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including Licensed Pastoral Counselors. In Kentucky, the supervisors may include nurses with a master’s and psychiatric certification and Certified Professional Art Therapists.

DISCUSSION Core Mental Health Services and Reimbursement

Most state licensure laws permit psychologists, social workers, marriage and family therapists and licensed professional counselors to practice assessment, treatment planning, and individual and group counseling. We found that psychologists and social workers are licensed in every state we studied, and that each of these professions has a level of licensure that permits that these core services be delivered independently. Similarly, every state that licenses marriage and family therapists and professional counselors permits these professionals to engage in at least some, and usually all, of these core functions independently. Consequently, we conclude that state licensure laws create little functional difference between these four professions in their ability to obtain an independent level of licensure and provide core mental health services.

Despite the fact that there is limited variation in the ability of the four professions studied to perform core mental health services, we found that the explicit authority to diagnose and provide psychotherapy to patents/clients was not consistent across states. Psychologists were the most likely profession to have diagnosis and psychotherapy included in their scopes of practice. However, in some states even psychologists were not explicitly permitted to perform these functions. In many states the explicit right to diagnose or to perform psychotherapy was not included in the scopes of practice for social workers, MFTs or LPCs, however no state explicitly prohibits these professions from providing these services. Consequently, we deem it unreasonable to use the absence of explicit language around diagnosis or psychotherapy as rationale for refusing to reimburse a specific profession for performing the core mental health services that fall within its scope of practice. In fact, our findings would seem to provide support for increasing the number of practitioners eligible for reimbursement, rather than for limiting it to one or two professions.

A handful of states have included language in their scope of practice laws to avoid the interpretation of these laws as a mandate for third party reimbursement. Thus, while state licensure laws may not have created explicit barriers to entry into independent mental health practice, they have often avoided language that might be used to break down barriers. Payers who seek guidance from scope of practice laws as to whom they should be paying for specific services may be disappointed. States that wish to dictate to third party payers that a specific


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