Supervision and Delegation: Unlicensed Practice and Informed Consent
Dr. C, a licensed psychologist in Fairbanks, supervises a pre-doctoral intern, Ms. D, who has not yet obtained her license. Dr. C asks Ms. D to conduct intake assessments and provide individual therapy to clients at a community mental health center. Dr. C reviews Ms. D's cases weekly and is available for consultation. However, Dr. C is often off-site and rarely observes sessions. Ms. D has been seeing a client with complex trauma for three months without Dr. C ever meeting the client. The client later files a complaint with the Alaska Board of Psychology, alleging that Ms. D was not qualified and that Dr. C did not properly supervise.
1. Does Dr. C's supervision meet the requirements for delegation to an unlicensed intern under Alaska law?
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Likely not. Alaska regulations (12 AAC 60.180) require that a supervising psychologist provide direct supervision and ensure that the supervisee's work is reviewed. While weekly case review is part of supervision, the supervisor must also have sufficient contact to ensure competence. Dr. C's absence and lack of direct observation may violate the requirement for adequate supervision. The Board expects supervisors to: (1) ensure the supervisee is qualified for the tasks assigned; (2) provide regular, documented supervision; (3) be available for emergencies; (4) review and co-sign treatment plans and notes. Dr. C should have met the client, observed sessions, or used live supervision. The fact that Dr. C never met the client suggests inadequate oversight. Dr. C may be subject to disciplinary action for failing to supervise properly.
2. What are Dr. C's ethical obligations regarding informed consent and client rights?
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Dr. C must ensure that clients are informed that Ms. D is a supervised intern and that Dr. C is the supervising psychologist. APA Ethics Standard 3.05 requires informed consent for supervision, and Standard 10.01 requires informed consent to therapy. Clients should be told: (1) Ms. D's status and qualifications; (2) that Dr. C is responsible for oversight; (3) how to contact Dr. C; (4) limits of confidentiality. Dr. C should also ensure that clients are informed of their right to ask questions and to request a different provider. The failure to disclose supervision may violate informed consent. Dr. C should document that this information was provided. Additionally, Dr. C should review and co-sign Ms. D's notes and ensure that the client's treatment is appropriate.