Letter from FACT to the Director of the Indiana State Psychology Board
September 15, 1998
Barbara M. McNutt, Director
Dear Ms. McNutt:
This letter is in response to the proposal that 318 "psychology tests" be restricted to licensed psychologists or exempt professionals pursuant to the Indiana State Psychology Board's interpretation of 1C 25.33-1-3(g). The National Fair Access Coalition on Testing (FACT) objects to such a list and believes that there is no single test on this list that warrants being restricted solely to the profession of psychology.
The Fair Access Coalition on Testing is a national coalition of associations and organizations representing over 500,000 professionals who are opposed to unreasonable restrictions on assessment practices by state psychology boards solely on the basis of licensure. It is our position that access to tests and assessment tools should be a function of training and experience. Many disciplines utilize various test instruments and have done so for decades. State licensing boards and national certifying bodies require considerable training and experience to utilize assessment instruments. All professions have ethical codes which require their practitioners to practice only within the scope of their training and experience. In short, we hold that there is no logical justification to allow only licensed psychologists (who may or may not have the necessary training and experience in the use of the listed tests) to perform certain testing, when other practitioners may have equal or superior training in the use of "psychological tests." Some of the listed tests have been developed by professionals who are not licensed psychologists, and for use by non-psychologists.
We find no national professional body which agrees with the Indiana State Psychology Board’s (ISPB) view on this subject. We must then assume that the ISPB proposed a regulation that is not in step with the thinking of scholars in their own discipline. We have enclosed copies of "Assessment of Test User Qualifications" (American Psychologist, 1995), an American Psychological Association (APA) publication, and "Test User Qualifications" (Science Directorate, APA, 1988) to point out that it is the qualifications of the test user, not the profession, which should determine test use. Since Indiana licensed psychologists must pass national examinations based upon national standards of practice and training set by APA, it seems unrealistic to ignore their studied conclusion.
Restricting professionals from use of tools of their livelihood seems a matter of serious legislative concern. We appeal to your better judgment to desist from trying to capture an area of employment in the name of public protection. We know of no instance where a profession by law has, after the fact, assumed the power to control access to materials developed by, and used by, other professions. And, we know of no profession which has been shown to harm the public by use of psychological testing. Surely independent actors, whether professional or not, may abuse testing, but your attempt to restrict professional access to testing is unprecedented in the United States.
We therefore request that the Indiana State Board of Psychology reconsider their proposition that the 318 listed tests be restricted to licensed psychologists and the few exempt professionals. We are making our organization and individual members aware of this situation and expect that they will also be contacting your Board with their concerns.
Thomas W. Clawson, Ed.D.