Honorable Senator or Representative [name]:
We are psychologists writing against the [bill or resolution title and number] being considered by the 1998 [name of state] State Legislature. We are the American Association of Applied and Preventive Psychology, which is an affiliate of the American Psychological Society. In 1995, we passed a Resolution Opposing Prescription Privileges for Psychologists. This AAAPP Resolution has been endorsed by Section III of the Clinical Division (12) of the American Psychological Association (Society for a Science of Clinical Psychology). Other professional psychological associations have opposed prescription privileges. The National Council of University Directors of Clinical Psychology programs voted against the pursuit of prescription privileges in 1995. In 1996, the Council of Graduate Departments of Psychology voted that a decision to pursue prescription privileges should not be made until those involved in providing university training support this major change to the profession.
While the American Psychological Association supports prescription privileges, the [bill or resolution number] may be incorrectly predicated on the assumption that privileges are universally supported by the discipline of psychology and that there is an urgent need for society to train more prescribers.
We will list five reasons why we are against prescription privileges and why we conclude there is not a societal need to spend taxpayer money on making clinical psychology a new medical profession.
1) Prescription authority for psychologists may result in greater risk to the consumer of medical mental health services. Therefore, consideration of appropriate medical training and regulation must be a conservative process. Psychoactive substances are poorly understood. Many of these drugs have serious medical side effects and are drugs of abuse. Prescribing them requires knowledge not just about their behavioral effects (which fits within the traditional domain of psychology) but also about how they impact organ systems, how changes in one organ system interacts with other organ systems, and how these powerful chemicals interact with other drugs.
No state in the country has licensed nonmedical mental health professionals, such as psychologists or social workers, to prescribe. Prescription authority has been extended in some states to paramedical providers, such as nurses and optometrists, but training for these professions is already based upon the medical sciences. Psychologists are trained in the social and behavioral sciences and cannot be compared to nurses or optometrists. Licensed psychologists are trained to provide services that do not physically invade the body cavity, such as psychological assessment and psychotherapy.
The APA model curriculum for the training of psychologists in the practice of medicine has not been evaluated. There is a short-term evaluation of the U.S. Department of Defense (DoD) psychopharmacology training program conducted by the U.S. Congress General Accounting Office, but the DoD program included more medical training than what is proposed in the APA model curriculum. In addition, there has been no systematic follow-up report on the consumer effects of long term independent practice of the ten DoD graduates. Therefore, the risk to the consumer of licensing nonmedical professionals to prescribe is unknown.
2) Societal needs for medical mental health services can be provided by those who are already trained in nursing and medicine. For example, there is no shortage of physicians. The 1995 report of the Pew Health Professions Commission states there is a surplus of about 150,000 physicians and 20% of medical schools should be closed. When needed, medication can readily and more inexpensively be provided by already trained medical professionals in collaboration with psychologists.
The U.S. Public Health Service's 1995 statistics on health professional shortage areas did indicate a geographic maldistribution of most health professionals. There is a resulting need to provide services to underserved populations, such as those living in rural areas. These needs can be met with existing health professionals if incentives are provided, such as the policy of many managed care companies to reimburse multidisciplinary care.
3) Because psychologists are not currently trained in medicine, to do so would be extremely costly to the taxpayers and consumers of mental health services. Expenses include more faculty at universities, greater liability insurance, more state regulatory agents, and several additional years of training (currently 7 - 11 years of graduate school). The General Accounting Office reported to the U.S. Congress in 1997 that the training of psychologists to prescribe in the military costs $610,000 per psychologist and was an unnecessary expense. These expenses are likely to be passed on to the consumer and taxpayer and thereby increase health care costs.
4) The costs of training and regulating prescription privileges for psychologists unnecessarily duplicates health care services already provided by medical professions. Prescription privileges would ultimately change psychology training at the undergraduate, graduate, post-doctoral, and continuing education levels.
When nurses and optometrists have pursued prescription privileges, doing so was not divisive within their professions. This may be because their training was already medical in nature. Psychologists who wish to prescribe may currently do so by completing nursing or medical school and utilizing the training and regulatory resources already provided by the taxpayer. Some psychologists have already earned prescription authority by becoming advanced practice nurses.
5) Psychology is an identified health profession that allows the consumer choices of treatment modalities. Psychological treatments have been shown to improve the human condition, often more effectively than drugs. The science of psychology has contributed to the understanding and amelioration of human suffering by the development of dozens of empirically-supported psychosocial interventions and prevention strategies. Psychology is not outmoded and continues to make important contributions to society.
Prescription privileges could impair the public's access to psychological services. Since the development of psychoactive medications, psychiatrists have abandoned psychosocial treatments in order to specialize in the provision of these chemical compounds which are often ineffective, particularly in the long term. Consumers of mental health services who prefer not to use drugs have come to rely upon the availability of the psychosocial approach of psychologists.
In conclusion, high quality and cost-effective treatment for mental health consumers can be provided by collaboration between psychologists and medical professionals. Such collaboration has worked well for many years and continues to be effective. It is commonly practiced, consistent with established disciplines, and in the best interest of the consumer. Psychologists who wish to prescribe can pursue training in nursing or medicine. This solution would not be divisive within psychology and would not rely on major additional taxpayer resources.
Thank you for your kind consideration of this opinion.
[names and titles] American Association of Applied and Preventive Psychology 1010 Vermont Ave., NW, Suite 1100
Washington, DC 20005-4907
(202) 393-7073 | aaapp at scs.unr.edu