The MHP designation is used in Washington within the Division of Behavioral Health and Recovery (DBHR) to indicate a person who is qualified to assess and diagnose a mental health condition. Since passage of this particular WAC, certain professional groups, namely mental health counselors and marriage and family therapists, have been at a disadvantage because of the way this particular definition was written. As it reads now, the definition of an MHP is “(1) a licensed psychiatrist, psychologist, psychiatric nurse, or social worker as defined in chapters 71,05 and 71,34 RCW; (2) a person with a master’s degree or further advanced degree in counseling or on of the social sciences from an accredited college or university. Such person shall have, in addition, at least two years of experience in direct treatment of persons with mental illness or emotional disturbance, such experience gained under the supervision of a mental health professional…”. Based on this definition, graduates from clinical mental health counseling master’s programs and marriage and family therapy programs are not necessarily “qualified” upon graduation to perform these tasks, despite the fact that these graduates have received training to do so.

On December 11, 2014, a group of representatives from the WMHCA and the WAMFT met with Mr. Dennis Malmer from DBHR to discuss rule-making action related to the MHP designation in Washington State. During this call, representatives discussed the updated language proposed by Assistant Secretary Beyer, which includes an additional line in the definition of MHP: “a person who is licensed by the Department of Health as a mental health counselor or marriage and family therapist”. Representatives commented that this language is a “step in the right direction” but does not adequately address the disparity that still exists between the sister professions of social work, mental health counseling, and marriage and family therapy.

Representatives suggested that this language more clearly identify those who are licensed, and suggested that the language include individuals who are licensed with the Department of Health as “Associates”, as that designation implies the candidate will be working under supervision. The proposed revision to this new definition could read: “a person who is licensed by the Department of health as a mental health counselor or a mental health counselor associate, a marriage and family therapist or a marriage and family therapist associate, a licensed clinical social worker or a licensed clinical social worker association, a licensed advanced social worker or a licensed advanced social worker associate”.

Mr. Malmer, who is responsible for rulemaking with the DBHR, supported the idea of clarifying this language to include individuals licensed at the “associate” level. The rationale behind this lies first in the fact that “associates” are, by definition, working under supervision. Secondly, according to Dr. Richard Stride, current president of WMHCA and CEO of Cascade Mental Health, DBHR agencies are already contractually obligated to provide supervision. Dr. Stride suggested letting the mental health centers decide who is “ready” to perform these duties, based on their existing processes for supervising employees and licensure candidates.

Mr. Malmer from DBHR will be reporting back to Secretary Beyer regarding the need to further clarify the language in the proposed revision to the MHP definition. He will then proceed with the rule-making process, with hopes of resolving this issue by mid-2015.