A2170 grant psychologists the authority to practice independently
A2170 require only 400 didactic hours
What does “relevant clinical experience” mean?
The APAPO is an organization to promote “the professional interests of practicing psychologists in all settings through a wide range of activities. APAPO’s mission is to advance and protect the practice of psychology.” This is a guild and advocacy organization. It is not an independent certifying organization like the National Board of Medical Examiners, the American Board of Medical Specialties or it subsidiary boards including the American Board of Psychiatry and Neurology. On its Website it has a section advocating for “Prescriptive Authority.” This presents a conflict of interest, and thus, this entity should not be part of a certification process for psychologists seeking prescribing privileges.
No Supervision under A2170
A2170 require “obtain[ing] relevant clinical experience sufficient to obtain competency in the psychopharmacological treatment of diverse populations under the direction of qualified practitioners, including but not limited to, licensed physicians or prescribing psychologists, as determined by the board” [Underlining is mine.]
A2170 require “Each applicant for renewal of prescriptive authority shall present evidence satisfactory to the board, demonstrating the completion of 18 contact hours of continuing education instruction relevant to prescriptive authority during the previous two year license period of the licensee.”
A2170 allow the prescribing of any drugs as defined in the New Jersey statute.
The statute defines drugs as “(a) substances recognized in the official United States Pharmacopoeia, official Homeopathic Pharmacopoeia of the United States, or official National Formulary, or any supplement to any of them; and (b) substances intended for use in the diagnosis, cure, mitigation, treatment, or prevention of disease in man or other animals; and (c) substances (other than food) intended to affect the structure or any function of the body of man or other animals; and (d) substances intended for use as a component of any article specified in subsections (a), (b), and (c) of this section; but does not include devices or their components, parts or accessories.” [P.L. 1970, c.226 (C.24.21-2)]
Controlled Dangerous Substance
A2170 will allow the prescribing of controlled dangerous substances including narcotics.
No State Medical Regulatory Oversight
In A2170 the “board” is defined as the State Board of Psychological Examiners” The approvals by “the board” required in A2170 are not by the New Jersey Board of Medical Examiners, which is responsible for “the protection of the public’s health, safety, and welfare. The Board meets its responsibility by licensing medical professionals, adopting regulations, determining standards of practice, investigating allegations of physician misconduct, and disciplining those who do not adhere to requirements - thereby assuring the public that the physicians are qualified, competent, and honest.” The BME licenses acupuncturists, athletic trainers, electrologists, hearing aid dispensers, midwives, perfusionists, physician assistants, podiatrists, and physicians (MD and DO).
Progressively Lowering Standards
RxP training then and now: This is progress? (Click to download PDF)
A2170 requirements are far below the requirements of the Department of Defense Psychopharmacology Defense Project that trained psychologists to prescribe in the closed system of the military from 1991 until the program was terminated in June 1997.
Standards and Requirements for the Practice of Medicine are Increasing
The bar to practice medicine is continuously being raised not lowered. In addition to board certification, there is now maintenance of certification and state medical licensing boards are working on implementing maintenance of licensure. These maintenance programs require lifelong self-learning, periodic examinations, and continuously working on practice improvement. A2170 allow psychologists to practice medicine without satisfying any of the present rigorous requirements and standards. It has no provision to anticipate the development of new requirements and standards that are being implemented in medicine.
Carving out one aspect of a person from the whole person can cause problems, be counter-therapeutic and increase risk. With the ever-growing scientific medical knowledge, there is no choice that specialization and sub-specialization is necessary in the field of medicine. But each physician attending to only one aspect of a person can be problematic. Where there is a choice, deliberate carve outs should be and must be avoided. Examples of carve outs are: lack of insurance benefit parity, managed care for people with mental disorders separate from people with other medical disorders, state institutions without integrated general hospital resources for patients with serious mental illnesses, and establishing treatment programs for substance use disorders separate from other mental disorders.
“One Stop Shopping” - The group of psychologists that are seeking prescribing privileges argue if granted prescriptive authority they would be able to provide “one stop shopping.” By having the tools of both psychotherapy and pharmacotherapy, they claim they could offer their clients both modalities so that the treatment does not have to be split between two mental health professionals.
Psychiatrists are trained both in psychotherapy and pharmacotherapy. Even medical students are taught about various psychotherapies. Cognitive Therapy that many psychologists claim as their form of psychotherapy was developed by Aaron Beck, MD, a psychiatrist. Many psychiatrists practice both psychotherapy and pharmacotherapy.
Granting prescribing privileges to psychologists will further carve out mental health care from the rest of health care. Psychologists are trained in psychosocial aspects of mental health not biomedical science.
As physicians, psychiatrists have the knowledge and skills to provide primary care and some do so. In addition, there are psychiatrists that have dual board certification in psychiatry and internal medicine or other medical specialties.
Carving out mental health care via A2170 guarantees that at least two professionals must care for the patient – a physician and a psychologist.
Will prescribing psychologists have the competency to use non-psychotropic medications to treat the adverse effects of psychotropic medication? As physicians, psychiatrists have this competency.
Role of Physician of Record
In the last legislative session, A2170 stated, “A prescribing psychologist shall not issue a prescription unless the psychologist: (2) has first contacted the physician of record of a patient to discuss the prescription”
This was vague. Several questions were raised: What is the purpose of this contact? What should be discussed? Is this “for your information” or a request for approval? What happens if the “physician of record” does not concur with the psychologist? What if there is no physician of record?
The Louisiana law requires that a “medical psychologist” shall prescribe “only in consultation and collaboration with the patient’s primary or attending physician, and with concurrence of that physician.” and in the event the patient does not have a primary or attending physician, the medical psychologist shall not prescribe for the patient.” The “medical psychologist” also has to consult with the patient’s physician prior to making any changes of the medication. [Underlining is added for emphasis.]
A2170 has revised the role of the physician of record so that it is similar to the Louisiana law.
While A2170 require a better interaction with a patient’s physician of record than A2170 fall short of the collaboration or supervision required of other physician extenders like physician assistants and APN’s, whose practice acts guarantee direct access to the highest trained provider.
The New Mexico law requires the psychologist to have an ongoing collaborative relationship with a physician or nurse practitioner to “ensure the psychotropic medication is appropriate.” [Underlining is added for emphasis.]
Lower Standards - Decreased Safety
Speaking to the psychiatric physicians of the American Psychiatric Association Assembly Meeting November 9, 2013
Click on arrow below to listen to former Congressman Kennedy.
“Only someone with a medical degree and training, like all of you, can make those diagnoses and prescribe the necessary medications for people with a brain-related illness.”
Phone: 973-699-3115 (cell)
Don’t let psychologists prescribe drugs
Dr. Consuelo Cagande: Don’t let psychologists prescribe drugs
During the last state legislative session, New Jersey psychologists aggressively lobbied for a bill that would grant them the authority to write prescriptions for any drug in the Physician Desk Reference. Under the proposed legislation, non-physician psychologists with a master’s degree and 400 hours of training would be able to write prescriptions for some of the most powerful psychotropic medications available on the market today.
Read the full article from Asbury Park Press on April 13, 2016 by clicking here.
N.J. bills allowing psychologists to prescribe medications would harm patients
As a licensed medical doctor and practicing psychiatrist in New Jersey, I am very concerned that the state Legislature is considering bills A2892 and S1864. This legislation would allow psychologists to prescribe medications; it would, in effect, confer a license to practice medicine without a medical education.
Read the full article on nj.com by clicking here.
Only medical doctors should be allowed to prescribe medication
Newly appointed executive director of NJ Psychiatric Association says proposed legislation will endanger patients
Read the full article on myCentralJersey.com by clicking here.
News on A2892/S1864
TRENTON — Psychiatrists in New Jersey have launched an online campaign they hope will torpedo “risky” legislation that gives psychologists the authority to write prescriptions.
The New Jersey Psychiatric Association unveiled a new website, ProtectNJpatients.com, that explains why the state legislature, the governor and the public should oppose the bill that passed the Assembly in June. To view the full article on nj.com click here.