Committee directs staff to draft Phase 1 changes to licensure pathway, including 7‑year exam and experience windows

The Board of Behavioral Sciences Workforce Development Committee on April 4 directed staff to draft and advance Phase 1 of a multi‑phase plan to restructure the pathway to licensure for licensed marriage and family therapists (LMFT), licensed clinical social workers (LCSW), licensed professional clinical counselors (LPCC) and licensed educational psychologists (LEP). The committee voted unanimously to send the completed Phase 1 proposal to the board’s Policy and Advocacy Committee for consideration.

The Phase 1 package staff presented would change several timing and documentary requirements the board says have created barriers for applicants while preserving public protection. "We talked about how the licensing and exams, it's a very complex process," Roseanne Helms, legislative manager for the board, said during the committee discussion.

Under the Phase 1 items discussed and approved for drafting, staff would:

- Allow associates to choose when to take the California law and ethics exam after registration is granted rather than requiring an annual attempt for renewal.

- Impose a seven‑year age limit on California law and ethics exam scores, aligning it with the existing seven‑year limit on clinical exam scores. Under the proposal, to obtain subsequent registration or to obtain initial licensure an applicant’s law and ethics score must be no more than seven years old at the time the board receives the application.

- Extend the allowable length of a registration number and the validity window for supervised experience hours from six to seven years to align with the exam score limits and to give applicants an additional year to complete requirements.

- Create a limited private‑practice exception for associates who hold a subsequent registration number: a one‑time, two‑year hardship extension permitting completion of supervised hours in a private practice if the associate, supervisor or employer submit specified information and the board finds "good cause." Legal counsel recommended tightening the definition of good cause to include, but not be limited to, extended medical leave, family caregiving responsibilities, difficulties finding employment and other circumstances beyond the applicant’s control.

- Make technical cleanups: remove obsolete fees, clarify how out‑of‑state clinical exam scores are treated when taken earlier than California eligibility would allow, and delete a now‑redundant requirement that an applicant retake the law and ethics exam in certain circumstances because the seven‑year score limit would already ensure both exam scores are current.

Christie Shields, legal counsel, said the packet’s draft language needed specific wording changes for clarity. "A passing score doesn't have a date," Shields said, recommending revisions so the text states the law and ethics exam "shall be passed no more than seven years" prior to the board's receipt of the application and that the private‑practice hardship section define "good cause" with illustrative examples.

Committee members pressed staff on sequencing and timing. Board member Justin Haupt (LMFT) asked why the committee is treating the AMFTRB national exam transition (Phase 2) and the structural timing change (Phase 3) separately; Roseanne Helms and Executive Officer Steve Sodergren said the changes involve different stakeholders and potential unintended consequences if implemented simultaneously. "There's a lot of nuances in the changing the timing of the clinical exam that it's going to take some more time," Helms said.

The committee approved a motion directing staff to incorporate the discussed language clarifications, draft corresponding amendments for the LCSW and LPCC practice acts, change the allowable age of LEP experience hours from six to seven years, and bring the completed Phase 1 package to the Policy and Advocacy Committee. Annette Walker moved the motion; Justin Haupt seconded. Christina (staff) recorded the unanimous vote in favor.

The next steps are drafting the statutory and regulatory language consistent with legal counsel’s suggestions, circulating parallel language for LCSW and LPCC practice acts, and forwarding the finished package to Policy and Advocacy. If Policy and Advocacy approves it, the proposal would return to the full board for consideration and, if necessary, for the legislative or regulatory processes required for implementation.

Votes at a glance: The committee approved the motion to direct staff to draft and advance Phase 1 changes; the vote was recorded as unanimous and the motion carries. The consent calendar (approval of the January 30, 2025 minutes) was also approved earlier in the meeting without public comment.