Article archive / July 1, 2013
Originally published: . Volume 4, No. 11. Source pages: 2, 3.
LPA Responds to Dr. Comaty Letter To The Editor From LPA Executive Council
Editor’s Note: In last month’s issue (June, Vol 4, No 10) the Times published a Letter to the Editor from Joseph Comaty, PhD, MP. He gave some views regarding the Louisiana Psychological Association’s (LPA) handling of the Behavior Analyst bill. The Times recently received a Letter to the Editor from members of the Executive Council of LPA, signed by Bryan Gros, PhD and Alicia Pellegrin, PhD, responding to views expressed in Dr. Comaty’s June Letter to the Editor.
A Letter To The Editor in the previous issue of The Psychology Times criticized LPA's handling of negotiations regarding SB 134, which, if signed by the governor, will create a practice act and separate board for BA (behavior analyst) practitioners. The author of that letter was not involved in the many discussions within LPA and its members, the LPA Executive Council, LPA’s discussions with the LSBEP, or with the communications between LPA and Senator Morrell, the author of SB 134. These discussions were quite extensive and rapidly changing. As the letter contained some inaccuracies, LPA would like to correct these in order to “set the record straight.”
Firstly, we would encourage colleagues who are not LPA members, including the author of that letter, to join LPA and increase the representation of all of psychology and to “have a voice” with LPA.
In 2012, the psychology board (LSBEP) presented LPA with a draft bill to place the regulation of behavior analysts as an advisory committee under LSBEP. We offered initial support. This draft was presented to the BAs and Senator Morrell, but was soundly rejected and the message was clear that the BAs and Senator Morrell would not support such an arrangement.
Subsequently, a BA study commission was formed to determine recommendations regarding BA regulation. This group included a representative from LPA who is a psychologist and a Board Certified Behavior Analyst (BCBA). The author of the letter to The Psychology Times was not a member of, or directly involved in this group. Politics were involved. LSBEP also had representatives on this commission and contrary to the letter to the editor, LPA was in frequent communication with LSBEP prior to and during deliberations and following the commission's recommendation(s).
It was clear during discussions that a final vote would not support BAs being regulated by LSBEP as an advisory committee. It was less clear if participants were willing to vote in favor of a merged board with psychology. With limited voting options and unknowns, LPA voted for a merged board for BAs with LSBEP. The final outcome was an overwhelming recommendation for the BAs to merge with the LPC board.
However, the BAs and the LPC board were unable to come to a mutually agreeable arrangement and this plan was abandoned. LPA was then informed that LSBEP had offered its own merger to the BAs with two full seats for BAs on the psychology board, as opposed to being an advisory committee. In the draft legislation, there were no provisions addressing voting restrictions for BAs, which was of serious concern to the LPA EC. LPA consulted with LSBEP, our lobbyist, and others. We communicated frequently with LSBEP. LPA made LSBEP aware of our concerns about BAs possibly being able to vote on psychology issues. LSBEP acknowledged these were valid concerns and stated that they hoped to restrict voting privileges through rule making. However, there was no guarantee that BAs, as full board members, would be completely prohibited from voting on psychology issues.
In addition to communications with LSBEP, there were on- going discussions among LPA EC members, our lobbyist, and much feedback from LPA members. The EC eventually decided that the potential risks outweighed the potential benefits and stated that LPA would not support a merger where our board would be diluted with non-psychologists and where BAs had two seats on LSBEP with no restrictions on voting by statute.
We also want to clear up concerns that may have been raised about dual licensure. This is a non-issue. “Behavior analysis” remains in the psychology practice act. Additionally, LPA successfully (and without objection) obtained an exemption in SB 134 for psychologists to continue to practice “behavior analysis”, and to state that they do in those terms. This is stated explicitly in SB 134: "An individual licensed to practice psychology within the state, so long as the applied behavior analysis services provided by the licensed psychologist are within the licensed psychologist's education, training and expertise. This includes individuals acting under the extended authority and direction of licensed psychologists." Dual licensure is not required for psychologists to practice “behavior analysis” or say that they practice as such; the BA board will have no regulatory authority over a psychologist’s practice of behavior analysis in such circumstances.
Furthermore, a BA license is not required to be a Board Certified Behavior Analyst; nothing will change in the regulation of the practice of psychologists who have that certification. Of course, psychologists “can” obtain dual licensure, just as they can with other professions in the field of behavioral health (i.e., a licensed psychologist can also be a licensed LPC; a medical psychologist licensed by the medical board can also choose to be licensed by LSBEP), but this is not a requirement.
LPA does not believe we have “given away part of psychology" as the previous author asserted. The political reality is that the BAs were going to obtain licensure and be regulated. Senator Morrell was adamant on that point and legislative leaders made it very clear to our lobbyist that with Senator Morrell's backing, the bill would pass. It was made known to LPA that all other parties, including LSBEP, were supportive of the eventual independent practice and regulation of BAs. It was made clear that the BAs would not be under the supervision of the LSBEP unless they had two full members on the board. This was a political fact and the only option was to work for the best outcome attainable. Contrary to the previous letter, we were not “pleased”. In fact, LPA did not like the political process and wished that matters were different, but this was the reality with which we were faced.
We want to be clear on another issue that was raised, funding for the BAs. In a face-to-face meeting during an LPA Executive Council meeting representatives from LSBEP indicated that BAs would be responsible for all costs, including start-up monies.
LPA represents its members and psychology in Louisiana. We hope that all current LPA members will continue their membership and, again, encourage non-member colleagues to join us to increase the representation of all of psychology within our organization.
On behalf of the LPA Executive Council, Alicia Pellegrin, Ph.D. Legislative Chair Bryan J. Gros, Ph.D. President
A previous meeting of the Executive Council of the Louisiana Psychological Association. The Council recently responded with a Letter to the Editor regarding it’s actions during the legislative session. Front to back: Drs. Paula Zeanah, Kim Van Geffen, Alicia Pellegrin, and Carolyn Weyand.
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