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each profession in Tables 1-4, assessment, treatment planning, and counseling (individual and group therapy). Because of their direct link to reimbursement, the other two services, diagnosis and psychotherapy, are presented separately in Tables 5 and 6. As stated in the OIG report (2001) discussed in the background section, scope of practice laws, by themselves, are often inconclusive and insufficient to generate conclusions about what level of practice is intended. The rules written by licensing boards were often helpful in clarifying ambiguous language. However, we made liberal use of an entry in our draft tables, “UC” for “unclear”, until we were able to follow up our research with telephone calls to appropriate licensing boards. While a few cells in Tables 1-4 remain unclear, we were able to clarify the precise intent in each state, for each profession to a far greater extent than was suggested by the OIG report (2001). However, Tables 5 and 6 indicate that there was far less consistency with respect to diagnosis and psychotherapy.

For all of the mental health professions studied, we found little differentiation among three primary mental health services (assessment, treatment planning, and individual and group counseling). That is, if a professional is allowed to provide assessment, s/he is typically allowed to provide individual and group counseling and treatment planning as well. And if s/he is allowed to provide any of these services independently, s/he can usually provide all of them independently. This pattern is illustrated in Tables 1-4, depicting the scopes of practice for psychologists, social workers, marriage and family therapists, and licensed counselors, respectively.

We found relatively little variation from one state to another in the scope of practice allowed for each profession. For example, both LCSWs and PhD psychologists are allowed to practice each of those three mental health services, independently, in all 40 states. Where variation occurs for these two professions it is in the activities permitted by practitioners licensed at a “lower” level, that is, among those members of the profession with less education and/or training. Of 40 states surveyed, 14 license psychologists at the master’s level, but few allow them to practice independently. Kansas, Vermont, West Virginia and Alaska allow independent practice by those licensed at this level, while in Oregon a master’s-trained psychologist may petition the psychology board for the right to practice independently after three years of supervised practice.

The two levels of licensure typically offered to social workers are not differentiated on the basis of doctoral education, but on the completion of a supervised clinical practicum (usually two years and/or 3000 hours). As indicated earlier, the title “licensed clinical social worker” is most commonly associated with this level of training, and all social workers who are licensed at this or


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