Website Credentials and an Unlicensed 'Associate MFT'

Maryland protects the titles 'licensed marriage and family therapist' and 'LCMFT' under Health Occupations Article, Title 17, Subtitle 3. A licensed psychologist may provide family therapy within the psychologist's scope, but may not call himself an LCMFT or 'Licensed Marriage and Family Therapist' unless separately licensed as an MFT. The phrase 'Associate MFT' is also risky: unless the Board has a specific registration or title for pre-licensure MFTs, J should use an accurate title such as 'post-master's MFT intern' and disclose supervision. The statement 'all clinicians are licensed marriage and family therapists' is false if J is unlicensed and Dr. R is not an LCMFT. The custody-evaluation advertising is separately misleading because forensic custody evaluations are not ordinary family therapy. The practice should take the site down or correct it immediately, remove inaccurate titles, list each clinician's actual license, and state that supervised interns provide services under supervision. Advertising must be truthful and not create a false impression of licensure, specialization, or results.

J may provide couples and family sessions only within a lawful pre-licensure arrangement and within the supervisor's scope. The owner is an LCPC, not necessarily an approved MFT supervisor. For MFT licensure hours, J needs supervision by a supervisor approved under the Board's MFT regulations; an LCPC may supervise for some purposes but may not satisfy MFT requirements unless approved. J must not diagnose or bill independently as an MFT. Billing under the owner's LCPC license may be permissible only if the owner actually provides the required supervision and the payer rules permit incident-to billing; the practice must verify. The caller should be told clearly that J is an intern, that J is supervised, and that J is not an LCMFT. If the son needs a diagnosis, the supervisor should be involved and the documentation should reflect who is responsible. The practice should also review whether it is accepting insurance for services that are not covered.

The practice should tell the caller: Dr. R is a licensed psychologist, not an LCMFT; J is a supervised intern, not a licensed MFT; and the practice will verify insurance benefits before the appointment. It should not promise 'LMFT reimbursement' if the rendering clinician is not an LCMFT. Custody evaluations are forensic services, not therapy, and they create a conflict if the same clinician is treating family members. The practice should not advertise 'family systems custody evaluations' unless it has qualified forensic evaluators and clear separation from treatment. If a parent calls for a custody evaluation, the practice should explain the difference between therapy and forensic evaluation, who retains the evaluator, and that the evaluator may be called to testify. The practice should not use therapy records for custody litigation without proper authorization or court order. The informed-consent form should disclose credentials, supervision, fees, insurance, confidentiality limits, and the role of any evaluator.