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between assessment and diagnosis, and the distinction between counseling and psychotherapy, may not be apparent to the layman, states and payers find substantive differences. Most licensure laws treat these as separate services, and many payers will accept bills for diagnosis and for psychotherapy, but will not pay for assessment or counseling. (Strosnider & Grad, 1993). We decided not to include psychological testing among the services inventoried because this service appears to be the exclusive domain of psychologists, with little variation from state to state. Data Collection

For each profession, we obtained licensure laws and rules from each state included in the study. As indicated earlier, licensure laws (also called regulations) are part of the statutes set down by the state legislature and are typically found in the “occupations and professions” section of state law. The rules are part of each state’s administrative code. States differ on which part of their administrative infrastructure is responsible for collecting and maintaining professional rules. They are typically written by the state board that regulates a profession under authority granted by the state legislature, and usually contain more detail and some interpretation of licensure laws.

Using these documents, we sought to determine whether each of the services targeted in this study could be performed independently by members of a profession, could be performed only with supervision, or are explicitly prohibited for that profession. Because the language used in both licensure laws and rules is not consistent from one state to another, we developed a protocol to guide our interpretation of the wording used by each individual state. Where language was explicit and consistent, we were able to make a determination solely on the basis of document review. However, in many cases there was some ambiguity or seemingly contradictory language in the laws and/or rules, so that we could not be confident in relying exclusively on our own interpretation of these documents. These cases were followed up with telephone calls to the state board for the profession in question, asking for clarification or examples of how the statute or rule is interpreted in practice. By this process, we were able to arrive at a confident summary of the scope of practice for each profession in each state. To assure consistency, all members of the research team were trained by an attorney who is also a clinician, and has extensive experience with interpretation of licensure laws.

Because states may issue more than one type of license within a profession, we developed a protocol for determining what types of license for each profession we would include in our analysis. Simply stated, we eliminated from consideration all levels of licensure that are


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