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RULE PROPOSALS 44 N.J.R. 2352(a) Proposed Amendment: N.J.A.C. 13:34-4.3 Experiential Requirements for Licensure Authorized By: State Board of Marriage and Family Therapy Examiners, Terri Goldberg, Acting Executive Director. Authority: N.J.S.A. 45:8B-13 and 18. Calendar Reference: See Summary below for explanation of exception to calendar requirement. Proposal Number: PRN 2012-151. Submit comments by December 14, 2012 to: Terri Goldberg, Acting Executive Director State Board of Marriage and Family Therapy Examiners PO Box 45007 124 Halsey Street Newark, New Jersey 07101 The agency proposal follows: Summary The State Board of Marriage and Family Therapy Examiners (the Board) is proposing amendments to the experience requirements for licensure set forth in N.J.A.C. 13:34-4.3. N.J.A.C. 13:34-4.3(b) requires an applicant for licensure as a marriage and family therapist to complete three calendar years of experience, with a minimum of two calendar years of supervised marriage and family therapy experience. A "calendar year" is defined as 1,500 hours of experience obtained over one 50-week period, or for those completing their training on a part-time basis, 750 hours of experience obtained over two periods of 50-weeks, for a total of 1,500 hours. Under the existing rule, an applicant for licensure must complete 1,000 hours of client contact; 200 hours of supervision, with a minimum of four hours of supervision per week; and 300 hours in other work-related activities, such as preparing and maintaining client records and writing reports, for a total of 1,500 hours of marriage and family therapy experience in a calendar year. The Board continues to believe that applicants must obtain three calendar years of experience in order to qualify for licensure and that a calendar year must consist of 1,500 hours of experience. The Board, however, believes that the current breakdown of hours set forth in N.J.A.C. 13:34-4.3(b) should be amended in order to make the Board's experience requirements more consistent with the experience requirements imposed on other mental health professionals in New Jersey by their respective licensing boards. Specifically, the Board notes that the requirement that its applicants obtain 200 hours of supervision per calendar year, with a minimum of four hours of supervision per week, is significantly more burdensome than the supervision requirements imposed on associate counselors, social workers, and alcohol and drug counselors working toward completion of their respective licensing requirements. The Board notes that the State Board of Social Work Examiners requires social workers under clinical supervision to obtain one hour of supervision per week pursuant to N.J.A.C. 13:44G-8.1. Similarly, the Alcohol and Drug Counselor Committee requires alcohol and drug counselors working under supervision to obtain 50 hours of face-to-face supervision per year, averaging one hour per week, pursuant to N.J.A.C. 13:34C-6.2. In addition, the Board notes that its Professional Counselor Examiners Committee requires applicants for licensure to complete 50 hours of face-to-face supervision per calendar year at the rate of one hour per week, pursuant to N.J.A.C. 13:34-10.2. The Board believes that this disparity in supervision requirements may place applicants for licensure as marriage and family therapists at a competitive disadvantage when seeking employment. The Board believes that because employers are required to spend four hours per week supervising such individuals, compared to one hour per week supervising other mental health professionals, it is less likely that employers will choose to hire marriage and family therapist licensure applicants. The Board, therefore, is proposing to amend N.J.A.C. 13:34-4.3(b) in order to make its experience requirements comparable to those imposed by other mental health licensing boards. The proposed amendments to N.J.A.C. 13:34-4.3(b) provide that supervised marriage and family therapy experience for each calendar year must consist of: a minimum of 50 hours of face-to-face supervision, at the rate of one hour per week; a maximum of 1,150 hours of actual marriage and family therapy client contact; and a maximum of 300 hours of other work-related activities. The proposed amendments to the supervision requirement further provide that no more than 25 hours of the required supervision may be in group supervision, ensuring that up to one-half of an applicant's hours are obtained in an intensive, one-on-one individual supervision setting. The proposed amendment to subsection (a) defines "group supervision" as supervision by a qualified supervisor of between two and six interns and/or permit holders at one time. The existing requirement in N.J.A.C. 13:34-4.3(b)2, which defines a calendar year of experience to be 1,500 hours, is proposed to be deleted as the term is already defined in subsection (a). In its place, the Board is proposing a new requirement, applicable to both the two calendar years of supervised marriage and family therapy experience, and the one calendar year of general counseling experience. The proposed amendment provides that no more than 30 hours of experience may be earned in any one week, and no more than 125 hours of experience may be earned in any one month. The Board is proposing this amendment in order to ensure that an applicant's experience is gained in a realistic timeframe, and notes that the amendment is consistent with the supervision requirements currently imposed on applicants for licensure as professional counselors under N.J.A.C. 13:34-10.2. The Board has provided a 60-day comment period for this notice of proposal, therefore, this notice is excepted from the rulemaking calendar requirement pursuant to N.J.A.C. 1:30-3.3(a)5. Social Impact The Board believes that the proposed amendments will have a positive impact on applicants for licensure as marriage and family therapists by ensuring that the counseling experience they obtain prior to licensure is well-rounded, and is consistent with the experience requirements for other mental health professionals. The Board believes that the proposed hours for face-to-face supervision, marriage and family therapy client contact, and work-related activities, will help to ensure that each calendar year of experience an applicant obtains prior to licensure will prepare the applicant to effectively engage in independent practice once licensed. Economic Impact The Board believes that the proposed amendments may have a positive economic impact on applicants for licensure as marriage and family therapists, to the extent that the proposed amendments, which will require Board applicants to obtain the same type of supervision as applicants for [page=2353] licensure by other mental health licensing boards, will make it easier for applicants to compete for employment opportunities. Federal Standards Statement A Federal standards analysis is not required because the proposed amendments are governed by N.J.S.A. 45:8B-13 et seq., and are not subject to any Federal requirements or standards. Jobs Impact While the Board anticipates that the proposed amendments will make it easier for applicants to compete for employment opportunities, it does not anticipate that the proposed amendments will result in an increase or decrease in the number of jobs in the State. Agriculture Industry Impact The Board does not anticipate that the proposed amendments will have any impact on the agriculture industry in the State. Regulatory Flexibility Analysis Currently, the Board licenses approximately 500 marriage and family therapists. If these licensees are considered "small businesses" within the meaning of the Regulatory Flexibility Act, N.J.S.A. 52:14B-16 et seq., then the following analysis applies. The proposed amendments will not impose any reporting or recordkeeping requirements on applicants for licensure as marriage and family therapists, but will impose compliance requirements on such individuals. These requirements are discussed in the Summary above. No additional professional services will be needed to comply with the proposed amendments. The costs of compliance with the proposed amendments are discussed in the Economic Impact statement above. The Board believes that the proposed amendments should be uniformly applied to all applicants seeking licensure as marriage and family therapists in order to ensure the health, safety, and welfare of the general public in the provision of marriage and family therapy services by its licensees. Therefore, no differing compliance requirements for any applicants for licensure are provided based upon the size of the business. Housing Affordability Impact Analysis The proposed amendments will have an insignificant impact on affordable housing in New Jersey and there is an extreme unlikelihood that the rule would evoke a change in the average costs associated with housing because the proposed amendments concern requirements for obtaining a license as a marriage and family therapist. Smart Growth Development Impact Analysis The proposed amendments will have an insignificant impact on smart growth and there is an extreme unlikelihood that the rule would evoke a change in housing production in Planning Areas 1 or 2, or within designated centers, under the State Development and Redevelopment Plan in New Jersey because the proposed amendments concern requirements for obtaining a license as a marriage and family therapist. Full text of the proposal follows (additions indicated in boldface thus; deletions indicated in brackets [thus]): 13:34-4.3 Experiential requirements for licensure (a) The following words and terms as used in this section and N.J.A.C. 13:34-5, shall have the following meanings, unless the context clearly indicates otherwise. . . . "Group supervision" means the ongoing process of supervising between two and six interns and/or permit holders at one time in a group setting by a qualified supervisor. . . . (b) An applicant for licensure as a marriage and family therapist shall submit to the Board documentation, on a form provided by the Board, establishing that the applicant has completed a minimum of two calendar years of supervised marriage and family therapy experience and one calendar year of counseling experience, which may be in marriage and family therapy, as set forth below: 1. Supervised marriage and family therapy experience for each calendar year shall consist of: [i. A minimum of 20 hours per week of actual marriage and family therapy client contact, with a minimum of one hour of supervision for every five hours of client contact; ii. A minimum of four hours of supervision per week, at least two hours of which shall be individual face-to-face supervision (the remaining two hours may be individual or group supervision); and] i. A minimum of 50 hours of face-to-face supervision, at the rate of one hour per week, of which not more than 25 hours may be in group supervision; ii. A maximum of 1,150 hours of actual marriage and family therapy client contact; and iii. A [minimum of six hours per week in] maximum of 300 hours of other work-related activities, such as preparing and maintaining client records as described in N.J.A.C. 13:34-8, report writing, maintaining appointment schedules, communicating with other professionals, preparing for supervision, preparing and maintaining financial records in accordance with N.J.A.C. 13:34-5.4 and 6.1, and any other activities the qualified supervisor deems appropriate; and [2. One calendar year of counseling experience, which may be in marriage and family therapy or in general counseling, shall consist of a minimum of 1,500 hours over a 50-week period, which is considered full-time, or no less than 750 hours over two periods of 50 weeks, which is considered part-time, totaling 1,500 hours for the two periods of 50 weeks.] 2. For the two calendar years of supervised marriage and family therapy experience and the one calendar year of counseling experience, no more than 30 hours of experience shall be earned in any one week, and no more than 125 hours of experience shall be earned in any one month. (c)-(d) (No change.)
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