ALERT: Rule Change with Major Implications to Texas Psychologists


Bottom Line: Proposed changes can allow those who have not completed a formal internship to petition for licensure.


Situation: The proposed rule allows for a waiver of virtually every formal internship requirement. The proposed rule gives the Texas State Board of Examiners of Psychologists (TSBEP) the power to circumnavigate the licensure process and grant full licensure regardless of completing an accredited or organized (as defined in statute)"pre-doctoral" internships consistent with standards adopted by APA and other state licensing boards. Please see the FAQ below for more specifics on the proposed wording changes.

Background: We acknowledge that it is becoming difficult for students in some regions to obtain a valid internship training experience. Compounding this is the proliferation of online doctoral programs that do not offer internships.

Assessment: Licensed professions establish and uphold uniform standards of training and practice. One of NAN’s missions is to promote human welfare, which is aligned with the TSBEP’s goal to protect the public from inadequately trained mental health providers. The long-term result of lowered and ambiguous standards will diminish the profession and our credibility as healthcare providers and create further confusion for the public regarding the training and competency of psychologists.

Recommendation: We are reaching out to the NAN community to consider advocating against this rule change which effectively ignores standards of training that have been developed and refined over decades. Especially for those providers with a Texas license, but anyone is welcome, you can submit your comments on the proposal (see link to sample letters below) to Brenda Skiff, Executive Assistant, Texas Behavioral Health Executive Council, 333 Guadalupe, Ste. 3-900, Austin, Texas 78701 or by email to

The deadline for comments is 5:00 p.m., CT, October 31.

Read FAQ about the Rule

Sample letters:

The NAN Legislative Action and Advocacy Committee (LAAC) provides periodic updates to inform members about recent advocacy efforts and to request input from members about their advocacy needs. To contact the LAAC, please email us at: