Co-signing Around the License: The 'Dr. Tan, Psychologist' Report
Dr. Alan Reyes holds a PsyD and a Kansas psychologist license and owns a group practice in Wichita. His employee, Brooke Tan, holds a PhD in biblical counseling from an unaccredited online school and is not licensed by the Behavioral Sciences Regulatory Board. The practice website lists her as 'Dr. Brooke Tan, Psychologist' and advertises 'Licensed Psychology Center: IQ, ADHD, custody and personality evaluations for ages 4 through adult.' Brooke administers the WISC-V and MMPI-2, writes the reports, and Reyes reviews and co-signs each one; he says that makes the reports his. A local school district has also asked Brooke to test students for gifted eligibility at the school, and a divorce attorney has retained the practice for a custody evaluation. Reyes has never completed a custody evaluation, but Brooke has 'done a few' at a previous agency. Last month Brooke administered an IQ test to a 7-year-old and signed the report 'Dr. Tan, Licensed Psychologist.'
1. Identify every licensure, titling, and scope-of-practice problem in this practice and explain which fall within the Board's authority.
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At least four distinct problems. (1) Title violation: only a BSRB licensee may call themselves a psychologist or offer 'psychological' services, so 'Dr. Brooke Tan, Psychologist' on a website and on a signed report violates the title-protection provisions of the Kansas Psychologists' Licensing Act, K.S.A. 74-5301 et seq. (2) Unlicensed practice: administering and interpreting the WISC-V and MMPI-2 and writing psychological reports is the practice of psychology, which requires a Kansas psychologist or LMLP license. (3) Aiding unlicensed practice: Reyes's employment and co-signature facilitate it. (4) Misleading advertising. The 'Dr.' compounds the problem because the doctorate is in biblical counseling from an unaccredited school and is being used to imply psychology licensure. The Board may discipline Reyes and refer Brooke for unlicensed practice. The practice must stop advertising 'psychological' services, remove the title, and reassign testing to licensees. Document the corrections and the date each was made.
2. Reyes argues that his review and co-signature make Brooke's testing and reports lawful. Evaluate that argument and state what must change.
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No. Co-signature is not a licensing substitute. Supervision in Kansas is a relationship between a licensee and a trainee who is authorized to practice under that supervision; it does not launder unlicensed delivery of services to the public. Reyes remains ethically responsible for the work he delegates (APA 2.05), but responsibility does not transfer the act of practice itself. Practical consequences: every report Brooke signed misrepresents the provider; Reyes has created records that courts and schools will rely on; the 'review' appears nominal if Brooke writes and signs; and if Reyes did not examine the test data, he cannot attest to validity. Required changes: Brooke may not test, diagnose, or sign psychological reports; she may perform only clerical or explicitly non-psychological duties under a correct title. Reyes should identify which reports are already in circulation, consult an attorney and his malpractice carrier about corrective letters, and expect Board scrutiny of his supervision practices.
3. What should Reyes do about the custody evaluation and the school district request?
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Decline the custody evaluation. Competence under APA 2.01 is specific: custody work requires forensic training, familiarity with Kansas family law, multiple methods and collateral sources, and adherence to the Specialty Guidelines for Forensic Psychology. 'Brooke did a few at another agency' is not a qualification, and Brooke cannot perform any part of the evaluation unlicensed. A psychologist who treats a child and then offers custody opinions also risks crossing from therapist into advocate. The school district request is different in kind: Kansas limits school psychology practice to school psychologists credentialed through the Kansas State Department of Education and working within the school setting, so the district should use its own school psychologist; a private practice may not route gifted-eligibility testing to an unlicensed employee. If Reyes wants this work, he should obtain formal forensic training and supervision, use validated measures, and put fees and retainers in writing. For now, refer both matters out.