. The supervisor of the experience shall meet each of the following requirements:

(i) The supervisor shall have completed a baccalaureate or higher degree program in psychoanalysis, in the subject of the field in which the supervisor is licensed as prescribed in subparagraph (iii) of this paragraph, or another field related to the field of psychoanalysis as determined by the department.

(ii) The supervisor shall have engaged in the practice of psychoanalysis for three years or the part-time equivalent. For purposes of this subparagraph, practice on a full-time basis shall mean 800 clock hours in the practice of psychoanalysis, earned over a 52-week period;

(iii) The supervisor shall be licensed and registered in New York State to practice psychoanalysis, medicine, as a physician assistant, psychology, licensed clinical social work, or as a registered professional nurse or nurse practitioner, pursuant to Articles 163, 131, 131-b, 139, 153, or 154 of the Education Law, respectively; or be an individual with equivalent qualifications as determined by the department; or for applicants who apply for licensure in psychoanalysis on or before December 31, 2007, be an individual with certification or registration by an acceptable national certifying or registering body for psychoanalysts. To be acceptable to the department, the national certifying or registering body must be recognized nationwide as an organization that certifies or registers psychoanalysts throughout the United States based upon a review of their qualifications to practice psychoanalysis and must have adequate standards for the review of the applicant's qualifications for practicing psychoanalysis, as determined by the department. Such standards must include standards for the review of the applicant's education and experience for practicing psychoanalysis and may include an examination requirement.

(d) Setting for the experience. For a setting for the experience to be acceptable to the department, it shall meet the following requirements:

(1) The setting shall be a location at which legally authorized individuals provide services that constitute the practice of psychoanalysis, as defined in section 8405(1) of the Education Law.

(2) The setting in which the experience is gained shall be responsible for the services provided by individuals gaining experience for licensure.

(3) The setting shall not be a private practice owned or operated by the applicant.

79-12.4 Limited permits. As authorized by section 8409 of the Education Law, the department may issue a limited permit to practice psychoanalysis in accordance with the requirements of this section.

(a) An applicant for a limited permit to practice psychoanalysis shall:

(1) file an application for a limited permit with the department and pay the application fee, as prescribed in section 8409(3) of the Education Law;

(2) meet all requirements for licensure as a psychoanalyst, except the examination and/or experience requirements; and

(3) be under the supervision of a supervisor acceptable to the department in accordance with the requirements of section 79-12.3 of this Subpart.

(b) The limited permit in psychoanalysis shall be issued for specific employment setting(s), acceptable to the department in accordance with the requirements of section 79-12.3 of this Subpart.

(c) The limited permit in psychoanalysis shall be valid for a period of not more than 12 months, provided that the limited permit may be extended for an additional 12 months at the discretion of the department if the department determines that the permit holder has made good faith efforts to successfully complete the examination and/or experience requirements within the first 12 months but has not passed the licensing examination or completed the experience requirement, or has other good cause as determined by the department for not completing the examination and/or experience requirement within the first 12 months, and provided further that the time authorized by such limited permit and subsequent extension shall not exceed 24 months total.

79-12.5 Classifications systems. A licensed psychoanalyst may use accepted classifications of signs, symptoms, dysfunctions and disorders, such as the Diagnostic and Statistical Manual of Mental Disorders, published by the American Psychiatric Association, or an equivalent classification system as determined by the department, provided that such use is consistent with the practice of psychoanalysis as defined in section 8405(1) of the Education Law.

79-12.6 Special provisions.

(a) Alternative requirements. In accordance with section 8411(2)(a) of the Education Law, an applicant who does not meet the requirements for licensure as a psychoanalyst as prescribed in section 8405(3) of the Education Law, may qualify for a license as a psychoanalyst through meeting the alternative requirements prescribed in either paragraph (1) or (2) of this subdivision, provided that the applicant meets all such requirements on or before January 1, 2006. The applicant shall:

(1) Alternative route one. An applicant may qualify for a license as a psychoanalyst through meeting the following alternative requirements. The applicant shall:

(i) file an application for licensure by January 1, 2006 and pay the fee for the initial license and the fee for the first registration period, as prescribed in section 8405(3)(g) of the Education Law;

(ii) be of good moral character as determined by the department;

(iii) be at least 21 years of age;

(iv) have completed a master's or higher degree program in any field that is registered by the department pursuant to Part 52 of this Title, or is an equivalent program as determined by the department;

(v) have completed coursework at a psychoanalytic institute chartered by the Board of Regents or an institution authorized by its charter or by authorization of the Board of Regents to confer degrees in New York State, or equivalent coursework, that is substantially equivalent to coursework required in a master's degree program in a health or mental health field of study. The course of study shall include at least 15 clock hours of classroom instruction in each of the following areas:

(a) personality development;

(b) psychoanalytic theory;

(d) analysis of resistance, transference, and countertransference;

(e) case seminars on clinical practice;

(f) psychoanalytic research methodology;

(g) professional ethics;

(vi) have completed at least 150 clock hours of personal psychoanalysis;

(vii) have completed at least 100 clock hours of supervised analysis of the applicant's psychoanalytic cases.

(vii) have engaged in the practice of psychoanalysis, as defined in section 8405(1) of the Education Law, for at least 1,500 clock hours.

(2) Alternative route two. An applicant may qualify for a license as a psychoanalyst through meeting the following alternative requirements. The applicant shall:

(ii) be of good moral character as determined by the department;

(iii) be at least 21 years of age;

(iv) have completed a baccalaureate or higher degree program in any field that is registered by the department pursuant to Part 52 of this Title, or is an equivalent program as determined by the department;

(a) personality development;

(b) psychoanalytic theory;

(d) analysis of resistance, transference, and countertransference;

(e) psychoanalytic research methodology;

(vi) have completed at least 150 clock hours of personal psychoanalysis;

(vii) have engaged in the practice of psychoanalysis, as defined in section 8405(1) of the Education Law, on a full-time basis for seven years or the part-time equivalent. For purposes of this subparagraph, practice on a full-time basis shall mean 800 clock hours in the practice of psychoanalysis, earned over a 52-week period; and

(viii) have submitted certifications from three individuals who meet the qualifications for supervisors of the experience requirement, as prescribed in section 79-12.3(c)(2), endorsing the applicant's good professional ethics and clinical competence to practice psychoanalysis. Such certifications shall be submitted on forms prescribed by the department.

(b) In accordance with section 8411(2)(b) of the Education Law, an applicant who meets all requirements for licensure as a psychoanalyst, as prescribed in section 8405(3) of the Education Law, except for the examination requirement, may qualify for a license as a psychoanalyst through meeting the requirements of this subdivision, provided that the applicant meets these requirements on or before January 1, 2006. The applicant shall:

(1) file an application for licensure by January 1, 2006 and pay the fee for the initial license and the fee for the first registration period, as prescribed in section 8405(3)(g) of the Education Law;

(2) meet all requirements for the license as a psychoanalyst prescribed in section 8405(3) of the Education Law, except the examination requirement; and

(3) either:

(i) have certification or registration by a national certifying or registering body for psychoanalysts, acceptable to the department. To be acceptable to the department, the national certifying or registering body must be recognized nationwide as an organization that certifies or registers psychoanalysts throughout the United States based upon a review of their qualifications to practice psychoanalysis and must have adequate standards for the review of the applicant's qualifications for practicing psychoanalysis, as determined by the department. Such standards must include standards for the review of the applicant's education and experience for practicing psychoanalysis and may include an examination requirement. For use under this subdivision, such certification or registration need not be current but shall not have been revoked for misconduct and/or unethical activities. For documentation of the applicant's certification or registration status to be sufficient, the national certifying or registering body must submit documentation verifying the applicant's certification or registration status directly to the department; or

(ii) if there is no national certifying or registering body for psychoanalysts acceptable to the department as prescribed in subparagraph (i) of this paragraph, have engaged in the practice of psychoanalysis, as defined in section 8405(1) of the Education Law, on a full-time basis for five years of the immediately preceding eight years prior to application for licensure. For purposes of this subparagraph, practice on a full-time basis shall mean 800 clock hours in the practice of psychoanalysis, earned over a 52-week period.

PROPOSED PROMULGATION OF SECTION 52.35 and SUBPART 79-12 OF THE REGULATIONS OF THE COMMISSIONER OF EDUCATION PURSUANT TO SECTIONS 207, 210, 6501, 6504, 6507, 6508, 8405, 8409, and 8411 OF THE EDUCATION LAW RELATING TO PROFESSIONAL LICENSURE IN PSYCHOANALYSIS

ASSESSMENT OF iSSUES RAISED BY pUBLIC cOMMENT

The proposed rule was published as a revised rule making on December 1, 2004. Below is a summary of written comments received by the State Education Department concerning the proposed rule, which were not addressed in the previously published Assessment, and the Department's response.

COMMENT: Proposed section 52.35(b) would require the completion of a master’s or higher degree before entry into a registered program leading to licensure psychoanalysis. The regulations should not penalize psychoanalytic candidates by requiring the receipt of a graduate degree prior to clinical entry, when such a requirement is not imposed upon social workers or psychologists.

RESPONSE: Section 8405(3)(b) of the Education Law establishes the education requirement for licensure in psychoanalysis. It requires the applicant to have received a master's or higher degree and to have completed a registered program leading to licensure or its equivalent. Section 6507(3)(a) of the Education Law authorizes the State Education Department to establish pre-professional education requirements. The requirement that the candidate have completed a master's or higher degree program prior to admission to the registered licensure-qualifying program is reasonable and consistent with the statutory requirements.

COMMENT: We believe the statute mandates that persons in psychoanalytic training who are not either exempt from licensure under Education Law section 8410(1), or already licensed in another field under Article 163, or in possession of a master's degree in a health or mental health field of study, should be required to complete additional coursework equivalent to coursework required for licensure in mental health counseling.

RESPONSE: Education Law section 8405(3)(b) requires the applicant for licensure in psychoanalysis to meet the following education requirement: "Have received a master's or higher degree from a degree-granting program registered by the department and have completed a program of study registered by the department in a psychoanalytic institute chartered by the board of regents or the substantial equivalent as determined by the department. The program of study in a psychoanalytic institute shall include coursework substantially equivalent to coursework required for a master's degree in a health or mental health field of study." The education requirements prescribed in the proposed regulation are consistent with these statutory requirements. The applicant must hold a master's degree, and complete a registered program leading to licensure in psychoanalysis or its equivalent. There is no basis in the authorizing statute to require applicants to complete an additional 48 to 60 semester hours of graduate coursework in mental health counseling beyond this requirement, as suggested by the comment.

COMMENT: The curriculum prescribed in the regulation for registered programs leading to licensure does not adequately provide subject matter knowledge in areas needed for practice.

RESPONSE: The subject area requirements for registered programs leading to licensure are specified in statute. Therefore, the regulation must include these subjects as mandatory requirements for registered programs leading to licensure. These requirements provide adequate subject matter preparation for licensure.

COMMENT: We urge the Department to survey training institute catalogs to establish required coursework in licensure-qualifying programs that is consistent with prevailing areas of instruction.

RESPONSE: Education Law section 8405(3)(b) establishes the minimum subject areas that must be covered by registered programs leading to licensure in psychoanalysis. The regulation prescribes these mandatory subjects areas, which must be included in registered programs at minimum.

COMMENT: The education requirement for licensure should more closely align with the standards for psychoanalytic training developed by the Accreditation Council for Psychoanalytic Education (ACPE), and should all be stated in the education requirement for licensure rather than the requirements for registered programs leading to licensure.

RESPONSE: The Department consulted with a variety of stakeholders in the field of psychoanalysis, including accrediting bodies, training institutes, professional associations, and individual practitioners, during the development of the education requirements for licensure. The Department believes that the requirements are reasonable and ensure adequate educational preparation for licensure. The regulation requires individuals to complete registered programs leading to licensure in psychoanalysis or equivalent programs. The regulation appropriately prescribes requirements for the registered programs.

COMMENT: The coursework in registered programs leading to licensure should include an additional broad-based course on psychopathology.

RESPONSE: The regulation requires registered programs to include adequate coverage in psychopathology, including coursework in psychoanalytic theory of psychopathology, sociocultural influence on growth and psychopathology, and practice in psychopathology and psychodiagnosis.

COMMENT: It is unclear why section 79-12.3 requires a supervisor of an applicant's experience requirement to hold a baccalaureate or higher degree, when a student entering a registered program must have a master’s degree.

RESPONSE: The regulations require the supervisor to have completed at minimum a baccalaureate program in psychoanalysis or a related field, in addition to other prescribed requirements. The practice of psychoanalysis has not been regulated, and many practitioners hold only a baccalaureate degree. These individuals may qualify for licensure under the special provisions, effective until January 1, 2006, that allow licensure of an individual with a baccalaureate degree, and prescribed psychoanalytic training and experience in psychoanalysis. The proposed regulations would allow these experienced practitioners to function as supervisors of applicants for licensure in psychoanalysis, while the applicants are meeting the experience requirement for licensure.

COMMENT: The regulation's requirements for personal analysis and supervised analysis and clinical experience should specify a minimum frequency of three sessions of psychoanalysis per week.

RESPONSE: The regulation includes a requirement that the registered program leading to licensure include 300 clock hours of personal psychoanalysis and 150 clock hours of supervised analysis. The regulation prescribes a supervised experience requirement of 1,500 clock hours in the practice of psychoanalysis. These requirements are sufficiently prescriptive. The Department does not believe it necessary to specify frequency of session per week requirements.

COMMENT: I support the regulation as written and oppose mandating in regulation a particular number of sessions per week that the applicant must meet with the client during the required experience for licensure.

RESPONSE: No response is necessary.

COMMENT: The regulation should permit physicians, psychologists, licensed clinical social workers and other exempt professionals who are permitted by section 8410 of the Education Law to provide psychoanalysis without a separate license to use their own private practices to obtain qualifying experience for licensure in psychoanalysis.

RESPONSE: The regulation requires all applicants for licensure in psychoanalysis to meet a supervised experience requirement. The regulation provides that the setting for the experience shall not be a private practice that is owned or operated by the applicant. This is a reasonable requirement that helps to ensure the quality of the supervised experience. Applicants who are already licensed in another profession will have to meet this requirement and will not be permitted to use their own private practices to satisfy the supervised experience requirement for licensure in psychoanalysis.

COMMENT: The regulations should specify that supervisors of the experience requirement who are licensed in other fields and are exempt from licensure under Article 163 should be governed by the practice requirements of their particular profession.

RESPONSE: The supervisor who is licensed in another profession is bound by the statutory and regulatory requirements of that profession. It is unnecessary to repeat this requirement in these regulations.

COMMENT: The regulation should specify the proportion of individual versus group supervision required of the supervisor of the experience requirement for licensure.

RESPONSE: The regulation requires the supervisor of the experience requirement to provide an average of one hour per week or two hours every other week of in-person individual or group supervision. The Department believes this standard is adequately prescriptive.

COMMENT: The regulation does not respect the ongoing tradition of psychoanalytic training that permits individuals in training to obtain experience in their own private practice, as part of this training.

RESPONSE: Education Law section 8405(3)(c) establishes the requirement that applicants for licensure in psychoanalysis must complete a minimum of 1,500 hours of supervised clinical practice. The regulation requires the setting for the supervised experience to be outside of the student's own practice to help ensure the quality of the supervised clinical experience.

COMMENT: The licensure examination should not be a multiple-choice examination but instead should be narrative case studies.

RESPONSE: At present, applicants will meet the licensure examination requirement through submission of case narratives. The Department will review other examinations as they become available, and will not rule out reliable examinations using the multiple-choice format.

COMMENT: If an applicant fails the case narrative twice, he or she should be permitted to submit additional case narratives.

RESPONSE: The regulation does not prohibit additional attempts to pass the examination but it does restrict the number of times the same failing case narrative may be revised and submitted. This is a reasonable requirement that ensures the integrity of the examination process.

COMMENT: The alternative requirements for licensure provide that the applicant must complete 150 clock hours of personal psychoanalysis. This number should be increased to 300 clock hours.

RESPONSE: The alternative requirements are available until January 1, 2006. They permit applicants who have practiced psychoanalysis for many years prior to the imposition of the licensure requirement to become licensed through meeting alternative requirements, including alternative education and experience requirements. The Department believes that 150 clock hours of personal psychoanalysis is a reasonable minimum for such experienced practitioners.

COMMENT: The requirements in the special provisions that permit licensure with baccalaureate education should require the applicant to pass a licensure examination.

RESPONSE: The special provisions are only available until January 1, 2006, and are designed to assist individuals who have practiced in this field for many years to become licensed. Alternative two of the special provisions requires applicants to be baccalaureate-educated, complete prescribed coursework, have extensive experience in the field, and obtain certifications from qualified individuals that endorse the applicant's professional ethics and clinical competence. These requirements establish satisfactory standards for licensure. An additional examination requirement is unnecessary.

The Honorable the Members of the Board of Regents