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THE STATE EDUCATION DEPARTMENT / THE UNIVERSITY OF THE STATE OF NEW YORK / ALBANY, NY 12234

TO:	The Honorable the Members of the Board of Regents
FROM:	Johanna Duncan-Poitier
COMMITTEE:	Higher Education and Professional Practice
TITLE OF ITEM:	Proposed Promulgation of Regulations of the Commissioner of Education Relating to Requirements for Licensure in Marriage and Family Therapy
DATE OF SUBMISSION:	January 4, 2005
PROPOSED HANDLING:	Approval
RATIONALE FOR ITEM:	To Implement Statute
STRATEGIC GOAL:	Goals 2 and 3
AUTHORIZATION(S):

SUMMARY:

Attached for approval is a proposed addition of section 52.33 and Subpart 79-10 to the Regulations of the Commissioner of Education, relating to requirements for licensure in marriage and family therapy. Supporting materials for the proposed regulation are available upon request from the Secretary to the Board of Regents.

The purpose of the proposed regulation is to implement the provisions of Article 163 of the Education Law by establishing education, experience, and examination requirements for licensure in the new licensed profession of marriage and family therapy, requirements for limited permits to practice this profession, and standards for registered college programs leading to licensure in this field. Marriage and family therapy is one of four new professions, under the State Board for Mental Health Practitioners, established by Chapter 676 of the Laws of 2002.

The Higher Education and Professional Practice Committee discussed the proposed regulation at its September and December meetings. A Notice of Proposed Rule Making concerning the regulation was published in the State Register on August 25, 2004. In response to public comments, the proposed regulation was revised in the areas of education, experience, and special provisions for licensing prior to January 1, 2006, and a Notice of Revised Rule Making was published in the State Register on December 1, 2004. An Assessment of Issues Raised by Public Comment since the publication of the revised rule making is attached.

I recommend that the Board of Regents take the following action:

VOTED: That section 52.33 and Subpart 79-10 of the Regulations of the Commissioner of Education be added, as submitted, effective February 3, 2005.

Attachments

AMENDMENT TO THE REGULATIONS OF THE COMMISSIONER OF EDUCATION

Pursuant to sections 207, 210, 6501, 6504, 6507, 6508, 8403, 8409, and 8411 of the Education Law.

1. Section 52.33 of the Regulations of the Commissioner of Education is added, effective February 3, 2005, as follows:

52.33 Marriage and family therapy.

In addition to meeting all applicable provisions of this Part, to be registered as a program recognized as leading to licensure in marriage and family therapy, which meets the requirements of section 79-10.1 of this Title, the program shall:

(a) be a program in marriage and family therapy leading to a master's or doctoral degree, which includes at least 45 semester hours, or the equivalent, of study;

(b) contain curricular content that includes but is not limited to each of the following content areas:

(1) the study of human development, including individual, child and family development, at least three semester hours;

(2) marriage and family therapy clinical knowledge, including but not limited to psychopathology, at least twelve semester hours;

(3) marriage and family therapy theoretical knowledge, at least six semester hours;

(4) family law;

(5) research, at least three semester hours; and

(6) professional ethics, at least three semester hours; and

2. Subpart 79-10 of the Regulations of the Commissioner of Education is added, effective February 3, 2005, to read as follows:

Subpart 79-10

Marriage and Family Therapy

79-10.1 Professional study of marriage and family therapy.

(a) As used in this section, acceptable accrediting agency shall mean an organization accepted by the department as a reliable authority for the purpose of accrediting marriage and family therapy programs, having accreditation standards that are substantially equivalent to the requirements for programs registered as leading to licensure in this field pursuant to section 52.33 of this Title, and applying its criteria for granting accreditation of programs in a fair, consistent, and nondiscriminatory manner.

(b) To meet the professional education requirement for licensure as a marriage and family therapist, the applicant shall present satisfactory evidence of completing:

(1) a master's or doctoral program in marriage and family therapy registered as leading to licensure in this field, pursuant to section 52.33 of this Title, or a master's or doctoral program in marriage and family therapy that is accredited by an acceptable accrediting agency, or a master's or doctoral program in marriage and family therapy that is substantially equivalent to such a registered or accredited program, as determined by the department; or

(2) a graduate degree program in an allied mental health field acceptable to the department, including but not limited to a graduate degree program in social work, psychology, and mental health counseling, and additional graduate level coursework, if needed, which together are determined by the department to provide the substantial equivalent professional educational preparation as that obtained from a master's or doctoral program in marriage and family therapy registered as leading to licensure in this field, pursuant to section 52.33 of this Title; or

(3) a program located outside the United States and its territories that is recognized by the appropriate civil authorities of the jurisdiction in which the program is located as a program that prepares an applicant for the professional practice of marriage and family therapy, has been verified in accordance with subdivision (c) of section 59.2 of this Title, and which is determined by the department to be substantially equivalent to a master's or doctoral program in marriage and family therapy registered by the department as leading to licensure in this field, pursuant to section 52.33 of this Title, or to a master's or doctoral program in marriage and family therapy accredited by an acceptable accrediting agency.

79-10.2 Professional licensing examinations.

(a) Each candidate for licensure as a licensed marriage and family therapist shall pass an examination:

(1) that is offered by an organization determined by the department to have satisfactory administrative and psychometric procedures in place to offer the licensing examination; and

(2) that the department determines adequately tests marriage and family therapy proficiency at the master's degree level and adequately measures the candidate's knowledge concerning practice as a licensed marriage and family therapist as defined in subdivision (1) of section 8403 of the Education Law.

(b) Requirements for admission to examination for licensure as a licensed marriage and family therapist. To be admitted to the licensing examination, the candidate shall be required to:

(1) file an application for licensure with the department;

(2) pay the fee for the initial license and the fee for the first registration period, as prescribed in section 8403(3)(g) of the Education Law;

(3) present satisfactory evidence of having met the education requirement for licensure as a licensed marriage and family therapist, as prescribed in section 79-10.1 of this Subpart, including receipt of the degree.

(c) Passing score. The passing score for the examination for licensure as a licensed marriage and family therapist shall be determined by the State Board for Mental Health Practitioners.

79-10.3 Experience requirement.

(a) An applicant for licensure as a licensed marriage and family therapist shall meet the supervised experience requirement set forth in this section.

(b) An applicant who has met the education requirement prescribed in section 79-10.1 of this Subpart through completing a master's or doctoral program registered by the department as leading to licensure in this field or an equivalent program in marriage and family therapy shall complete at least 1,500 client contact hours of supervised clinical experience in a setting acceptable to the department. That experience may include supervised client contact clock hours completed as part of the program in marriage and family therapy or after completing such program, in accordance with the requirements of section 52.33 of this Title.

(c) An applicant who has met the education requirement prescribed in section 79-10.1 of this Subpart through completing a graduate degree program in an allied mental health field and additional graduate level coursework, if needed, shall complete at least 1,500 client contact clock hours of supervised clinical experience at a setting acceptable to the department, which all must be completed after completing the graduate degree program in the allied mental health field.

(d) Supervision of the experience. The experience shall be supervised in accordance with the requirements of this subdivision.

(1) Supervision of the experience shall consist of contact between the applicant and supervisor during which:

(i) the applicant apprises the supervisor of the assessment and treatment of each client;

(ii) the applicant’s cases are discussed with the supervisor;

(iii) the supervisor provides the applicant with oversight and guidance in the application of marriage and family therapy theories, techniques and supervisory processes to assist the applicant in developing skills necessary to practice marriage and family therapy, which emphasizes the treatment of relational, systemic dynamics in therapy and focuses on special training and techniques required for treating more than one person in therapy; and

(iv) the supervisor provides an average of one hour per week or two hours every other week of in-person individual or group supervision.

(2) Qualifications for supervisors of the required experience. The supervisor of the experience shall meet each of the following requirements:

(i) The supervisor shall have completed a master's or higher degree program in marriage and family therapy, in the subject of the field in which the supervisor is licensed as prescribed in subparagraph (iii) of this paragraph, or in another field related to the field of marriage and family therapy as determined by the department.

(ii) The supervisor shall have engaged in the practice of marriage and family therapy for three years or the part-time equivalent. For purposes of this subparagraph, practice on a full-time basis shall mean 960 clock hours in the practice of marriage and family therapy, earned over a 52-week period;

(iii) The supervisor shall be licensed and registered in New York State to practice marriage and family therapy, medicine, as a physician assistant, psychology, licensed clinical social work, or as a registered professional nurse or nurse practitioner, pursuant to Articles 163, 131, 131-b, 139, 153, or 154 of the Education Law, respectively; or be an individual with equivalent qualifications as determined by the department; or for applicants who apply for licensure in marriage and family therapy on or before December 31, 2007, be an individual with certification or registration by an acceptable national certifying or registering body for marriage and family therapists as a clinical supervisor. To be acceptable to the department, the national certifying or registering body must be recognized nationwide as an organization that certifies or registers marriage and family therapists throughout the United States based upon a review of their qualifications to practice marriage and family therapy and must have adequate standards for the review of the applicant's qualifications for practicing marriage and family therapy, as determined by the department. Such standards must include standards for the review of the applicant's education and experience for practicing marriage and family therapy and may include an examination requirement.

(e) Setting for the experience. For a setting for the clinical experience to be acceptable to the department, it shall meet the following requirements:

(1) The setting shall be a location at which legally authorized individuals provide services that constitute the practice of marriage and family therapy, as defined in section 8403(1) of the Education Law.

(2) The setting in which the experience is gained shall be responsible for the services provided by individuals gaining experience for licensure.

(3) The setting shall not be a private practice owned or operated by the applicant.

79-10.4 Limited permits. As authorized by section 8409 of the Education Law, the department may issue a limited permit to practice marriage and family therapy in accordance with the requirements of this section.

(a) An applicant for a limited permit to practice marriage and family therapy shall:

(1) file an application for a limited permit with the department and pay the application fee, as prescribed in section 8409(3) of the Education Law;

(2) meet all requirements for licensure as a marriage and family therapist, except the examination and/or experience requirements; and

(3) be under the supervision of a supervisor acceptable to the department in accordance with the requirements of section 79-10.3 of this Subpart.

(b) The limited permit in marriage and family therapy shall be issued for specific employment setting(s), acceptable to the department in accordance with the requirements of section 79-10.3 of this Subpart.

(c) The limited permit in marriage and family therapy shall be valid for a period of not more than 12 months, provided that the limited permit may be extended for an additional 12 months at the discretion of the department if the department determines that the permit holder has made good faith efforts to successfully complete the examination and/or experience requirements within the first 12 months but has not passed the licensing examination or completed the experience requirement, or has other good cause as determined by the department for not completing the examination and/or experience requirement within the first 12 months, and provided further that the time authorized by such limited permit and subsequent extension shall not exceed 24 months total.

79-10.5 Classifications systems. A licensed marriage and family therapist may use accepted classifications of signs, symptoms, dysfunctions and disorders, such as the Diagnostic and Statistical Manual of Mental Disorders, published by the American Psychiatric Association, or an equivalent classification system as determined by the department, provided that such use is consistent with the practice of marriage and family therapy as defined in section 8403(1) of the Education Law.

79-10.6 Special provisions.

(a) Alternative requirements. In accordance with section 8411(2)(a) of the Education Law, an applicant who does not meet the requirements for licensure as a marriage and family therapist as prescribed in section 8403(3) of the Education Law, may qualify for a license as a marriage and family therapist through meeting the alternative requirements prescribed in either paragraphs (1), (2), or (3) of this subdivision, provided that the applicant meets all such requirements on or before January 1, 2006.

(1) Alternative route one. An applicant may qualify for a license as a marriage and family therapist through meeting the following alternative requirements. The applicant shall:

(i) file an application for licensure by January 1, 2006 and pay the fee for the initial license and the fee for the first registration period, as prescribed in section 8403(3)(g) of the Education Law;

(ii) be of good moral character as determined by the department;

(iii) be at least 21 years of age;

(iv) have completed a master's or higher degree program in marriage and family therapy or in a related field such as social work, psychology, or mental health counseling that is registered by the department pursuant to Part 52 of this Title, or is an equivalent program as determined by the department, provided that the program includes:

(a) coursework that contains curricular content in the study of:

(1) human development, including individual, child and family development;

(2) marriage and family therapy clinical knowledge;

(3) marriage and family therapy theoretical knowledge;

(4) research; and

(b) a supervised practicum in marriage and family therapy; and

(v) after completing the master's or higher degree program prescribed in subparagraph (iv) of this paragraph, have engaged in the practice of marriage and family therapy, as defined in section 8403(1) of the Education Law, for at least 1,500 clock hours.

(2) Alternative route two. An applicant may qualify for a license as a marriage and family therapist through meeting the following alternative requirements. The applicant shall:

(ii) be of good moral character as determined by the department;

(iii) be at least 21 years of age;

(iv) have completed a baccalaureate or higher degree program in marriage and family therapy or in a related field such as social work, psychology, or mental health counseling, that is registered by the department pursuant to Part 52 of this Title, or is an equivalent program as determined by the department, provided that the applicant demonstrates the completion of coursework within such a program that contains curricular content in the study of human development, marital and family therapy, and research;

(v) after completing the baccalaureate or higher degree program prescribed in subparagraph (iv) of this paragraph, have engaged in the practice of marriage and family therapy, as defined in section 8403(1) of the Education Law, on a full-time basis for seven years of the immediately preceding ten years prior to application for licensure. For purposes of this subparagraph, practice on a full-time basis shall mean 960 clock hours in the practice of marriage and family therapy, earned over a 52-week period;

(vi) have submitted certifications from three individuals endorsing the applicants good professional ethics and clinical competence to practice of marriage and family therapy. Such certifications shall be submitted on forms prescribed by the department. The individual making the certification shall meet the qualifications for supervisors of the experience requirement, as prescribed in section 79-10.3(d)(2), except that such individual may be certified or registered by a national certifying or registering body for marriage and family therapists instead of being specifically certified or registered as a clinical supervisor by such body; and

(vii) have met one of the following three requirements:

(a) after completing the baccalaureate or higher degree program prescribed in subparagraph (iv) of this paragraph, have three years of supervised experience in the practice of marriage and family therapy, which may be part of the seven years of experience required in subparagraph (v) of this paragraph. The supervisor of the experience must meet the qualifications for a supervisor of required experience prescribed in section 79-10.3(d)(2) of this Subpart, or

(b) be certified or registered by a national certifying or registering body for marriage and family therapy, acceptable to the department. To be acceptable to the department, the national certifying or registering body must be recognized nationwide as an organization that certifies or registers marriage and family therapists throughout the United States based upon a review of their qualifications to practice marriage and family therapy and must have adequate standards for the review of the applicant's qualifications for practicing marriage and family therapy, as determined by the department. Such standards must include standards for the review of the applicant's education and experience for practicing marriage and family therapy and may include an examination requirement; or

(c) complete an acceptable post-baccalaureate program in marriage and family therapy or a related field from an institute chartered by the Board of Regents, or an institution authorized by its charter or by the Board of Regents to confer degrees in New York State, or the equivalent as determined by the department, provided that such program contains curricular content in the study of:

(1) human development, including individual, child and family development;

(2) marriage and family therapy clinical knowledge;

(3) marriage and family therapy theoretical knowledge; and

(4) research.

(3) Alternative route three. An applicant may qualify for a license as a marriage and family therapist through meeting the following alternative requirements. The applicant shall:

(ii) be of good moral character as determined by the department;

(iii) be at least 21 years of age;

(v) after completing the baccalaureate or higher degree program prescribed in subparagraph (iv) of this paragraph, have engaged in the practice of marriage and family therapy, as defined in section 8403(1) of the Education Law, on a full-time basis for 10 years of the immediately preceding 15 years prior to application for licensure. For purposes of this subparagraph, practice on a full-time basis shall mean 960 clock hours in the practice of marriage and family therapy, earned over a 52-week period;

(vi) have submitted certifications from five individuals endorsing the applicants good professional ethics and clinical competence to practice marriage and family therapy. Such certifications shall be submitted on forms prescribed by the department. The individual making the certification shall meet the qualifications for supervisors of the experience requirement, as prescribed in section 79-10.3(d)(2), except that such individual may be certified or registered by a national certifying or registering body for marriage and family therapists instead of being specifically certified or registered as a clinical supervisor by such body.

(b) In accordance with section 8411(2)(b) of the Education Law, an applicant who meets all requirements for licensure as a marriage and family therapist as prescribed in section 8403(3) of the Education Law, except for the examination requirement, may qualify for a license as a marriage and family therapist through meeting the requirements of this subdivision, provided that the applicant meets these requirements on or before January 1, 2006. The applicant shall:

(1) file an application for licensure by January 1, 2006 and pay the fee for the initial license and the fee for the first registration period, as prescribed in section 8403(3)(g) of the Education Law;

(2) meet all requirements for the license as a marriage and family therapist prescribed in section 8403(3) of the Education Law, except the examination requirement; and

(3) either:

(i) have certification or registration by a national certifying or registering body for marriage and family therapists, acceptable to the department. To be acceptable to the department, the national certifying or registering body must be recognized nationwide as an organization that certifies or registers marriage and family therapists throughout the United States based upon a review of their qualifications to practice marriage and family therapy and must have adequate standards for the review of the applicant's qualifications for practicing marriage and family therapy, as determined by the department. Such standards must include standards for the review of the applicant's education and experience for practicing marriage and family therapy and may include an examination requirement. For use under this subdivision, such certification or registration need not be current but shall not have been revoked for misconduct and/or unethical activities. For documentation of the applicant's certification or registration status to be sufficient, the national certifying or registering body must submit documentation verifying the applicant's certification or registration status directly to the department; or

(ii) if there is no national certifying or registering body for marriage and family therapists acceptable to the department as prescribed in subparagraph (i) of this paragraph, have engaged in the practice of marriage and family therapy, as defined in section 8403(1) of the Education Law, on a full-time basis for five years of the immediately preceding eight years prior to application for licensure. For purposes of this subparagraph, practice on a full-time basis shall mean 960 clock hours in the practice of marriage and family therapy, earned over a 52-week period.

PROPOSED PROMULGATION OF SECTION 52.33 and SUBPART 79-10 OF THE REGULATIONS OF THE COMMISSIONER OF EDUCATION PURSUANT TO SECTIONS 207, 210, 6501, 6504, 6507, 6508, 8403, 8409, and 8411 OF THE EDUCATION LAW RELATING TO PROFESSIONAL LICENSURE IN MARRIAGE AND FAMILY THERAPY

ASSESSMENT OF iSSUES RAISED BY pUBLIC cOMMENT

The proposed rule was published as a revised rule making on December 1, 2004. Below is a summary of written comments received by the State Education Department concerning the proposed rule, which were not addressed in the previously published Assessment, and the Department's response.

COMMENT: The proposed regulations should require the supervisor of the experience requirement to be qualified as supervisors by the American Association for Marriage & Family Therapy (AAMFT). Unlike other professions, the supervision of marriage and family therapy requires sub-specialty training.

RESPONSE: In response to public comment, the regulations have been strengthened to increase requirements for supervisors of the applicant's experience. Such individuals are required to have master's level education and three year's experience in the practice of marriage and family therapy. In addition, they must be licensed in New York State in specified fields, which permit them to practice marriage and family therapy in New York State, or meet equivalent qualifications. The regulation would permit the acceptance of a supervisor's credential issued by an acceptable national certifying or registering body as a substitute for licensure and evidence of supervisory competence until January 1, 2008. This will accommodate the fact that marriage and family therapy is a new licensed profession in New York State. The regulations have adequate standards to ensure the qualifications of supervisors of the experience requirement for licensure.

COMMENT: The proposed regulation would not allow an applicant to meet the experience requirement in a private practice. AAMFT approved supervisors are taught to ask for audiotapes and videotapes of patient treatment to monitor therapy in the post-degree phase. Limiting the practice setting accomplishes little.

RESPONSE: The proposed regulation does not prohibit the applicant from gaining experience for licensure in a private setting. It only prohibits the setting from being a private practice owned or operated by the applicant. This helps to ensure the quality of the experience.

COMMENT: The State Education Department does not have the authority to prohibit in regulation the experience requirement to be met in a private practice owned or operated by the applicant.

RESPONSE: The Department has the authority to regulate the setting of the experience requirement for licensure in marriage and family therapy. Education Law section 8403(3)(c) requires the applicant to meet an experience requirement "in accordance with the commissioner' s regulations." The regulation at issue will help to ensure the quality of the experience.

COMMENT: Experience obtained prior to licensure should not count towards the three-years of experience necessary to become a qualified supervisor of the experience requirement.

RESPONSE: This is a new licensed profession and the Department needs the flexibility to consider pre-licensure experience in the determination of qualified supervisors.

COMMENT: The requirements for supervisors of the experience required for licensure in marriage and family therapy are insufficient. Such supervisors should be required to meet additional experience and coursework requirements relating to supervision of marriage and family therapists.

RESPONSE: The regulation has been revised to increase requirements for supervisors of the required experience for licensure. Such supervisors must have completed a master's or higher degree in marriage and family therapy or a related field, have engaged in the practice of marriage and family therapy for three years, and be licensed to practice marriage and family therapy or be licensed in a profession that is exempt from licensure, or be an individual with equivalent qualifications, or until December 31, 2007 be appropriately certified as a clinical supervisor. The Department does not believe it necessary to add additional education and experience requirements for supervisors.

COMMENT: The regulations should specify that supervisors of the experience requirement who are licensed in other fields and are exempt from licensure under Article 163 should be governed by the practice requirements of their particular profession.

RESPONSE: The supervisor who is licensed in another profession is bound by the statutory and regulatory requirements of that profession. It is unnecessary to repeat this requirement in these regulations.

COMMENT: The curriculum prescribed in the regulation for registered programs leading to licensure does not adequately provide subject matter knowledge in areas needed for practice.

RESPONSE: The subject area requirements for registered programs leading to licensure are specified in the statute. Therefore, the regulation must include these subjects as mandatory requirements for registered programs leading to licensure. These requirements provide adequate subject matter preparation for licensure.

COMMENT: The regulations for registered programs leading to licensure in marriage and family therapy should specify detailed requirements for internships, including paid and unpaid internships, flexibility for working students, supervision requirements, and diversity of placements.

RESPONSE: The regulations require registered programs leading to licensure in marriage and family therapy to include a supervised practicum of at least 300 client clock hours. Prior to registration, the Department will review the adequacy of the practicum, including the adequacy of supervision and placements. The Department does not believe it necessary to specify in regulation additional requirements for the practicum.

COMMENT: We strongly support the regulation's flexibility in permitting an applicant to meet the education requirement for licensure through completion of a graduate degree program in an allied mental health field and additional graduate level coursework, if needed.

RESPONSE: No response is necessary.

COMMENT: The regulations do not allow for a number of well established, nationally certified marriage and family therapists to qualify for a license through alternative requirements.

RESPONSE: The regulations provide four alternative routes to licensure in marriage and family therapy, for applicants who apply and meet the requirements by January 1, 2006. The regulations provide ample opportunities for applicants who are currently practicing in this field to become licensed through these alternative requirements.

COMMENT: The requirements in the special provisions that permit licensure with baccalaureate education should require the applicant to pass a licensure examination.

RESPONSE: The special provisions are only available until January 1, 2006, and are designed to assist individuals who have practiced in this field for many years to become licensed. Alternatives two and three of the special provisions require applicants to be baccalaureate-educated, complete prescribed coursework, have extensive experience in the field, and obtain certifications from qualified individuals that endorse the applicant's professional ethics and clinical competence. These requirements establish satisfactory standards for licensure. An additional examination requirement is unnecessary.

COMMENT: We are opposed to baccalaureate degree under any circumstances as the basis for licensure in marriage and family therapy because the statutory authorizing language for obtaining a license through the alternative method requires the criteria for licensure to be substantially equivalent to the regular requirements for licensure.

RESPONSE: Education Law section 8411(2)(a) provides the statutory basis for establishing the alternative requirements for licensure in marriage and family therapy. Section 8411(2)(a) acknowledges that the applicant "does not meet the requirements for licensure within this article." It authorizes the establishment of "alternative criteria determined by the department to be substantially equivalent of such criteria."

The regulation includes alternative requirements for licensure in this new profession for applicants who have practiced marriage and family therapy for many years prior to the imposition of this new licensure requirement. The special provisions are only available for a limited time, until January 1, 2006. Alternatives two and three of the special provisions permit licensure of baccalaureate-educated individuals. Such applicants must complete prescribed coursework and have significant experience in marriage and family therapy. In addition, they must obtain certifications from qualified individuals that endorse their professional ethics and clinical competence.

The Memorandum in Support of the enabling legislation makes it clear that the sponsors of the Legislation did not intend to unfairly disenfranchise individuals who were practicing the profession prior to the imposition of the licensure requirement. The Memorandum states: "The Bill is not intended to disenfranchize any individuals presently practicing mental health counseling, marriage and family therapy, creative arts therapy or psychoanalysis that meet standards set forth in the bill or their substantial equivalent as determined by SED." In developing these alternative requirements, the Department consulted with the State Legislature to ensure that the requirements were consistent with legislative intent that authorized the Department to establish alternative criteria for licensure.

The prescribed requirements, taken together, establish standards that are substantially equivalent to the regular requirements for licensure. The alternative requirements for licensure will ensure that adequacy of preparation for licensure in the field of marriage and family therapy, while easing the transition to licensure for individuals who have practiced this profession for many years. The State Education Department has statutory authority to establish such alternative requirements in regulation.

The Honorable the Members of the Board of Regents