Frequently Asked Questions
Education Requirements for Licensure as a Mental Health Practitioner
These Questions and Answers are offered as 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. (August 7, 2008)
Program leading to licensure in New York | Education completed outside of New York | Satisfying additional educational requirements for licensure | Requirements are established in law and regulation | Education for licensure in Mental Health Counseling | Education for licensure in Marriage and Family Therapy | Education for licensure in psychoanalysis | Additional information
- What is a licensure-qualifying program?
The Department registers as licensure-qualifying an education program that is offered in New York State and which it has determined includes the course content specified in Education Law and Commissioner's Regulations for the specific profession. If you graduated from a licensure-qualifying program after its official date of registration, you will automatically satisfy the education requirements for licensure.
Please note that the Department registers a program that leads to a specific degree which includes the degree and content specified in Education Law and the Commissioner's Regulations. Only the degree program is acceptable; a degree from the same school in a different field is not license-qualifying. For instance, a graduate degree in school psychology is not licensure-qualifying, even if offered by a university that offers a licensure-qualifying graduate degree in mental health counseling.
- Where can I find a list of licensure-qualifying programs?
The Inventory of Registered Programs (IRP) is accessible on-line and provides the name of each program that is registered as licensure-qualifying by the Department. You can access the IRP at www.nysed.gov/heds/IRPSL1.html and search for programs leading to a license in the 48 professions. You can access a list of the degrees leading to licensure and the date of approval under the requirements for each of the mental health professions on this site.
- How do I verify that I completed a licensure-qualifying
You must submit a Form 2 to the registrar of the school where you completed the education program. The registrar must complete Form 2 and submit this directly to the Department, indicating that you completed a licensure-qualifying program and the date the degree was or will be awarded. We cannot accept Form 2 from the applicant or any other person.
- What if I graduated from a program before it was designated
Only those individuals who graduate after the program is registered have completed a licensure-qualifying program. For instance, if the program was registered on September 1, 2005, the school has promised the Department that every graduate after that date has completed the required program for licensure. A student who graduated prior to the licensure-qualifying registration date must have the school submit directly to this office Form 2, transcripts, course syllabi and other information that will allow the Bureau of Comparative Education to determine if the applicant satisfied education requirements equivalent to a licensure-qualifying program. This review will be done on an individual, case-by-case basis. The applicant will be notified if additional information is required or if additional education or an internship must be completed to meet the education requirements for licensure in New York.
- What if I graduated from a program that is outside
of New York?
The Department does not register as licensure-qualifying programs that are offered by institutions outside of New York. Each individual who graduates from a program outside of New York must apply for licensure and then be individually evaluated to determine if the applicant has satisfied education requirements equivalent to a New York licensure-qualifying program. The Bureau of Comparative Education will review the Form 2, transcript, course syllabi and other information that is submitted directly by the college or university. The applicant will be notified if additional information is required or if additional education or an internship must be completed to meet the education requirements for licensure in New York.
- What if I completed an education program in another
jurisdiction that was accredited?
The Department has determined that programs accredited by the following organizations in the specific professions are equivalent to a New York State-registered program:
- Masters or higher degree in mental health counseling of 60 semester hours (or more) accredited by the Council for Accreditation of Counseling and Related Education Programs (CACREP) under its 2009 Standards;
- Masters or higher degree program in marriage and family therapy accredited by the Commission on the Accreditation of Marriage and Family Therapy Education (COAMFTE) under its 2005 Standards;
- Masters or higher degree program in art therapy that is accredited by the American Art Therapy Association (AATA) under its 2007 Standards;
- Post-masters program in psychoanalysis that is accredited by the American Board for Accreditation in Psychoanalysis (ABAP) under its 2002 Standards.
An applicant who did not complete a New York State licensure-qualifying program or an accredited program, as defined above, must have an individual review of education as described above (#5).
- Can I complete a distance-learning program to meet
the education requirements for licensure in New York?
The Department will accept a degree program that is completely or partially offered on-line, if the program meets the accreditation standards above (#6). If you complete a distance-learning program at a regionally accredited school outside New York that is not accredited by one of the organizations above, we will review the transcript, course syllabi and internship to determine whether the program is equivalent to a New York licensure-qualifying program after the application for licensure and fee have been received.
- If I am enrolled in a distance-learning program or
a college or university in another jurisdiction that is not accredited or registered as leading to licensure in New York, can I complete the supervised internship in New York?
Effective January 1, 2006, only persons who are licensed, hold limited permits, or are exempt pursuant to Article 163 may practice as mental health counselors, marriage and family therapists, creative arts therapists, or psychoanalysts. Section 8410(3) of the Education Law allows the practice of the professions by a "student, intern or resident in, and as part of, a supervised educational program in an institution approved by the Department."
A school that is outside of New York and seeks to place student interns in New York is responsible for identifying and approving a placement and supervisor, consistent with New York law. The supervisor and the setting must meet the same qualifications as set forth in the Commissioner’s Regulations for the post-degree, supervised experience. The internship site may include a setting that is defined as exempt from licensing laws until July 1, 2013.
The Professional Education Program Review (PEPR) unit in the Office of the Professions has established a process by which an out-of-state education program that is not accredited (as noted in question 6) may seek permission to place interns in New York. Until an out-of-state program is approved, a student could be placed in an internship at an exempt program, as defined in law, until July 1, 2013*. Otherwise, the program needs to have the appropriate professional accreditation or NYSED registration. The program is responsible for identifying sites and supervisors where the student will complete supervised internships in the practice of the profession, as part of the education program.
Colleges and universities seeking additional information should contact Professional Education Program Review at OPPROGS@mail.nysed.gov.
* Nothing in the requirements for licensure under Article 163 of the Education Law “shall prohibit or limit such activities or services on the part of any person in the employ of a program or service operated, regulated, funded, or approved by the Department of Mental Hygiene, the Office of Children and Family Services, the Department of Correctional Services, the State Office for the Aging and the Department of Health or a local governmental unit as that term is defined in Article 41 of the Mental Hygiene Law or a social services district as defined in Section 61 of the Social Services Law, pursuant to authority granted by law. This section shall not authorize the use of any title authorized pursuant to Article 153 or 163 of the Education Law by any such employed person, except as otherwise provided by such articles respectively."
- How do I complete additional coursework to meet the
requirements in New York?
If you did not complete a licensure-qualifying program, the Bureau of Comparative Education will evaluate your transcript, course syllabi and other material to determine if your education is the equivalent to a licensure-qualifying program in New York State. For each profession, the regulations specify (1) an acceptable qualifying degree program (e.g., counseling or marriage and family therapy) and (2) the required course content.
- If you have not earned a qualifying degree, regardless of specific course content and supervised internship, you may be required to complete a new degree in a qualifying degree program, including all required course content and supervised internship. Advanced standing status would be up to each school/college.
- If you have earned a qualifying degree, but lack a few courses or a supervised internship, it is likely that you can complete additional graduate coursework or supervised internship at an acceptable graduate degree program.
- If you currently are enrolled in an education program that is not licensure-qualifying in New York, you may wish to review with your academic advisor your program of study and the education requirements for licensure in New York. It may be possible to complete the courses as part of your current education program or you may choose to seek advanced standing at another degree-granting institution.
- If internship and practice courses that require students to assess and treat patients under supervision are to be completed in New York State, they can only be completed by a student enrolled in a licensure-qualifying program or by a student performing the internship and practice courses in an exempt setting.
- In general, all course work must be graduate level from a college or university registered in New York or regionally accredited.
- Please note that non-credit bearing continuing education courses are not accepted for licensure.
- The Education Law does not authorize the substitution of experience or credentials for the education required to become licensed in one of the mental health professions.
- If I have completed the qualifying degree and course
work, but not the required internship how can I meet this requirement?
At a minimum, the internship must be part of the graduate educational program and reported on the transcript of an educational institution acceptable to the Department. The internship must be legally completed in accordance with the laws of the jurisdiction where the internship occurs. The student intern must engage in the practice of the profession as defined in statute and be under the supervision of a qualified supervisor who is appropriately licensed in the jurisdiction.
In order to complete the internship, the intern must be legally authorized to practice the profession under supervision as part of an education program. This means the internship must be:
- Part of a New York State licensure-qualifying program in the profession, as a matriculated or non-matriculated student; OR
- Until January 1, 2010, in an exempt setting, as defined in Education Law; OR
- Completed in another jurisdiction as part of a graduate educational program that leads to a degree in the profession in accordance with the laws of the jurisdiction, acceptable to the Department; OR
- Completed in another manner, acceptable to the Department
Except as authorized under New York law, the internship may not count toward the experience requirement for licensure in the profession.
- Can I practice the profession while meeting the education
requirements in New York?
If you are enrolled in a licensure-qualifying program, you may only practice the profession under supervision as part of the required internship or practicum. You may not practice outside of the supervised setting that is part of your education program. Once you complete the licensure-qualifying program and receive your degree, you may not practice until you have received a limited permit or license from the Department.
You can access more information about limited permits, including frequently asked questions, fees, and instructions for submitting the permit application, on this site.
- If I have to complete additional coursework does this
affect the date of my degree and the requirements for post-degree
If you are seeking licensure in mental health counseling, creative arts therapy, or in marriage and family therapy based on a degree in an allied field, you must have post-degree hours of supervised experience in the practice of the profession. If the Bureau of Comparative Education determines that you have a qualifying graduate degree but need additional coursework to meet the content requirements, we can count any experience after the date of that acceptable degree. However, if the Bureau of Comparative Education determines that you need to complete a new degree to qualify for licensure, we can count only that experience after the date you received the new degree.
For instance, licensure as a mental health counselor requires a 60-semester hour degree in counseling with required course content and supervised internship in mental health counseling. An applicant with a master’s in school counseling/psychology, counseling psychology, or community counseling may only have to complete additional coursework in mental health counseling and supervised internship in mental health counseling, but would not have to complete a new degree, since the original degree is in "counseling” as determined by the Department. Another applicant with a graduate degree in human services, liberal studies, or another field may have related courses (e.g., human development, cultural aspects of counseling) but does not have a qualifying graduate degree, acceptable to the Department, or the majority of required content in mental health counseling. This applicant would be required to complete a new degree program (but may qualify for advanced standing at a licensure-qualifying program – see question # 16 for more information). In this case, only experience after the second degree can count toward licensure.
- Can I meet the internship requirement by working at
my current job?
The determination of an acceptable internship site is the responsibility of the licensure-qualifying program, which has affirmed that every student will be supervised by a licensed or qualified professional. If your regular employment is determined to be acceptable for the internship, it should be clear who is providing supervision of your practice and evaluating your internship for educational credit.
An intern practicing in New York must be under the supervision of an individual who is licensed and qualified to practice the profession being supervised. The supervisor is responsible for the assessment and treatment of each patient and must be on-site. You cannot have a supervisor who is in another jurisdiction or receive supervision by phone or other technology.
If the education program places students in an internship outside of New York, the experience must be supervised by a licensed and qualified supervisor in that jurisdiction and constitute the practice of the profession in New York.
- Where can I review the education requirements for licensure?
Article 163 of the Education Law sets the general requirements for licensure, including graduate education, supervised experience and examination. The requirements to be met by a program that is licensure-qualifying in New York are in the Commissioner’s Regulations:
- Part 52.32 for Mental Health Counseling
- Part 52.33 for Marriage and Family Therapy
- Part 52.34 for Creative Arts Therapy
- Part 52.35 for Psychoanalysis
You can access the law and regulations on line.
- A licensure-qualifying program in mental health counseling
is defined as 48 semester hours, prior to January 1, 2010,
and 60 semester hours after that date. A qualifying degree
is in counseling with the course content and supervised internship
in mental health counseling specified in law and regulation.
- 15a. If I complete a 48-semester hour licensure-qualifying
program and apply for licensure prior to January 1, 2010,
will I have to complete additional course work?
You would not need to complete additional course work. You must meet all other requirements for licensure, including supervised post-degree experience, moral character and examination.
- 15b. If I completed a 48-semester
hour licensure-qualifying program prior to January 1,
2010 and apply for licensure after that date, will I
have to complete additional course work?
Yes. You must also meet all other requirements for licensure, including supervised post-degree experience, moral character and examination.
- 15c. If I enrolled in a 48-semester hour licensure-qualifying
program but do not complete the education until after
January 1, 2010, do I need 60 semester hours?
A licensure-qualifying educational program is not authorized to award a 48-semester hour degree in mental health counseling after December 31, 2009. You will be required to complete a 60-semester hour licensure-qualifying program to receive a degree after January 1, 2010.
- 15a. If I complete a 48-semester hour licensure-qualifying program and apply for licensure prior to January 1, 2010, will I have to complete additional course work?
- I completed a graduate degree in school counseling
and want to become a mental health counselor. How can I meet
the education requirements for licensure?
An applicant for licensure as a mental health counselor must meet the requirements for a master’s or higher degree in “counseling” that includes specified content in mental health counseling. A degree that qualifies for certification as a school counselor or school psychologist generally is not sufficient to meet the requirements for licensure as a mental health counselor. You must complete additional graduate coursework, including supervised internship in mental health counseling, to meet the requirements for licensure.
Depending on your initial degree and course content, you may need to complete either a new degree or additional graduate coursework. For instance, an applicant with a master’s in liberal studies or human services may be required to earn a new graduate degree in counseling, including required content. An applicant with a degree in school counseling/psychology, counseling psychology, or community counseling, on the other hand, may only need to complete additional graduate coursework and/or supervised internship. The following are the available options for completing additional required coursework:
- An education program registered as licensure-qualifying in mental health counseling may admit a student with a master’s degree, in school counseling or a related profession, and waive certain classes required for the licensure-qualifying program. It is up to the individual school to determine what coursework can be transferred/accepted as advanced standing in the new program. The education program would require the student to matriculate in the licensure-qualifying program and complete specific graduate coursework and internship in mental health counseling. Upon completion, the student would be certified by the Registrar as having completed a licensure-qualifying program and awarded a new master’s or higher degree in counseling.
- An individual with a master’s in school counseling could apply for licensure and individual evaluation by the Education Department. The Department would provide the student with a list of deficiencies in coursework and/or internship. If agreed to by the school, the student could enroll as a non-matriculated student in a program registered as licensure-qualifying in mental health counseling. Upon completion of the coursework, the Registrar would submit Form 2 and a transcript to the Department to verify the graduate coursework and/or internship in mental health counseling that were completed by the student in that institution. The Department would evaluate the prior counseling degree and the supplemental graduate education to determine if the student has completed a program that is substantially equivalent to a licensure-qualifying program.
- The Education Department has registered several “bridge” programs at institutions that also have a license-qualifying degree program in mental health counseling. Completion of the “bridge” program, in addition to the original graduate degree in counseling or a related field, would allow the student to meet the education requirements for licensure. This type of program would require each student to meet specific admission criteria (e.g., 48 semester hour degree in school counseling/psychology) and complete required course content such as:
- assessment and appraisal of individuals, couples, families and groups;
- professional orientation and ethics;
- foundations of mental health counseling and consultation;
- clinical instruction; and
- include a supervised internship or supervised practicum in mental health counseling of at least one-year, defined as at least 600 clock hours for purposes of this section.
- A school that offers a “bridge” program that is not registered by the Department cannot assure the student that he/she will meet all education requirements upon graduation. Since the student did not complete a licensure-qualifying program, the Department must individually evaluate the students’ academic transcript(s).
- An individual with a master’s in school counseling/psychology could enroll as a non-matriculated student in an education program, assuming that his/her education does not meet the requirements for licensure. The student would complete graduate coursework and/or internship in mental health counseling based on advice from the education program. Upon completion of the coursework, the Registrar would submit Form 2 and a transcript to the Department to verify the graduate coursework and/or internship in mental health counseling that were completed by the student in that institution. The Department would evaluate the prior master’s degree and the supplemental graduate education to determine if the student has completed a program that is substantially equivalent to a licensure-qualifying program. In this case, it may be determined that the student has not met the requirements, as the course selection was made prior to any evaluation by the Department.
- Why are there distinctions between pre-degree and post-degree
experience in the practice of marriage and family therapy?
An applicant for licensure in marriage and family therapy can meet the education requirement with a degree in marriage and family therapy or in an allied mental health field. All experience, including supervised experience as part of the degree program, must be verified by a qualified supervisor, acceptable to the Department.
A program that is registered by the Department as licensure-qualifying in marriage and family therapy, or determined by the Department to be the equivalent, will award a master’s or doctoral degree on the basis of meeting the curriculum requirements, including a supervised practicum in marriage and family therapy of at least 300 client contact hours. The Education Law and Commissioner’s Regulations allow supervised client contact hours completed in the marriage and family therapy program to count toward the 1,500 client contact hours of supervised experience required for licensure.
An applicant for licensure as a marriage and family therapist may meet the education requirements through the completion of a master’s or higher degree in an allied profession (e.g., social work, psychology, counseling) and additional graduate course work, if needed. Education Law and Commissioner’s Regulations require an applicant with a degree in a field other than marriage and family therapy to complete 1,500 client contact hours of post-degree, supervised experience in marriage and family therapy, acceptable to the Department.
- How do I document that I met the education requirements
for licensure in psychoanalysis which requires a master’s degree
and an advanced certificate in psychoanalysis?
In order to be admitted to a licensure-qualifying program in psychoanalysis, the registered program must determine that you received a master’s degree in any field from a program registered by the Education Department or regionally accredited. In order to qualify for a license or limited permit to practice psychoanalysis, the Department must receive verification from both the college or university where you received the master’s degree and from the psychoanalytic training program. Individuals who did not complete a licensure-qualifying psychoanalytic program will be evaluated individually to determine if the program was the equivalent of a licensure-qualifying program. The Department cannot count any psychoanalytic study earned prior to completion of the master’s degree.
- If I am licensed in another health profession (e.g.,
medicine, social work, psychology or occupational therapy)
do I have to meet any requirements for licensure as a mental
health counselor, marriage and family therapist, creative arts
therapist or psychoanalyst?
Licensure in one profession does not guarantee licensure in another profession. If you want to be licensed in another profession, you must meet all requirements for licensure mandated for that profession, including the education and experience requirements.
If you are licensed as a physician, physician’s assistant, registered professional nurse, nurse practitioner, licensed clinical social worker, or licensed psychologist, and competent in the practice of mental health counseling, marriage and family therapy, creative arts therapy or psychoanalysis, you may not need another license to practice the profession. You can demonstrate competence through the completion of continuing education, specialized training, and similar professional activities. Those activities must be completed in accordance with the requirements of your license and you may not hold yourself out as licensed in another profession.
For instance, the practice of licensed clinical social work includes the practice of psychoanalysis. If you are an LCSW you may complete training in psychoanalysis and would not need to be licensed as a psychoanalyst, so long as you do not imply that you are a “licensed psychoanalyst”. However, if you wish to become a licensed psychoanalyst you must complete a an acceptable psychoanalytic program, supervised experience in psychoanalysis and examination. You could not hold yourself out as a psychoanalytic practitioner while completing the training and could only practice under supervision. You can review the requirements for licensure and the definition of practice of all 48 professions online.
- What happens to my application if I do not meet the
requirements for licensure?
First, you can withdraw your application and request a refund of the three-year registration fee that you submitted with your application. If you apply in the future you would have to meet all requirements for licensure at that time. Second, you can maintain your application and meet the “standard” requirements for licensure, including a graduate degree with required content, supervised experience and examination. If you wish to pursue this option, you should contact licensure-qualifying programs and review your qualifications with the program to determine what courses would be required to earn a qualifying degree. When you complete the required education, you would qualify for a limited permit to allow supervised practice while meeting the experience and examination requirements.
Please remember that an individual who practices a profession that requires licensure without being licensed or exempt, as defined in the Education Law, could be charged with illegal practice of a profession, which is a felony. A felony conviction would be considered a question as to whether you have acceptable moral character to qualify for a license or limited permit to practice one of the licensed professions in the future.
- I have many years of experience in the profession,
including credentials and licensure in other jurisdictions.
Is there reciprocity or any way my qualifications can substitute
for the requirements in New York?
There is no reciprocity for a professional license. An applicant must meet the requirements for graduate education, including specific course work and internship, supervised experience and examination, as established in the Education Law and Commissioner’s Regulations. The Department may endorse an applicant who is licensed in another jurisdiction in the same profession; who satisfies our requirements for education, experience and examination; has not been disciplined in another jurisdiction; is of good moral character as determined by the Department, and has at least two years of full-time (1,750 hours per year) post-license practice of the profession, acceptable to the Department.
- I applied for licensure without examination and did
not meet those requirements by December 31, 2006. How can I
qualify for licensure and can I continue to practice?
Effective January 1, 2006, the Education Law restricts the practice of mental health counseling, marriage and family therapy, creative arts therapy and psychoanalysis to individuals who are licensed or exempt. An amendment to the Education Law and Commissioner’s Regulations allowed individuals who applied for licensure prior to January 1, 2006 under the special provisions to have until December 31, 2006 to document having met the education and experience requirements for licensure. All education and experience for licensure under the grandparent provisions must have been completed by December 31, 2006 to qualify for licensure. If you did not meet these requirements, you may be evaluated under the standard pathway to licensure. Please refer to question # 9 for information about completing additional course work or degree requirements for licensure.