This correspondence is in response to your letter dated October 11, 2000, asking for an opinion from the Kentucky Board of Psychology on a Master’s level credential holder and employment duties and title.
Please keep in mind that this correspondence is an opinion of the Board based solely on the facts you have presented, which will be summarized below. The Board has authorized this opinion to you as an Opinion and Declaratory Ruling pursuant to KRS 13A.130(3) and KRS 13A.010(2)(b) as the agency with jurisdiction to interpret the statutes and regulations in KRS Chapter 319 and 201 KAR Chapter 26 which govern the practice of psychology in the Commonwealth of Kentucky.
I. Introduction.
You have written in sum that a local hospital has opened a geriatric psychiatric services unit. The staff psychologist at that facility is credentialed by the Board as a Master’s level psychologist. This psychologist is a Certified Psychologist with Autonomous Functioning as set forth in KRS 319.056(2).
You have inquired as to the job title and duties of such Certified Psychologist with Autonomous Functioning.
II. Whether a Certified Psychologist with Autonomous Functioning may be a director< of psychological services in a mental health facility.
The Board is presented with the question whether a Certified Psychologist with Autonomous Functioning may be recognized by the Board as a Director of Psychological Services for the hospital’s inpatient and partial geriatric psychiatry services. You have further stated that this psychologist’s role "is that of an independent consultant with no supervisory duties."
KRS 319.056(2) states in full: "A certified psychologist who has been granted autonomous functioning may function without supervision in areas in which he is certified. He shall not supervise certified psychologists or psychological associates." The Board interprets this prohibition on supervising other psychologists only to prohibit clinical supervision. This would not prevent a certified psychologist with autonomous functioning from performing discretionary, internal employment duties such as setting staff schedules, approving vacation schedules, completing employee evaluations, making various reports, and such.
Another relevant statute is the very definition of the practice of psychology. KRS 319.010(3) defines the "practice of psychology" to be the
rendering to individuals, groups, organizations, or the public any psychological service involving the application of principles, methods, and procedures of understanding, predicting, and influencing behavior, such as the principles pertaining to learning, perception, motivation, thinking, emotions, and interpersonal relationships; the methods and procedures of interviewing, counseling, and psychotherapy; of constructing, administering, and interpreting tests of mental abilities; aptitudes, interests, attitudes, personality characteristics, emotion, and motivation. The application of said principles and methods includes, but is not restricted to: diagnosis, prevention, and amelioration of adjustment problems and emotional and mental and nervous disorders of individuals and groups; educational and vocational counseling; the evaluation and planning for effective work and learning situations; and the resolution of interpersonal and social conflicts.
Nothing in KRS Chapter 319, and specifically in either of the two statutes cited above, would prevent a certified psychologist with autonomous functioning from being a director of psychological services at a mental health facility.
Keep in mind that like all psychologists a certified psychologist with autonomous functioning is limited in practice "to the areas of competence in which proficiency has been gained through education, training, and experience." 201 KAR 26:145 § 3(1).
III. Conclusion.
As the agency authorized by the Kentucky General Assembly to regulate the practice of psychology in this state, the Board is empowered to interpret its statutes and regulations. In summary, nothing in KRS Chapter 319 prevents a certified psychologist with autonomous functioning from serving as a director of psychological services at a mental health facility so long as that psychologist does not supervise other psychologists in their clinical work and so long as that psychologist limits his practice to the competency and proficiency gained through education, training, and experience.