EPPP Huge News
Members, the ASPPB board voted to add a Part 2 of the national EPPP exam. Importantly, the ASPPB board voted without consulting the various territories about feasibility and regional needs. The two-part exam was to be mandated by January 2026 and elicited several concerns regarding feasibility, the lack of validity, and new barriers to entering the field. Texas Behavioral Executive Council has been on the forefront of asking ASPPB important questions, expressing concerns about legal issues within Texas, and advocating for psychologists in our state. ASPPB presented limited data to support the validity of the new exam and need within the field, while lacking support for how to implement the new exam that would incur significant time and financial investment. With significant momentum from states and other organizations, ASPPB announced on October 23, 2024 that they are postponing the January 2026 mandate. While this announcement is hopeful and relieving, Texas continues to fight to force ASPPB to allow an opt-out approach. Texas and Tennessee boards met for a Preserving Jurisdictional Autonomy town hall on October 25, 2024. Additionally, Texas is pushing for an ASPPB community vote for an amendment that allows for territories to opt-in or opt-out. In other words, Texas is proposing to keep the rules the same as the past year, where territories could implement changes at their choosing. This vote will occur during the ASPPB annual meeting in Dallas from October 30, 2024 to November 2, 2024. We are attaching additional resources for you to read on your own time and encourage you to share information with colleagues in other states. Meanwhile, BCPA will continue to share updates through our website and upcoming events.
Additional background links for the website: https://d15k2d11r6t6rl.cloudfront.net/pub/bfra/eupuax14/fh2/w0e/7hi/EPPP2TSBEP%20Update%202024.pdf
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TSBEP/BHEC Update and EPPP Part 2
April 2024
BHEC Update
The Texas Behavioral Health Executive Council (BHEC) has been in effect for over 5 years and has accomplished or surpassed all initial goals. Application times have significantly improved for all license types and time to resolve complaints has also dramatically decreased. In general, the newly organized system for mental health care providers in Texas has been largely successful. Some changes that you will see for psychologists: TSBEP will only meet three times a year instead of four and it takes longer to make rule changes as proposed rules are sent to BHEC for their approval/denial – but this also means that stakeholders have more opportunity to register comments during the rulemaking process.
RECENT TSBEP EVENTS
The current issue on the slate at TSBEP is what to do about the written examination requirement for licensure for psychologists and Licensed Psychological Associates (LPAs). As this is a statutory requirement, TSBEP is unable to change it – they only have authority in rulemaking. The examination requirement has been met for years with the EPPP (Examination for the Professional Practice of Psychology). The EPPP is primarily a knowledge-based test and not a clinical competency measure. Prior to 2019, the clinical competency measure for licensure was an oral exam. Due to the costs, difficulty of implementation, and questionable discrimination, the Texas State Legislature removed the oral exam requirement during Sunset Review. At this time, a large number of psychologists testified against the removal of a competency measure, but the difficulty in administering these exams outweighed the reported benefits.
The developer of the EPPP is the Association of State and Provincial Psychology Boards (ASPPB) and around the time of our Sunset Review (2016), they had begun developing a competency-based test for states to use as a measure of clinical readiness for licensure. It would be called the EPPP2 – a clinical addition to the EPPP already in use across the country and other provinces (and now called EPPP1). While this seemed to be a good answer to providing an alternative clinical competency measure, several issues and concerns have been noted which is stopping TSBEP from adopting this measure.
ASPPB is requiring states to adopt both the EPPP1 and EPPP2 by January 2026 – an all or none mandate. Texas will no longer have access to utilizing the EPPP1 if they do not adopt both tests.
Adding another test will increase the costs of licensure, and states have not been provided data demonstrating that an additional test is necessary to discriminate readiness for practice in order to protect the public. Since there has not been a second measure for over 5 years, it is difficult for TSBEP to justify the need for adding another test (which BHEC will construe as an anti-trust concern and reject the proposal should it be sent to them).
Initial data indicated discrimination against minority applicants; pass rates were significantly different. ASPPB reported that they removed multiple items to adequately address this issue, but will not provide any states the specific data.
Pass rates dramatically increase on the EPPP2 with practice exams, but these are only available to those who can afford it and this adds another unfair barrier to those seeking licensure.
Current State of EPPP2 in Texas
Most TSBEP members are strongly in favor of maintaining an examination component for licensure. They held a special meeting on March 6, 2024 to allow stakeholders to ask questions and make public comments about their concerns regarding the EPPP2. There was a clear consensus of the Board members that they want to maintain standards for licensure, but do NOT want to create additional barriers to licensure, especially for minority applicants. Several individuals commenting during the special meeting noted that minority applicants were having difficulty passing the EPPP to get licensed, and there are currently no other alternatives for licensing if this is not achieved.
ASPPB’s argument is that psychology is one of the only professional groups who do not have a clinical competency exam for licensure. Setting up national standards consistent across states could allow for more mobility of our licensure. In addition, they report that some training directors want this added measure to ensure determination for readiness for practice. ASPPB also reports that the additional test will not cause delay in licensing as the tests can be taken at different times during training – the EPPP1 after coursework is complete and the EPPP2 during the clinical training (the post-doctoral year or end of internship). It was noted during the special TSBEP meeting that while this seemed logical, the practicality of implementing this testing during training was questionable. In some states, however, passing the EPPP is part of the graduate program already, and some programs have students pass the test to obtain their LPA license on their way to obtaining their doctorate. ASPPB states: “The methodology undertaken to develop the exam is sound, it involved over one hundred licensed psychologists in direct development, and it reflects the minimum level of skills that should be demonstrated to safely
practice.”
Licensing boards across the country are asking for more data regarding the EPPP2 validity in order to justify the additional cost. In Texas, we need the data to show that it serves the valuable purpose of ensuring competency and providing protection to the public. This is the ONLY way the Texas legislature will even consider approving adoption of another “barrier” to licensure. At this point in time, TPA and TSBEP agree that the best option is to push ASPPB to delay the adoption date until more data is available. Only two states and two provinces have chosen to adopt both parts at this time. One state that adopted early has since withdrawn adoption, likely for the reasons stated above.
NEXT STEPS
TPA is staying closely involved with TSBEP and Dr. Brian Stagner, TPA Director of Professional Affairs, is working with other DPAs across the country to get more information, find alternative pathways and options, or information supporting the appropriate adoption of the EPPP1 and EPPP2. No perfect exam exists and comments were made by our own TPA Board member regarding the negative effects of the EPPP for some applicants. Dr. Stagner has noted that several DPAs across the country believe that their legislatures and regulators are especially loathe to implement anything that (1) expands regulatory activity, (2) increases barriers to practice, and/or (3) impedes access to mental health services. TPA is invested in maintaining training standards but also sensitive to bias and impact on minority provider groups who are clearly needed across the nation.
Carol A. Grothues, Ph.D.
Chair, TPA TSBEP/BHEC Monitoring Committee
2024 TSBEP/BHEC Monitoring Committee Members:
Dr. Matthew Baysden
Dr. Francis Douglas
Dr. Michael Flynn
Dr. George Grimes Dr. Suzanne Hart Dr. David Hill
Dr. Brian Stagner Dr. Corinne Zupanik