Consider these related issues and questions.

Education and training requirements for psychology licensure vary across states. Most states align with APA’s Model Act for State Licensure of Psychologists, which recommends that applicants complete “the equivalent of two full-time years of sequential, organized, supervised professional experience prior to obtaining the license.”

Under the Model Act, applicants who plan to practice as a health service provider must complete one of the two years of supervised clinical experience as a predoctoral intern (optimally in an APA accredited site) and the other following completion of the doctoral degree program.

About a dozen states have enacted sequence-of-training legislation allowing psychology trainees to complete their supervised clinical training by the end of their doctoral degree program. For example, the state of Washington requires two years of supervised experience totaling 3,000 hours, where 1,500 hours must be completed during an accredited internship and 1,500 hours may be completed in a predoctoral internship and/or postdoctoral supervised experience. Those hours of supervised clinical training must meet certain criteria and be documented appropriately to comply with state requirements.

In all cases, the intern or trainee must be supervised by a licensed psychologist. Psychologists have an ethical obligation to maintain competence in providing services, teaching and conducting research. That same obligation extends to ensuring that any trainee under the supervision of a psychologist performs competently (see Standards 2.01(a), Boundaries of Competence, and 2.05, Delegation of Work to Others, APA Ethical Principles of Psychologists and Code of Conduct, 2010). 

Psychologists who are interested in supervising an intern or postdoctoral trainee should first check the supervision requirements specified by your state licensing board. The state psychology practice act and implementing regulations will outline the supervision requirements in terms of what is required of the psychologist and the supervisee and what kind of documentation must be submitted to the board. Below are some specific issues to consider and to ask your licensing board.

Additional questions to consider are: 

  • How does your state law define supervision? For example, Ohio has three different categories of professional supervision in psychology: psychological work supervision, psychological training supervision and psychological umbrella supervision. Only psychological training supervision qualifies as part of the eligibility requirements for licensure. How many total hours of supervised clinical training does your state require for licensure? Is there a minimum number of hours per week or per month in which the psychologist must provide face-to-face supervision to the trainee? 
  • How is supervision conducted? Must it be in-person or can it be done virtually? For example, Montana permits teleconferencing as a substitute for face-to-face supervision if using technology that allows for two-way, interactive audio-video interaction. For audio-only teleconferencing, only up to 25 percent of the total supervision is permitted. 
  • Does your state require a supervision contract between you and the trainee that must be submitted to the licensing board? Does the state place the responsibility on the supervisee to submit the required documentation? Or are you as supervisor required to register in some fashion with the licensing board? North Carolina specifies the respective responsibilities of the supervisor and supervisee and requires a signed psychology supervision contract to be filed with the licensing board. Colorado requires licensure applicants to file with the psychology licensing board certificates of completion signed by the applicants’ supervisors attesting to completion of their supervised training. Likewise, supervisors are expected to maintain accurate records tracking their supervisees’ clinical training including supervision hours. 
  • What title may the supervisee use since he/she is not (yet) a psychologist? It is important to check your licensing law to confirm what title your supervisee may use. More importantly, it is critical to inform patients that: your supervisee is completing his/her clinical training under your supervision; you will remain involved in the services provided by your supervisee; and patient confidentiality protections apply (See Standard 10.01(c), Informed Consent to Therapy, APA Ethical Principles of Psychologists and Code of Conduct, 2010). 
  • How do I address the financial aspects of supervision? May I charge the supervisee for supervision? May I bill for the supervisee’s services? Many states may not allow supervising psychologists to bill the supervisee for providing supervision. However, there may be exceptions. For example, Ohio prescribes very narrow circumstances under which a psychologist may charge the supervisee for supervision as described in Ohio Admin. Code Section 4732-16. Whether you can bill for services provided by a supervisee will depend upon the payer. Medicare will not pay for services provided by a supervised individual. However, private insurance companies and even Medicaid might. It is incumbent upon the supervising psychologist to check with each individual payer to determine that payer’s policies.

In addition to checking with your licensing board about what steps must be taken at the beginning, during the course of and upon completion of supervision, it is also important to check with your professional liability company to ensure that your current malpractice coverage extends to your role as a clinical supervisor. You might also ask what kind of coverage your supervisee needs for his/her supervised professional training period.

Please note: Legal issues are complex and highly fact specific and require legal expertise that cannot be provided by any single article. In addition, laws change over time and vary by jurisdiction. The information in this article does not constitute legal advice and should not be used as a substitute for obtaining personal legal advice and consultation prior to making decisions regarding individual circumstances.