Comments of the American Psychiatric Association to the



Comments of the American Psychiatric Association to the

Oregon Work Group on Prescriptive Authority for Licensed Psychologists

On the Draft Bill Relating to Prescriptive Authority for Licensed Psychologists

Submitted to the Work Group

January 11, 2010

The American Psychiatric Association (APA), the medical specialty society representing more than 38,000 psychiatric physicians in Oregon and nationwide, appreciates the opportunity to submit these comments concerning the draft bill relating to prescriptive authority for licensed psychologists. This draft is the product of the State’s Work Group on Prescriptive Authority for Licensed Psychologists, created by enactment in 2009 of House Bill 2702.

The APA compliments the Work Group on its diligence in fulfilling its assigned task. Of equal importance is its demonstrably clear understanding that mental illnesses are physical illnesses and, as such, that providers of treatment for persons with mental illnesses must have sound medical education and training. The resulting document is a description for a training program that closely parallels that required for licensure as a Nurse Practitioner.

This raises an overarching question. If the work group is recommending that psychologists who wish to engage in the practice of medicine must complete the training that is required of a Nurse Practitioner, why is it necessary to develop a unique training program for psychologists? University-based programs for NPs and for Physician Assistants are already in place in Oregon and could easily accommodate psychologists who have the necessary background in basic sciences. The Work Group is operating under the charge of the legislation; nevertheless, the question stands.

We also offer comments about four specific elements of the draft bill.

1. Section 2.(1) creates a seven-member Committee on Prescribing Psychologists, the majority of whose members would be psychologists. This committee would have the authority to develop the drug formulary from which prescribing psychologists would prescribe. Consequently, under its “majority rule” authority, decisions about which powerful medications could be prescribed by psychologists would be made by members who themselves are not trained to prescribe. While the committee’s other responsibilities are couched as “recommendations” to the Oregon Medical Board, this critical responsibility rests solely with the committee.

2. The draft bill is silent on the issue of oversight. Mental illnesses are serious illnesses involving abnormalities in brain chemistry. The drugs used to treat them are among the most powerful and potentially dangerous medications available in modern medicine. They also affect other organ systems and interact with other medications. In fact, 50 percent of patients with mental illness are on such additional medications to treat other medical illnesses. There is no requirement in the draft bill for supervision of a prescribing psychologist by a physician. Even more troubling, under this bill, there is no requirement that a psychologist with a prescription certificate ever consult with the patient’s primary physician about the patient’s overall condition or care.

3. Section 4.(1) stipulates that a clinical training program for a prescribing psychologist must include 18 months of training “with a longitudinal outpatient experience” which may be completed concurrently (emphasis added). It is unclear how a clinical experience – assuming it is thorough and full-time, could be done simultaneously in pediatric, geriatric, and addiction treatment settings.

4. Section 4.(3) seems to suggest that a psychologist could file an application for a certificate of prescriptive authority before completing the clinical training program. This is contradictory to Section 3(2)(b), which says a candidate must have completed the clinical training before applying to the medical board for a prescribing certificate.

These comments are not meant to suggest any support for this legislation by the American Psychiatric Association. The APA still strongly asserts that proponents of this legislation have not demonstrated a medical need that would be ameliorated by such a program. Thank you for the opportunity to provide these comments. If the work group has any questions about the APA comments, please contact Paula Johnson, Senior Deputy Director, State Affairs, at pjohnson@ or 703-907-7800.

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