Mental Health Practitioners

Frequently Asked Questions About Applying for Licensure as a Mental Health Practitioner in New York State

These Questions and Answers are offered as a matter of general guidelines and do not carry the force of law. You should also review the actual statute and regulations. Application forms and instructions are available on this site; please see the links on the left. NOTE: The Department cannot determine whether or not applicants have the necessary qualifications for licensure over the phone or through e-mail. We will carefully review your qualifications only after we receive your application, fee, and all necessary documentation directly from the education program or supervisor.

1. Can I be licensed as a mental health practitioner or psychotherapist?
2. How do I apply for licensure as a Licensed Marriage and Family Therapist?
3. How do I apply for licensure as a Licensed Creative Arts Therapist?
4. How do I apply for licensure as a Licensed Psychoanalyst?
5. How do I complete the course in the identification and reporting of suspected child abuse?
6. What are the requirements for completing supervised experience as a requirement for licensure?
7. What is a limited permit and do I need to apply for one?
8. If I am licensed in another state, how do I become licensed in New York State?
9. Do I need to be licensed if I have a credential from a national organization or society?
10. Once I am licensed when does my license expire and what do I have to do to renew it?

11. What are the differences between the four professions created under the State Board for Mental Health Practitioners?
12. There is no psychotherapy license so which license should I have to practice "psychotherapy"?
13. Are there individuals who do not require a license to practice mental health counseling, marriage and family therapy, creative arts therapy or psychoanalysis?
14. How do I verify my experience if I cannot find my former supervisor or the supervisor is deceased?
15. In some professions, the application requires the completion of "semester hours" while other sections require the completion of "clock hours" and even others require the completion of "client contact hours". Is there a difference or are these all the same?
16. I did not graduate from a program that is registered as leading to licensure in a mental health profession in New York State so how can I prove that I have completed the education required for licensure?
17. If I was supervised by an individual with a credential that is not listed in the application packet, would the supervisor be qualified?
18. I completed--or I am in the process of completing--a training program in psychotherapy in an institute chartered by the Board of Regents. Does that mean that I meet the qualifications for licensure? If not, can I continue to practice until there is a license for which I might qualify?
19. I already received a master's degree in an appropriate field but it was not a license-qualifying program and did not include some of the course content required under the Education Law and Regulations. If I complete additional graduate coursework, does any of my prior experience count toward the requirement for licensure?

1. Can I be licensed as a mental health practitioner or psychotherapist?
   

   No. "Mental health practitioners" and "psychotherapists" are not among the licensed professions established in New York State Education law. The State Education Department does oversee the licensure and regulation of practice of Mental Health Counselors, Marriage and Family Therapists, Creative Arts Therapists and Psychoanalysts. Only individuals licensed in one of these four professions and other professions (medicine, nursing, psychology and social work) or individuals exempt under the law can practice psychotherapy. For information on the requirements for licensure in each of the new professions, please read the appropriate section of this Q&A.

2. How do I apply for licensure as a Licensed Marriage and Family Therapist?
   

   To apply for licensure, you must:

   • file the application for the Licensed Marriage and Family Therapist (Form 1),
   • pay the application and registration fee ($345),
   • have the college or university from which you completed your graduate program verify that you received a master's or doctoral degree in marriage and family therapy or a related degree that includes course content required in the law and regulations (Form 2 and transcript),
   • have your employer or supervisor document that you completed 1,500 client contact hours of supervised experience in marriage and family therapy, acceptable to the Department, through either:
     • 1,500 hours, which may include the practicum, if you graduated from a MFT program (Form 4 and 4B) or,
     • 1,500 hours of post-degree experience if you graduated with a degree in a related field (Form 4 and 4B),
   • complete the two-hour Department-approved course in child abuse identification and reporting or the exemption (Form 1CE), and
   • pass the licensing examination from the Association of Marriage and Family Therapy Regulatory Boards (AMFTRB).
   
   
3. How do I apply for licensure as a Licensed Creative Arts Therapist?
   

   To apply for licensure, you must:

   • file the application for the Licensed Creative Arts Therapist (Form 1),
   • pay the application and registration fee ($345),
   • have the college or university from which you completed your graduate program verify that you received a master's degree in creative arts therapy or a related degree that includes course content required in the law and regulations (Form 2 and transcript),
   • have your employer or supervisor document that you completed 1,500 hours of post-degree supervised experience in creative arts therapy acceptable to the Department (Form 4 and 4B),
   • complete the two-hour Department-approved course in child abuse identification and reporting or the exemption (Form 1CE), and
   • pass an acceptable examination (Certification Board for Music Therapy or Art Therapy Credential Board) or two case narratives acceptable to the Department for licensure.
   
   
4. How do I apply for licensure as a Licensed Psychoanalyst?
   

   To apply for licensure, you must:

   • file the application for the Licensed Psychoanalyst (Form 1),
   • pay the application and registration fee ($345),
   • have the college or university from which you completed your graduate program verify that you received a master's degree in any field from a college or university registered by the Education Department, or the equivalent (Form 2 and transcript);
   • have the psychoanalytic training program from which you completed your psychoanalytic training verify that you completed a curriculum that includes course content required in law and regulations (Form 2 and transcript);
   • have your supervisor or employer document that you completed 1,500 hours of supervised experience in psychoanalysis acceptable to the Department (Form 4 and 4B),
   • complete the two-hour Department-approved course in child abuse identification and reporting or the exemption (Form 1CE), and
   • meet the examination requirement by submitting two case narratives to the State Board for Mental Health Practitioners that describe the assessment and treatment of psychoanalytic patients.
   
   
5. How do I complete the course in the identification and reporting of suspected child abuse?
   

   You must complete the two-hour Department approved course in the identification and reporting of suspected child abuse, or request an exemption, to receive a license or limited permit. The two-hour course is available from providers throughout New York State. Distance learning options are also available. A list of approved providers and additional information is on OP's website. It is your responsibility to submit documentation that you have completed the course or your exemption to the Department with your application materials. An exemption form is also available on the web.

6. What are the requirements for completing supervised experience as a requirement for licensure?
   

   Licensure in each of the professions requires the completion of a supervised experience, acceptable to the Department. The specific requirements for the number of hours and any special requirements are found in the Education Law and Commissioner's Regulations, in the application packet for each profession, and on this site.

   Experience setting. You may complete the required experience in any setting where the mental health therapy professions can be practiced legally, including health care facilities, community-based agencies or clinics, or a practice owned and operated by an individual authorized to practice the profession. Only an individual who is licensed or exempt can own a private practice providing mental health services, therefore if you are not licensed and are completing the required experience under a limited permit you may not own or operate your own private practice.

   Supervisor qualifications. The supervisor for the experience must be licensed and have at least three years of post-licensure experience in the practice of the same profession as the applicant, or the equivalent as determined by the Department. A license has not been required to practice these professions until recently, so until January 1, 2008, the Department will accept certification by a national organization in lieu of state licensure. However, the supervisor must still meet the requirements for education and experience in the appropriate profession.

   Purpose of supervision. Supervision in the mental health professions does not require that your supervisor be on-site when you are providing services. The purpose of supervision is to help you improve your skills as a mental health professional and the supervisor plays an important role in helping you meet this requirement. You should provide Appendix A in the application packet to a prospective supervisor to ensure that the supervisor understands his or her role in your attempts to become licensed. Appendix A provides specific information about the supervisor's qualifications, the frequency and duration of supervision, and the goals that should be met through supervision by a qualified, licensed practitioner.

7. What is a limited permit and do I need to apply for one?
   

   The Education Law authorizes the Department to issue a limited permit (sometimes called a "temporary license") to an individual who has met the requirements for education, age, moral character, and has completed the child abuse identification course or is exempt from training. The permit provides an opportunity for the holder to complete the experience requirement for licensure and/or pass the licensing examination while enabling the permit holder to practice under supervision. A permit holder must be under the supervision of a qualified supervisor who is responsible for his or her practice in a setting acceptable to the Department. A limited permit for creative arts therapists, marriage and family therapists, and psychoanalysts is valid for one year. The limited permit for mental health counselors is valid for two years. All limited permits may be renewed by the Department for one additional year to allow the permit holder to complete the experience or pass the examination.

8. If I am licensed in another state how do I become licensed in New York State?
   

   New York State does not license an individual solely on the basis of licensure in another jurisdiction. You must file an application in New York and meet all requirements for licensure in effect at the time of application (education, experience, examination, child abuse reporting and moral character). Your former supervisors must attest that you practiced the profession for the specified period of time, that the supervisor was qualified under New York State Law, and that the supervision was of the frequency and duration required in New York State. If your education, supervised experience or examination score do not meet the requirements in New York, you will be required to complete the appropriate requirement before you can receive a license.

   You must also have each jurisdiction in which you are currently or you were ever licensed verify your licensure status directly to the Education Department, using Form 3 in the application packet. If you previously passed the licensing examination for licensure in another jurisdiction, you must have the examination vendor send your scores to the Education Department to receive credit. If you had passed the examination in another jurisdiction under non-standard conditions, such as the use of a translating dictionary, you should contact the Department to determine if your scores are acceptable for licensure in New York State.

9. Do I need to be licensed if I have a credential from a national organization or society?
   

   Yes, you must be licensed to practice in New York State. A national credential or certification (e.g., National Certified Counselor, Registered Dance Therapist, or Clinical Marriage & Family Therapy Supervisor, etc.) is not a substitute for licensure. To practice in New York State, you must file an application and fee and meet all requirements for licensure (education, examination, experience, child abuse reporting, and moral character) and be licensed and registered with the Education Department. You may not substitute the credential or certification for direct verification of the supervised experience required for licensure in New York State.

10. Once I am licensed, when does my license expire and what do I have to do to renew it?
    

    A license is valid for life, unless it is revoked, annulled or suspended by the Board of Regents. To practice your profession in New York State, you must be both licensed and currently registered. Your registration period is three years and begins on the date you are licensed. You will receive a renewal notice about 4 months before your initial registration expires. The second registration period will be for slightly more or less than three years, and the fee adjusted accordingly, so that it will expire in the month before your birthday. It is your responsibility to maintain your registration to practice in New York State.

    Your notice to re-register and any other communications from the Department are sent to your address of record. If you move, you are responsible for notifying the Department within 30 days of your new address.

11. What are the differences between the four professions created under the State Board for Mental Health Practitioners?
    
    
    1. Each profession has specific requirements for education, supervised experience, and examination that must be met by an applicant.
       
       
    2. The definition of practice in each profession is defined in the Education Law and, although there are overlaps, there are differences among the four professions. The definitions of practice are found in Article 163 and below:
       
       §8402. Mental health counseling.
       1. Definition of the practice of mental health counseling. The practice of the profession of mental health counseling is defined as:
       (a) the evaluation, assessment, amelioration, treatment, modification, or adjustment to a disability, problem, or disorder of behavior, character, development, emotion, personality or relationships by the use of verbal or behavioral methods with individuals, couples, families or groups in private practice, group, or organized settings; and
       (b) the use of assessment instruments and mental health counseling and psychotherapy to identify, evaluate and treat dysfunctions and disorders for purposes of providing appropriate mental health counseling services.
       
       §8403. Marriage and family therapy.
       1. Definition of the practice of marriage and family therapy. The practice of the profession of marriage and family therapy is defined as:
       (a) the assessment and treatment of nervous and mental disorders, whether affective, cognitive or behavioral, which results in dysfunctional interpersonal family relationships including, but not limited to familial relationships, marital/couple relationships, parent-child relationships, pre-marital and other personal relationships;
       (b) the use of mental health counseling, psychotherapy and therapeutic techniques to evaluate and treat marital, relational, and family systems, and individuals in relationship to these systems;
       (c) the use of mental health counseling and psychotherapeutic techniques to treat mental, emotional and behavioral disorders and ailments within the context of marital, relational and family systems to prevent and ameliorate dysfunction; and
       (d) the use of assessment instruments and mental health counseling and psychotherapy to identify and evaluate dysfunctions and disorders for purposes of providing appropriate marriage and family therapy services.
       
       §8404. Creative arts therapy.
       1. Definition of the practice of creative arts therapy. The practice of the profession of creative arts therapy is defined as:
       (a) the assessment, evaluation, and the therapeutic intervention and treatment, which may be either primary, parallel or adjunctive, of mental, emotional, developmental and behavioral disorders through the use of the arts as approved by the department; and
       (b) the use of assessment instruments and mental health counseling and psychotherapy to identify, evaluate and treat dysfunctions and disorders for purposes of providing appropriate creative arts therapy services.
       
       §8405. Psychoanalysis.
       1. Definition of the practice of psychoanalysis. The practice of the profession of psychoanalysis is defined as:
       (a) the observation, description, evaluation, and interpretation of dynamic unconscious mental processes that contribute to the formation of personality and behavior in order to identify and resolve unconscious psychic problems which affect interpersonal relationships and emotional development, to facilitate changes in personality and behavior through the use of verbal and nonverbal cognitive and emotional communication, and to develop adaptive functioning; and
       (b) the use of assessment instruments and mental health counseling and psychotherapy to identify, evaluate and treat dysfunctions and disorders for purposes of providing appropriate psychoanalytic services.
       
       
12. There is no psychotherapy license so which license should I have to practice "psychotherapy"?
    

    The practice of psychotherapy is included in the definition of practice of each of the new mental health professions. The decision of which license is appropriate must be made by an individual based upon the applicant's education or training and supervised experience.

    An individual who is not licensed in one of the mental health professions, or exempt under the Education Law, may not practice psychotherapy or hold oneself out as a psychotherapist.

13. Are there individuals who do not require a license to practice mental health counseling, marriage and family therapy, creative arts therapy or psychoanalysis?
    

    The Education Law includes several exemptions, including:

    1. Licensees in other professions whose practice includes similar services, e.g., medicine, psychology, nursing, social work, mental health counseling, marriage and family therapy, creative arts therapy, and psychoanalysis can perform those functions but cannot use the licensed titles of the new professions;
    2. Students, interns and residents, as part of a supervised educational program in an institution approved by the Department;
    3. Individuals, churches, schools, and not-for-profit entities providing "instruction, advice, support, encouragement or information" to individuals, families and relational groups;
    4. Attorneys, rape crisis counselors, alcohol and substance abuse counselors, and pastoral counselors when functioning within the authority of those credentials;
    5. Pastoral counseling by members of the clergy and Christian Science Practitioners, in the context of discharging one's ministerial functions;
    6. Occupational therapists licensed under Article 156 of the Education Law, so long as they do not practice psychotherapy; and
    7. Individuals in programs that are operated, regulated or financed by the New York State Office of Mental Health, Office of Mental Retardation and Developmental Disabilities, Office of Alcoholism and Substance Abuse Services, Office of Children and Family Services or local social service districts until January 1, 2010, so long as the person does not use the restricted title.
    
    
14. How do I verify my experience if I cannot find my former supervisor or the supervisor is deceased?
    

    In some instances a supervisor cannot be located or is deceased. Two licensed colleagues who attest that the applicant received the supervision from the person named on the experience form can verify the experience. The process requires that:

    • The applicant completes the first part of Form 4B and sends it to the agency or colleagues who will verify that the experience met the requirements for the license or privilege. Form 4B must be submitted directly to the Office of the Professions and must bear original signatures; photocopies and faxes are not acceptable.
    • Form 4B should include information about the qualifications of the supervisor (e.g., educational degree, license number, profession, and/or national certification).
    • The licensed colleagues attesting to the experience should each include his/her license number, profession and contact information.

    Applicants seeking licensure based on experience completed as part of the licensing requirement in another jurisdiction must have the supervisor (or two licensed colleagues) complete the required information on the frequency and duration of the supervision and qualifications of the supervisor. The Education Department will not accept licensure in another jurisdiction nor receipt of a national credential as evidence of having met the supervision requirement under New York State Education Law.

    Applicants seeking to meet the experience requirement through the completion of supervised experience in the education program (if allowed under the Education Law and Commissioner's Regulations) should indicate the experience on Form 4 and have the supervisor submit Form 4B to the Department for evaluation.

15. In some professions, the applications require the completion of "semester hours" while other sections require the completion of "clock hours" and even others require the completion of "client contact hours". Is there a difference or are these all the same?
    

    The Commissioner's Regulations define a "semester hour" as one credit hour that is equal to a 50-minute instructional hour, over a 15-week period, plus the completion of 30 hours of assigned work outside the classroom. A semester hour is only used in degree-granting institutions and may be converted to a quarter-hour in degree granting programs.

    A clock hour is defined as a 60-minute hour. If the education or experience requirement is for a "clock hour" there should be 60 minutes of practice or instruction.

    A "client contact hour" is a 60-minute hour in which the applicant or licensee is providing services to a client (individual, family or group). A client contact hour may not include collateral services, filing, travel, record-keeping or other activities that are not spent with the client.

16. I did not graduate from a program that is registered as leading to licensure in a mental health profession in New York State, so how can I prove that I have completed the required education for licensure?
    

    The Education Law requires the applicant to complete a registered program that leads to licensure, as defined in Part 52 of the Commissioner's Regulations, or the equivalent, as determined by the Department. In the case of applicants under the alternative pathways, the required course content is spelled out in the regulations, but is less than the content required in a registered program.

    The registrar of a college or university that was not registered by the Department as leading to licensure must submit directly to the Department, along with a transcript showing the courses completed and grades earned, a copy of the course catalog or syllabi for each course attempted. The Department must have the course catalog or syllabi in order to determine if the applicant completed the required curriculum content in the education program.

    If a degree-granting institution in New York State has ceased operations or has eliminated a program of study, the institution must transfer student records to another degree-granting institution or to the Education Department. You can contact the Office of Higher Education in the Department to determine the repository for records for each college or university that no longer operates in New York State.

    If you attended a training program chartered by the Board of Regents that did not award a degree, you should consult with former classmates, instructors or administrators to determine whether records are accessible. The Department may accept college catalogs that include course descriptions or syllabi from certain individuals or institutions to use in the evaluation of applications for licensure. It remains the responsibility of the applicant-not the State Education Department--to ensure that required information is provided to the Department so that an application may be evaluated.

17. If I was supervised by an individual with a credential, other than those listed in the application packet, would the supervisor be qualified?
    

    The Department reviewed the criteria established by credentialing organizations that had contacted us prior to the printing of the applications. It is likely that other organizations have similar standards for the review of an applicant's education, experience and collegial endorsements that are necessary to issue a credential. A credentialing organization that believes it utilizes standards acceptable to the Department should submit to the State Board Office information that can be reviewed by the Department. The list of acceptable credentials will be updated on this site. Even if a credential is acceptable to the Department, it is only acceptable until January 1, 2008 and the credentialed supervisor must also have the education and experience specified in the Commissioner's Regulations to be acceptable to the Department.

18. I completed-or am in the process of completing-a training program in psychotherapy in an institute chartered by the Board of Regents. Does that mean I meet the qualifications for licensure? If not, can I continue to practice until there is a license for which I might qualify?
    

    The Education Law sets specific standards for education, experience and examination that are required for licensure in the mental health professions. The only non-degree programs that qualify for licensure are those psychoanalytic training programs that meet the requirements of Part 52 of the Commissioner's Regulations. The Education Department cannot register as licensure-qualifying any program unless the program meets the requirements in Part 52.35.

    If you are licensed in a mental health profession (e.g., mental health counseling, clinical social work, psychology, nursing or medicine) you may participate in education programs that do not lead to licensure. If you are not licensed and the program is not registered as license-qualifying, you must cease your practice. If you wish to practice as a mental health practitioner you may enroll in a license-qualifying program and only provide services as part of that supervised educational experience. A student in a registered program who practices the profession without supervision may not only face termination from the education program and may be charged with the illegal practice of a profession that requires a license, which is a felony in New York State. A felony conviction may require the Department to determine whether an applicant is of sufficient moral character to be licensed in a profession.

19. I already received a master's degree in an appropriate field but it was not a license-qualifying program and did not include some of the course content required under the Education Law and Regulations. If I complete additional graduate coursework, does any of my prior experience count toward the requirement for licensure?
    

    The Commissioner's Regulations in the new professions require that an applicant complete a program registered by the Department as leading to licensure in New York State, or the equivalent as determined by the Department. If we determine that your education is deficient, you can correct the deficiency through the completion of graduate coursework from a registered program. The Department can then consider that graduate coursework in addition to the coursework you completed in earning the graduate degree. Although some of the coursework may be completed after the degree date, we typically utilize the degree date as the starting point for supervised experience.

If you have questions not addressed above, you may contact the State Board for Mental Health Practitioners at (518) 474-3817 ext. 450; or e-mail mhpbd@mail.nysed.gov