Texas State Board of Examiners of Psychologists

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Exemption for Post-doctoral Supervised Experience Under Board Rule 461.10(c)

Generally speaking, a person may not engage in the practice of psychology, which includes practicing under the supervision of a licensed psychologist while acquiring post-doctoral experience, unless the person is licensed or has been issued trainee status by the Board.  See Section 501.251 of the Psychologists’ Licensing Act and Board rule 461.10(a).   However, the activities or service of a post-doctoral fellow or resident are exempt, i.e. do not require a license or trainee status, if certain exemption criteria are met.  See Section 501.004 of the Psychologists’ Licensing Act and Board rule 461.10(c) for a list of these criteria.

Individuals who contend their post-doctoral supervised experience meets the exemption criteria of Board rule 461.10(c) must be able to demonstrate the exempt nature of their activities or services.  The failure or inability to do so may render any post-doctoral supervised experience acquired in Texas on or after September 1, 2016 without a license or trainee status, ineligible for consideration when the individual applies for licensure as a psychologist.  Furthermore, individuals who cannot demonstrate the exempt nature of their activities or services must immediately stop practicing psychology, regardless of whether they are or have been under the supervision of a licensed psychologist.

In order to demonstrate the exempt nature of his or her activities or services in a post-doctoral setting, an individual must be able to show each of the following criteria:

  1. Enrollment or participation in a formal post-doctoral program that is either APA accredited or an APPIC member program, or a post-doctoral program that is substantially similar to one of these programs;
  2. The activities or services were delivered in connection with the formal post-doctoral program;
  3. The activities or services took place under the superivsion of a licensed psychologists; and
  4. The individual was designated as a post-doctoral  fellow or resident, or by another title that clearly indicates the person's training status.

When trying to determine whether an unaccredited  or non-member post-doctoral program is substantially similar to an APA accredited or APPIC member program, the Board has determined each of the following criteria must be met before the program will be considered substantially similar.

  • An organized experience with a planned and programmed sequence of supervised training experiences.
  • A designated psychologist responsible for the program who possesses expertise or competence in the program’s area.
  • Two or more licensed psychologists on staff, at least one designated as supervisor with expertise in area of practice.
  • A minimum of 2 hours per week of face-to-face supervision.
  • A minimum 2 additional hours per week of learning activities.
  • A minimum 25% of the fellow’s time is spent providing professional psychological services.
  • Admission requirements that require the applicant to complete all professional degree requirements and a pre-doc internship, which at a minimum meets Board requirements.
  • A requirement that participants use titles such as intern, resident, fellow, or trainee.
  • Documentation describing the goals, content, organization, entrance requirements, staff, mechanisms for evaluations (minimum 2 per year), and a statement that the program meets Texas’ licensure requirements.
  • At a minimum, an informal due process procedure regarding deficiencies and grievances.
  • A written requirement for at least 1500 hours to be completed in not less than 9 months and not more than 24 months.

Formal Post-doctoral Programs Substantially Similar to APA Accredited and APPIC Member Programs

The Board has determined, based upon applications previously submitted, that the following post-doctoral programs meet the substantial similarity requirement set out in Board rule 461.10(c)(1)(B).

  1. Behavrioal Health Consultants, 11211 Taylor Draper Ln., Ste. 202, Austin, TX 78759
  2. Dallas Therapy Alliance, 12801 N. Central Expwy., Ste. 1730, Dallas, TX 75243
  3. Houston OCD Program, 708 E. 19th St., Houston, TX 77008
  4. Institute for Clinical Neurosciences - Irving, 4425 W. Airport Fwy., Ste. 590, Irving, TX  75062

Individuals relying upon supervised experience obtained from one of these programs do not have to submit documentation evidencing the program’s substantial equivalency.

Please note that the Board does not pre-evaluate or pre-approve post-doctoral programs for substantial equivalency under Board rule 461.10(c).  It is incumbent upon post-doctoral fellows and residents to ensure that any unaccredited or non-APPIC member program is substantially equivalent to a program listed in 461.10(c)(1)(A) before delivering services within that program without a license or trainee status.