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MPA Fights Bill to License “Independent Psychotherapists”

Saturday, July 19, 2014   (2 Comments)
Posted by: Jonathan Brush
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July 18, 2014

Senator James T. Welch

Chair, Joint Committee on Health Care Financing

State House, Room 416A

Boston, MA 02133 Fax: 413-306-5179


Representative Jennifer E. Benson Vice Chair, Joint Committee on Health Care Financing

State House, Room 236

Boston, MA 02133

Fax: 617-722-2813


Re: Opposition to HB 236: An Act for consumer protection and regulation in psychotherapy.

Dear Senator Welch and Representative Benson:

There are approximately 5000 licensed psychologists in Massachusetts. The Massachusetts Psychological Association is the largest organization representing psychologists in the Commonwealth. I am writing to you on behalf of the MPA and request that you and your colleagues on the Joint Committee of Health Care Financing oppose HB 236 an Act for consumer protection and regulation in psychotherapy.

H236 was filed in response to House Bill 3466, An Act To Protect Psychotherapy Patients which would protect consumers by restricting the practice of psychotherapy to licensed providers with psychotherapy contained in their scope of practice. HB 236 attempts to create a “back door” route to licensing individuals who wish to provide “psychotherapy” without training and expertise in comprehensive assessment and treatment of mental health conditions associated with one of the already established mental health professions and a group of individuals.

House Bill 236 creates a new and separate licensing process for “psychoanalysts.” However, psychoanalysis is not a “profession” as is psychiatry, psychology, social work and nursing. Rather it is a type of psychotherapy, a tool used by properly trained professionals. The American Psychological Association defines psychoanalysis as an advance specialization of the mental health professions. There are hundreds of recognized types of psychotherapy. Creating separate professions for practioners of each individual type of psychotherapy is neither practical nor in the consumers’ best interest. As an advanced specialty practice by otherwise licensed mentalprofessional, properly trained psychoanalysts are developing this specialty on a foundation that includes broad training in the causes of mental disorders, assessing mental disorders and an understanding of many different types of psychotherapies and treatments. Even if one chooses to specialize in psychoanalysis it is important that they have an understanding of the broad range treatment options and can ethically advise consumers on their choices so they can make a properly informed choices for treatment.


Individuals who wish to train and practice in psychoanalysis already have many established legal ways to become licensed in the Commonwealth without this bill becoming law.


Should House Bill 3466, An Act to Protect Psychotherapy Patients be enacted, psychoanalysts can still provide psychoanalysis. However, the small minority of psychoanalysts who do not have

comprehensive training in one of the recognized mental health professions, often referred to as “lay

analysts” would not be able to also call themselves psychotherapists or what they do psychotherapy.


Any practitioners who seek licensure have the right to do so, by filing legislation. They can make

their case for licensure just as psychologists, social workers, nurses, psychiatrists and licensed mental health counselors have done. By embedding their licensure in a larger consumer protection bill, the question of credentials and qualifications gets lost in the context of the compelling consumer protection issue. HB 236 would put vulnerable consumers at risk by licensing providers who do not have training, supervision, and experience that many consider critical for ethical practice of psychotherapy. We believe that the issues of protecting consumers by restricting the use of the terms “psychotherapy” and “psychotherapist” should be considered separately and not comingled as they are in this bill.


Further, the Division of Professional Licensure within the Office of Consumer Affairs and Business

Regulation has opposed legislation in the past that would separately license psychoanalysts.


This bill does not represent consumer protection as its name suggests. Rather this bill represents the special interests of a small number of individuals and we urge you to oppose it.



Michael A. Goldberg, Ph.D.

Director of Professional Affairs

169 Libbey Parkway, Second Floor

Weymouth, MA 02189



Frances Bigda-Peyton says...
Posted Tuesday, July 22, 2014
Frances Bigda-Peyton, Ed.D. adds... I have reviewed the previous discussion and have come down on the side of supporting H236. Though I am sure Dr Goldberg is well intentioned, some of his facts are incorrect: it is not a backdoor bill and psychoanalytic practitioners are very well trained. In fact, I have been a psychologist for over 30 years and have found psychologists who have completed analytic training to be better prepared than most at understanding themselves and working therapeutically. As indicated in Dr. Movahedi's letter, H236 ensures that psychoanalytic practice will not be restricted. I think it is important to offer patients a variety of treatment options. We protect consumers the most when we focus on what works best for various presenting problems. We need to be in this together-being inclusive rather than exclusive.
Siamak Movahedi Ph.D. says...
Posted Sunday, July 20, 2014
I am writing to correct the gross distortions presented to you in emails opposing H236. H236 is a consumer protection bill, quite comparable to H3466; it restricts the practice of psychotherapy to licensed mental health professionals. The inclusion in H236 of licensure language for the last remaining group of highly qualified mental health practitioners in MA, currently unlicensed, independent psychoanalysts and psychoanalytic psychotherapists, was necessitated by the restriction on practice that would result from passage of the consumer protection portion of the bill alone. The requirements for the training and licensure of independent psychoanalysts and psychoanalytic psychotherapists are comparable to or surpass those of the other currently licensed professions. The Board of Allied Mental Health and Human Services Professionals will have oversight of those licensed by the bill. I encourage you to read the bill before you make any judgment. Siamak Movahedi, Ph.D. NCPsyA

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