Abolish The Two 6-year Rules

Make Licensure Attainable for California Clinicians from Vulnerable Populations

What are the two six-year rules?

 

The Board of Behavioral Sciences has two rules that govern the accrual of hours for intern therapists who are on the path to licensure in California.    

 

One rule concerns the aging out of hours. The other rule concerns limitations on where hours can be accrued.    

 

Aging out:  After graduating a master's program, therapist interns have 6 years in which to gain 3,000 hours of experience. When/if hours are older than 6 years, the intern must register for a subsequent number, and every hour that is 6 years or older is forfeit, which means that hours of experience are lost by the week as they re-accrue. 

 

Site limitations:  Once an intern has registered for a subsequent number, there are limits placed on where they can gain experience - specifically, they are no longer able to accrue hours in a private practice setting.

Why abolish them?

The goals of the two rules, and why each rule no longer serves its purpose.

The rule concerning the aging of hours was designed with the intention of protecting mental health consumers from therapists who may practice out of date modalities, or be unaware of changes in the law.    

 

The rule prohibiting private practice sites for subsequent number interns was designed with the intention of protecting interns from private practice therapists who exploit interns in need of mentorship and supervision for profit. 

 

However…

 

Aging out - there are two contradictions apparent In relation to this rule. One contradiction is longstanding, while the other contradiction comes from a recent policy change.    

 

The longstanding contradiction: if the intern is still acquiring hours, then the experience that they are acquiring is current and relevant. This dismantles the argument that a therapist would go into licensure with irrelevant knowledge of clinical practices.    

 

Recent policy change: As of January 2023, The board of behavioral Sciences has added a new requirement to annual registration renewal. Interns must now take a law and ethics course every single renewal cycle, regardless of whether they passed the exam (which they must pass in order to renew after their first year) to keep up with the changes in the law. This dismantles the argument that a therapist would go into licensure with ignorance of current laws and ethics.

 

Private practice exploitation - It is easy to understand why either of the 6-year rules would make it easier for a private or a public entity to keep an intern in pre-licensure limbo. Rather than protecting the intern from exploitation, The effect of this law makes interns vulnerable to exploitation from public systems, which benefits the government with cheap labor from highly educated individuals for many years - at the expense of the intern's success and well-being.

Who do the six-year rules harm?

Who is affected by the two 6-year rules?
  • Interns with disabilities 
  • Interns with mental illness
  • Interns with chronic illness
  • Interns with terminal illness
  • Interns who are caregivers
  • Interns of lower socioeconomic backgrounds

 

  • Consumers with disabilities
  • Consumers of lower socioeconomic backgrounds 
  • Mental health consumers at large.

 

The harm done to interns:

 

It makes licensure inaccessible to interns who don't come from wealthy backgrounds, or who have impairments or illnesses that place the “intern hustle” out of their reach. 

 

It also forces interns to put their families last. Starting a family, bereavement, caregiving, and even terminal illness are not qualifiers for extending the window of valid hours.

 

When therapist interns are discouraged from being parents until they have finished a journey with such obstacles, what does that say about the mental health field, especially when so many clients are children?

 

The harm done to consumers:

 

It continues to place consumers in the difficult situation of having no choice but to confide in a clinician who may or may not have a clear understanding of their situation.

 

It continues to keep consumers in treatment with therapist interns who might be a bad match, since the scarcity mentality concerning clients, hours and time limits has been instilled in therapist interns.

 

It continues to pollute the relationships between therapist interns and clients who may have difficulty showing up to session for reasons they cannot help, or because of their mental health issues in the first place.

 

It robs consumers of the opportunity to be helped by someone who may have personal experience in what they struggle with.

 

IT CREATES AN EVER-PRESENT CONFLICT OF INTEREST SITUATION, WHICH IS AGAINST THE LAWS AND ETHICS OF THERAPY TREATMENT.

 

The harm done to society:

 

These two rules create obstacles that uphold oppressive systems in the mental health industry, by privileging those who are already privileged, and keeping the underprivileged in positions of disempowerment and dependency on the privileged.

 

Easier Entry 

Better Therapy!!!

If I am not for myself, who will be for me? But if I am only for myself, what am I? If not now, when?

 

  - Rabbi Hillel, Pirkei Avot 1:14