Verifying Out-of-State Supervision for a Provisional Psychologist
Dr. Elena Reyes has been a Missouri-licensed psychologist for eight years and owns a group practice in St. Louis. Mateo, 34, holds a Missouri provisional psychologist license and needs postdoctoral supervised hours. For six months he saw 22 clients in Missouri while his supervisor, Dr. Han, was licensed only in Illinois and supervised by video. Mateo now asks Reyes to sign the Missouri verification form for those 22 clients and to backdate supervision to cover a two-month gap. Reyes also wants Mateo to work as a 1099 contractor, paid 55% of collections, seeing Reyes’s referrals; they have no written supervision agreement. Mateo asks that weekly group staff meetings count as individual supervision because his 18-month-old daughter has medical appointments. Reyes is willing because the practice is busy and she has not checked whether the board approved Dr. Han.
1. Can Dr. Reyes sign the verification form for Dr. Han’s six months of supervision and backdate supervision? Explain.
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No. Missouri supervised hours must be obtained under a supervisor who meets the board’s requirements, including holding a Missouri psychologist license unless the board has approved an equivalent arrangement. Dr. Han was licensed only in Illinois and was not approved by the Missouri board, so Reyes cannot attest to supervision she did not provide. Signing or backdating a verification form would be falsification and a disciplinary violation, even if the clinical work was real. Reyes should tell Mateo to submit only accurate, contemporaneous documentation and contact the board about whether any prior hours can be accepted. Mateo may need to complete additional supervised hours.
2. What supervision and employment problems arise from the 1099 arrangement, 55% split, and use of group meetings as individual supervision?
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The arrangement mixes employment, financial, and evaluative power in one relationship, creating a multiple-relationship risk. The board expects a written supervision agreement defining the supervisee’s duties, the supervisor’s authority, the frequency and type of supervision, documentation, and evaluation. A 55% productivity split can pressure the trainee to see too many clients and may exploit the trainee; Reyes must ensure it does not interfere with supervision. Group staff meetings do not automatically substitute for required individual supervision; the board’s rules specify the form and amount of supervision. Reyes should not count meetings unless the rule allows it and the meetings meet the definition. She should consult the board and revise the contract.
3. Mateo’s provisional license lapses for 10 days before renewal. He has four scheduled clients. What should Reyes do?
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Reyes must not allow Mateo to provide psychological services under a lapsed license, even for established clients. The provisional license is the legal authority to practice under supervision; a lapse means he is unlicensed. Reyes should reschedule or transfer the four clients, document the reason, and ensure continuity of care. She can provide supervision and administrative contact but not bill for Mateo’s clinical services. Allowing him to see clients would expose both to discipline and could create insurance fraud. Reyes should verify licensure status before each billing cycle.