Maryland MFT Practice Act and COMAR Framework
Two layers of law
- The Health Occupations Article, Title 17, Subtitle 3 establishes MFT licensure and delegates administration to the State Board of Professional Counselors and Therapists.
- COMAR Title 10, Subtitle 58, Chapter 03 supplies operational rules: definitions, application, supervised experience, examination, renewal, conduct, and discipline.
- The statute controls; a regulation or Board policy cannot create a license category or waive a statutory prerequisite.
Board authority the exam tests
- Issue, renew, deny, suspend, revoke, reprimand, and place licensees on probation with conditions.
- Approve supervisors and qualifying programs, investigate complaints, subpoena records, and seek injunctive relief.
- Adopt regulations through notice-and-comment rulemaking and decide contested cases through fair procedure.
Worked example
An applicant has a qualifying MFT master's degree but has not completed supervised postgraduate practice. She applies for the clinical license and asks the Board to count her internship and waive the rest. The Board must deny the LCMFT because the supervised-experience prerequisite is unmet; it may issue an LGMFT if the graduate-level requirements and supervision plan are satisfied. Internship hours count only as COMAR and the application forms allow. The Board cannot grant the clinical license by policy preference.
Traps
- Treating a Board handbook as if it were the statute; check the statute and COMAR.
- Assuming the Board can waive degree, exam, or hour requirements as an accommodation.
- Using counselor or art-therapy rules for MFT questions; each occupation has separate provisions.
- Confusing rulemaking authority with adjudicatory authority in a contested case.