Kansas psychology advisory committee begins rewrite of postdoctoral experience rules, tables final decision to June

The Licensed Psychology Advisory Committee of the Kansas Behavioral Sciences Regulatory Board spent its May meeting reviewing draft regulatory language that would change the experience requirement for psychologist licensure to two years, or 3,600 hours, and debated whether some predoctoral practicum hours should count toward that total.

The committee did not adopt a final rule. Members directed staff to prepare options and to continue the discussion at the committee’s next meeting on June 10, 2025.

The discussion matters because the change would alter how early-career psychologists document supervised experience before full licensure. Leslie Allen, a staff member for the Behavioral Sciences Regulatory Board, presented draft language that would require 1 year and 1,800 hours to be an internship meeting the stated standards, while the remaining 1 year and 1,800 hours could be predoctoral, postdoctoral, or a combination.

“We did not want to list a bunch of requirements because I don’t know that much about practicum in doctoral programs,” Allen said as she reviewed the draft. She asked the committee whether the regulations should specify supervision ratios, minimum direct-client-contact percentages, or limit what years of a graduate program could be counted.

Committee members raised several concerns about treating practicum and internship hours as interchangeable. Jessica Hamilton, an advisory committee member, said practicum experiences typically differ substantially from internships in structure and oversight. “Practicum experiences are a very different nature of training than what somebody has received or who had completed a postdoctoral fellowship,” Hamilton said.

Members debated several technical points that would affect implementation if the regulation changed: whether programs must document a minimum percentage of direct client contact (one state example cited required 25 percent), whether supervision should follow internship-style ratios (for example, documented supervision hours per trainee), which predoctoral years should count toward licensure, and whether a master’s degree should be required before predoctoral hours begin to accrue. Several participants said documentation standards will be critical: without consistent documentation of supervision and direct-contact time, many predoctoral hours could be ineligible.

David Fye, executive director for the Behavioral Sciences Regulatory Board, summarized the practical effect of any adopted change: detailed, consistent documentation would be needed to accept predoctoral hours and that the board staff could model options after other states or ASPPB resources.

The committee agreed staff would prepare a spreadsheet of options and comparative language from other jurisdictions for review before the June meeting. Allen said she would circulate the American Psychology–related model regulations and resources she had gathered to the committee.

Because the committee did not take final action, no statutory or regulatory change was adopted at this meeting. Chair (name not specified) moved to table further deliberation until the June 10 meeting; the committee agreed to resume the item then.

The committee also asked staff to return with specific wording options that would define: what types of predoctoral practicum (if any) could be counted; required minimums for direct client contact and supervision ratios; and whether a master’s degree or other milestone should gate when hours may begin to accrue.

A rewritten rule would be a regulation; staff and committee members noted that whether a statutory change would be required depends on the final scope of language the committee recommends to the full board.