Category Archives: Licensure FAQs (all versions)

Is it time to start preparing for face-to-face supervision? (California BBS)

The short answer is yes.  During the COVID-19 pandemic the Board of Behavioral Sciences issued (and extended multiple times) a waiver for the face-to-face supervision requirement.  This waiver has allowed Associates in any setting (including private practice) to count supervision via two-way, real-time videoconferencing.  In addition, it allowed Practicum students to count telehealth hours toward their required hours of counseling.

We have heard multiple reports indicating that it is highly unlikely that this waiver will be extended beyond the current expiration date of August 31, 2021.  When this waiver expires (whether on August 31 or at a later date), Associates in for-profit settings (including private practices) will once again be required to receive face-to-face supervision on a weekly basis in order to claim hours of experience. Associates in non-profit settings will still be allowed to receive supervision via videoconferencing.  The law does not address supervision via videoconferencing for practicum students.

View Waiver on the BBS website

My supervisor is refusing to sign my hours. What do I do?

Ideally, as you go through your supervised experience for California licensure, you’ll have your supervisor sign your Weekly Summary of Hours of Experience each week. That way, if something happens to the supervisor, you have strong documentation of the hours of experience you had gained up to that point. But what happens when a supervisor is refusing to sign your forms, even for hours that you gained weeks, months, or years ago?

When a supervisor refuses to sign weekly logs or the summary of experience form, it is the supervisee who suffers. The BBS will not count hours of experience without a signed Verification of Experience and a Supervisor Responsibility Statement. If either of these is missing, all of your hours under that supervisor will not be counted.

Common reasons for refusing to sign

While these instances are rare overall, it does sometimes happen that a supervisor refuses to sign off on a supervisee’s experience. In my experience, this happens most commonly when a supervisor has left an agency, and then supervisees from that agency ask the supervisor weeks or months later to complete paperwork. If the supervisor has moved, if the separation from the agency was less-than-friendly, or if the supervisor is having other challenges in their life, they may refuse to sign hours. They may not respond to emails or phone calls at all.

It’s worth noting here that there are often good, valid reasons why supervisors might refuse to sign hours. If the supervisor believes that the supervisee is counting or calculating their experience incorrectly, then the supervisor shouldn’t sign the hours — to do so would be unprofessional conduct on their part. It would arguably be participating in fraud. Of course, if that’s their reason for the supervisor refusing to sign, they should explain that and work with the supervisee to resolve the issue by signing for the hours they’re comfortable signing or that the supervisee can reasonably support through documentation.

Common resolutions for refusing to sign

The first steps to resolve such refusal should always be empathetic ones. If a supervisor hasn’t responded to messages, is there a chance they simply haven’t gotten the messages? Are there other ways you might reach them? If a supervisor is uncomfortable with your listed hours, do you have additional documentation to support those numbers?

If it becomes clear that the supervisor is dodging contacts or willfully refusing to sign, it’s time for a gentle confrontation. Regardless of what they think of you or the quality of your work, if they supervised it, they have some responsibility for it. That includes acknowledging the work that you did by signing off on it.

California law for supervisors refusing to sign hours

In fact, under California law, a supervisor is required to give at least 7 days notice if they are going to stop signing for further hours of experience. If they refuse to sign for hours gained in good faith before such notice was given, the supervisor may be found by the BBS to have committed unprofessional conduct. Their license may be disciplined. That may include losing the ability to supervise.

So, if a supervisor is refusing to sign your documentation of experience that they did in fact supervise, you should put in writing a request that they respond to you by a certain date, citing the law,* and noting that if they do not respond, a board complaint may result. Send this in a way that delivery is documented (for example, using package tracking), and then once delivery is confirmed, follow up with a phone call or email. Most supervisors at this point will provide signatures, even if reluctantly.

Of course, the threat of a complaint should only be a last resort, never a first step. Thankfully, most supervisors are eager to resolve any disputes about hours amicably, and to sign for supervised hours as part of their role in helping you achieve licensure. If anything, these kinds of disputes, while thankfully rare, offer a useful reminder: It’s so much easier (and less risky) to just get required signatures every week as you gather experience.

Those legal citations: For MFTs, it’s California Code of Regulations (CCR), Title 16, Division 18, section 1833.1(c). For PCCs, it’s CCR Title 16, Division 18, Section 1821(d). For CSWs, it’s CCR Title 16, Division 18, Section 1870(a)(11). The relevant section is determined by the type of supervisee, not supervisor. Each of these regulations says the same thing: “A supervisor shall give at least one (1) week’s prior written notice to an associate of the supervisor’s intent not to sign for any further hours of experience for such person. A supervisor who has not provided such notice shall sign for hours of experience obtained in good faith where such supervisor actually provided the required supervision.”

Ben Caldwell is the Education Director for SimplePractice Learning.

Should you include buffer hours when submitting hours for licensure?

One of the most often-asked questions prelicensed therapists ask happens just as they hit the proverbial finish line: 3,000 hours of supervised experience (or whatever specific number their state board requires). They’re getting ready to submit their hours of supervised experience to their licensure board for review, and they wonder: Should I go above and beyond what’s required before I submit my hours, just in case some of my experience gets disallowed? In other words, do I need to include buffer hours when I submit my hours?

The short answer here is no, you don’t. You should submit as soon as you hit 3,000 hours of supervised experience (or whatever number your board requires). As long as you have used TrackYourHours or a similarly reliable method for counting hours, the chances that some experience will be disallowed are slim. Even in the unlikely event that does happen, including buffer hours doesn’t really help you.

Here’s why. State boards, especially California’s, can take a long time to process applications for license eligibility. During the time they’re processing your application, you’re likely still working under supervision. Continue documenting your hours during this time. In the unlikely event that your board does ultimately determine that some of your submitted hours will be disallowed, it is very likely that by the time you even receive your notification, you will have already worked enough additional hours to make up the deficiency. Such deficiencies are often quickly resolvable without moving you to the proverbial back of the line.

On the other hand, adding buffer hours can lead you to wait weeks or even months longer before even submitting your application. Resolving a deficiency or disallowance sometimes takes as little as a week; earning buffer hours usually involves much more time, and that added time rarely has any benefit. The trade-off simply isn’t worth it.

So if you add buffer hours and don’t wind up having any hours disallowed, all you did was delay your licensure process. And if you add buffer hours and do wind up having some hours disallowed, it’s still not likely that you actually sped things up — it’s much more likely that the time you spent building that buffer exceeds the time you would have needed to resolve the deficiency once your application had been evaluated.

Simply put, don’t wait one day longer than you need to in the process of getting licensed.

Ben Caldwell is the Education Director for SimplePractice Learning.

New 2021 BBS Forms

The BBS has released new experience verification and weekly summary forms dated January 1, 2021.  The experience verification forms have only one minor change on page 1.  “*If licensed in California for less than two years on the first date of experience claimed, provide out-of-state license information.” was changed to “*If licensed in California for less than two years on the first date of experience claimed, attach out-of-state
license information.”  Note that only the Option 1 (New Requirements) forms were updated and the Option 2 forms have been removed from the BBS site.  TYH will continue to produce the Option 2 forms until December 31, 2021.

The weekly summary forms were changed from 8 rows with the weeks as column headers to 5 rows with the weeks as row headers.  Note that only the Option 1 (New Requirements) forms were updated and the Option 2 forms have been removed from the BBS site.  TYH will continue to produce the Option 2 forms until December 31, 2021.

Example of new Option 1 LMFT Weekly Summary Form

COVID waiver extensions

Four of the COVID-19 waivers have been extended by the BBS:

  • renewal requirements – extended to Oct 31, 2020
  • L&E Exam requirement for subsequent registrations – extended to Oct 31, 2020
  • face-to-face supervision – extended to Nov 2, 2020
  • practicum enrollment – (date has not been updated by the BBS but they have stated that the waiver has been extended)

View all Waivers