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Advisory committee reviews PSYPACT rule revisions; members urge clarity on "in-person" education and appeals language
Summary
The committee reviewed proposed PSYPACT (APIT/TAP) rule changes posted for comment through Oct. 3, 2025, including a proposed 'one academic year' in-person instruction requirement and new grounds for denial/revocation and appeals; members suggested splitting votes, clarifying 'any other adverse action,' and defining hybrid programs.
The advisory committee reviewed proposed revisions to rules governing PSYPACT authorizations to practice interjurisdictional telepsychology (APIT) and temporary in-person practice (TAP), which are out for public comment through Oct. 3, 2025.
Staff described proposed language that would require applicants to have "successfully completed a graduate course of study with a minimum of 1 academic year of in-person, face-to-face instruction at the educational institution," and noted corresponding revisions to TAP. The proposed packages also add detailed grounds for application denial and revocation (fraud or deception in application, misrepresentation of status, practicing with expired authorization, notification of adverse or disciplinary action, failure to provide requested information, and failure to comply with SIPAC commission rules) and replace a short appeals pointer with a 30-day written appeals process and an appeals committee decision that would be final.
Committee members supported aligning Kansas rules with PSYPACT where reasonable but raised several concerns. Members asked whether the education wording would inadvertently exclude accredited hybrid programs, how the rule defines an educational institution and "in-person" instruction, and whether the committee should ask the board to split the rule package so the textual/appeals/discipline items could be voted on separately from the educational-definition changes. Members also pointed out vague language such as "any other adverse action" and asked for explicit limits (e.g., actions by licensing boards rather than unspecified entities).
Chair Richard Nobles said he will raise these questions with commissioners at the PSYPACT annual meeting in November and the advisory committee may craft a recommendation to the board about whether to align with PSYPACT's changes or to seek clarifying edits. The committee invited public comment through the Oct. 3 deadline and encouraged new members to submit individual comments if they wish.
