Dear Colleagues and Advocates,
We have been receiving many questions regarding the new regulations that require mandatory continuing education (CE) for all Licensed Mental Health Practitioners, including LCATs. While we all respect and value the process of continuing education for maintaining competence in practice, NYSTF has concerns about components of the proposed regulations, specifically:
- The limited number of hours allowed for certain educational activities
- The constraints imposed on eligibility to become a state-approved provider.
In spite of our advocacy efforts last December when many of you provided comments to the Deputy Commissioner of the Office of the Professions, our concerns did not alter the outcome of the proposed regulations. Continuing education requirements for LCATs were added as written to the regulations and will be enacted as scheduled on January 1, 2017. Details of the law and regulations are available at the links provided.
The CE regulations added a new Section 8412 of Article 163 (the Mental Health Practitioners law) http://www.op.nysed.gov/prof/mhp/article163.htm#CE and a new Section 79-11.8 of the Regulations of the Commissioner of Education http://www.op.nysed.gov/prof/mhp/subpart79-11.htm#coned and mandate 36 hours of continuing education in each 3-year registration period.
The regulations define acceptable CE subjects and other types of educational activities and include:
- Courses and other educational activities taken from a state-approved provider including university and college credit and non-credit courses, professional development programs, technical sessions offered by national, state and local professional associations and other organizations, and any other organized educational and technical programs related to the practice of CAT;
- Preparing and teaching a course offered by an approved provider of CE, preparing and teaching a course at a higher education institution or psychotherapy institute, or making a technical presentation at a professional conference (all actual instructional time plus preparation time which may be up to two additional hours for each hour of presentation);
- Completing a self-study program (no more than twelve hours of continuing education in any three-year registration period);
- Authoring a first-time article published in a peer-reviewed journal or a chapter in a published book (2 hours);
- Authoring a first-time book in the practice of CAT (5 hours);
- Participating in a juried art show or performance activity (2 hours per year).
The new mandatory CE regulations take effect 1/1/2017. While there are still many unknowns, the task force continues in our efforts to provide input on the application form and procedures, and qualifications for LCAT CE providers. CBMT and the Mid-Atlantic Region are committed to providing continuing education to LCATs and are keeping abreast of regulatory developments.
This entire process has further strengthened the belief of the task force that an authentic music therapy license is warranted, one in which the full scope of music therapy practice is recognized and also one in which continuing competency requirements more reflective of our current CMTE procedures is accepted. We will be asking for the support and advocacy of all music therapists and music therapy students in New York as we move forward in this effort.
In the spirit of service,
The New York State Task Force on Occupational Regulation
MAR/AMTA