Unlicensed Psychometrist, Off-Site Supervision, and Report Signatures
Dr. Nguyen is a licensed psychologist in an Atlanta group practice. She supervises Ben, a master’s-level psychometrist who is not licensed. Ben administers the WAIS-V and MMPI-3, writes integrated reports that include diagnostic impressions, and signs them “Psychological Associate.” Dr. Nguyen reviews and co-signs reports about two weeks after Ben gives them to clients. Ben also conducts intake interviews alone; last week a client disclosed suicidal ideation and Ben made a safety plan without consulting Dr. Nguyen until the next day. Dr. Nguyen is often off-site and communicates by text. The practice bills Ben’s testing under Dr. Nguyen’s provider number. Ben asks to start seeing therapy clients for “supportive counseling” because he has a master’s degree.
1. What Board rule and licensure problems are presented by Ben’s testing and report practices?
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The central problem is unlicensed practice of psychology and inadequate supervision. Ben may perform limited technical tasks within his training and under appropriate supervision, but he may not independently practice psychology, formulate diagnostic impressions as an autonomous provider, or hold himself out as a psychologist. The title “Psychological Associate” can imply licensed status and should be reviewed against Georgia title-protection rules. Integrated reports that include diagnosis and interpretation are psychological services, not clerical scoring.
Dr. Nguyen’s review two weeks after reports are released is not adequate supervision for work that includes interpretation and diagnosis. The supervisor must be licensed, must actually direct and review the work, and should ensure that reports are not released until she has reviewed and signed them. Off-site texting is not a substitute for documented supervision. Billing under Dr. Nguyen’s provider number does not cure the problem; it may compound it if services were rendered outside the scope of lawful supervision. The Board could pursue both unlicensed practice and failure to supervise.
2. What corrective supervision plan should Dr. Nguyen implement immediately?
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She should stop Ben from releasing integrated reports or diagnostic impressions until she has reviewed them. She should revise the workflow so Ben completes testing and scoring, but Dr. Nguyen conducts or directly observes the clinical interview, interprets the data, and signs the final report before it goes to the client or referral source. If Ben is to continue intake work, Dr. Nguyen must provide direct supervision and ensure that risk disclosures are escalated immediately, not the next day.
She should create a written supervision contract that defines Ben’s title, permitted tasks, prohibited tasks, supervision frequency, documentation, emergency procedures, and who signs reports. Supervision should be scheduled and documented, with a mix of direct observation and case review. Ben should receive training on suicide risk and must have a way to reach Dr. Nguyen or a covering licensed psychologist in real time. The practice should correct billing to reflect only services lawfully delivered and should consult the Board or legal counsel about any reports already released.
3. May Ben begin providing “supportive counseling” under Dr. Nguyen’s supervision?
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No, not merely because he has a master’s degree. Psychotherapy is a core psychological service, and an unlicensed person may not provide it independently. Whether any limited counseling tasks can be delegated depends on Georgia law, Ben’s training, the setting, and the Board’s supervision rules; it is not a workaround for licensure. “Supportive counseling” is not a magic phrase that removes the requirement.
If Ben is to participate in treatment at all, Dr. Nguyen must define a narrow role, provide direct supervision, ensure informed consent that identifies Ben’s status and the supervisor’s role, and retain responsibility for the treatment plan. She should not let Ben carry a therapy caseload, make independent treatment decisions, or represent himself as a counselor or psychologist. If Ben wants to provide psychotherapy, the appropriate path is supervised experience toward the applicable license, with clear disclosure and close oversight.