Licensure as Guild Protection Is Infeasible

An integral goal of licensure is to protect a profession from others who would present themselves as qualified to perform the same work or services. The education and training of members in a licensed profession should be distinctive enough to establish initial boundaries that define the profession. However, in the case for licensure in I-O psychology, this type of guild protection is problematic for two reasons. First, the subject matter for I-O practice is not uniquely I-O psychology. The SIOP website lists 77 doctoral programs and 125 master's-level programs in I-O psychology, but these numbers pale in comparison to the 220 accredited doctoral programs (AASCB, 2003) and 972 MBA programs (Murray, Reference Murray2011) in business schools. Subdisciplines in these programs that share significant content with I-O psychology include human resources management, management consulting, organizational behavior, and organizational development. The argument that I-O psychologists are uniquely trained and that licensing would ensure higher standards of qualifications fails to consider the fact that many I-O psychologists train students outside psychology departments. SIOP's own membership lists more faculty in business schools than in departments of psychology. Furthermore, other disciplines such as labor relations, communications, human factors, and industrial engineering also include subject matter that overlaps with I-O content. The path to I-O practice is equifinal.

Second, other disciplines that share I-O subject matter have well-developed professional organizations that support the practice of I-O work. In particular, the Academy of Management has over 18,000 members with two of its largest divisions representing human resources and organizational behavior. In addition, the Society for Human Resource Management claims 285,000 professionals around the world. The practice of I-O psychology is often performed by others who are not psychologists, nor would they be required to be licensed. Efforts to require licensing for I-O psychologists are likely to create a competitive disadvantage for our profession and unduly burden young practitioners who would be required to pay substantial fees for periodic testing. Efforts to require others outside our discipline to be licensed are likely to fail. APA's own policy for state licensure of psychologists acknowledges that “Members of other established professions . . . may provide services that are similar or related to the scope of practice of psychology. They should be exempted from licensure on the condition that they not represent themselves to be psychologists” (APA, 2011, p. 10).

Graduate Education Implications

One of the biggest challenges of licensure is its effects on constraining and controlling graduate education. Those of you who are faculty in psychology departments with clinical (or counseling or school) programs will appreciate the burden this places on course requirements, clinical supervision, and the accreditation process. It is a resource sink hole. This is particularly problematic for the current discussion because IOP graduate education appears to be the point of leverage that the LCIOP Joint Task Force is targeting. As noted in our prior point, licensing based on the title “psychologist” or on the professional “behavior” of an I-O psychologist is increasingly problematic for licensing proponents. Many jurisdictions are shifting to an educational standard—APA accreditation—as a licensing criterion. APA does not accredit IOP programs, but the “ASPPB Model Licensing Act includes an ‘or equivalent’ provision” (Nagy, Silzer, & McPhail, email communication, October 20, 2016) that could serve as a substitute for APA accreditation. On that basis, the LCIOP Task Force set out to document the program requirements of 177 IOP graduate programs and to evaluate those requirements with the 1999 SIOP Education and Training Guidelines.Footnote ²

It is important to note that the LCIOP Task Force has indicated that: “It is not the LCIOP intention to use this information to advocate for requiring licensure of all I-O psychologists or to propose accreditation of I-O programs. This information will be used to communicate to jurisdictions about what they can expect when evaluating I-O psychology-trained candidates for licensure” (Nagy et al., email communication, October 20, 2016). Perhaps. But directing educational requirements—even as guidelines—is the first step on the slippery slope to regulation and specifying the nature of graduate coursework and experiences. Those guidelines are just that: guidelines. They are not graduate education specifications.

Two years ago, another target article in this journal essentially made a case for using the SIOP Education and Training Guidelines as credentialing or certification criteria (Byrne, Hayes, McPhail, Hakel, Cortina, & McHenry, Reference Byrne, Hayes, McPhail, Hakel, Cortina and McHenry2014). Many of us vigorously disagreed. In particular, Ford, Kozlowski, and Ryan (Reference Ford, Kozlowski and Ryan2014) argued that, among other limitations, such graduate education criteria stifle adaptation, innovation, and excellence. They do not actually raise standards, they lower them. “Certification sets minimal standards. In that sense, it provides cover for weak curricula and hobbles graduate training. It stifles innovation, and it limits practice. Anyone familiar with our sister discipline of clinical psychology will well appreciate the many problems that accrue when guild interests overwhelm academic and scientific values in the governance of the graduate curriculum” (Ford et al., Reference Ford, Kozlowski and Ryan2014, p. 46).

Follow the Money

Organizations use “political goals” as high-level statements about the purpose of the institution, which are designed to attract stakeholder support for its activities. The ASPPB website trumpets “Serving member jurisdictions by promoting excellence in regulation and advancing public protection in psychology” on its homepage. More detailed descriptions of its mission, vision, and values that elaborate on this banner statement are available on its Mission page. These are political goals.

Political goals are “where the rubber meets the sky.” Planning and action goals translate these political goals; its where “the rubber meets the road.” To understand what that means for ASPPB, one would need access to its financial statements. We do not have that access, but one can do some reasonable speculation. How does ASPPB accrue resources? It promotes the licensure of psychology practitioners across the USA and Canada. Once those regulations are adopted, it is the source of testing services: Examination for Professional Practice in Psychology (EPPP). The base examination fee is currently $600, not including appointment and rescheduling fees. According to one source (Nelson, 2016), the EPPP is the ASPPB's primary source of revenue, bringing in over $4 million in 2014. The ASPPB financial information provided by Nelson (2016) is quite interesting.

What is the purpose of bringing licensure to IOP? We are a relatively small profession compared to, say, clinical psychology. Moreover, the proportion of I-O psychologists who would be interested in licensure is likely very small. A 2006 survey of all SIOP members found that only 6% of respondents indicated that they intended to pursue licensure in the next 18 months (SIOP, 2006). Higher percentages of members interested in licensure that were reported in the LCIOP Joint Task Force article were based on SIOP Practitioner Needs Surveys that were not intended to survey the entire membership. Should the vast majority of I-O psychologists who are not interested in licensure be subject to graduate program restrictions in order to comply with licensure qualifications? Should licensure be mandated for I-O psychologists when similarly trained professionals from business schools and other disciplines freely practice our work? Licensure is an appropriate option for I-O psychologists whose practice can be viewed as having aspects that are similar to that of health service providers (e.g., individual assessment and/or executive coaching), but the majority of us who are better described as general applied psychologists should continue to be exempt from licensure requirements. Certainly, one needs to consider the strategic and/or unintended consequences of requiring licensure. This is food for thought as you mull the meaning and intent of the LCIOP Joint Task Force (2017) article and actions.