To: Department of Licensing and Regulatory Affairs, Office of Regulatory Reinvention
From: Jennifer Headley-Nordman, President, Michigan Association of School Psychologists
Date: November 7, 2016
Subject: 2016-033 ED; Rule Changes to the School Psychologist Certificate

Thank you for the opportunity to respond to pending rule changes to the School Psychologist Certificate within proposed rule revision 2016-033 ED. The Michigan Association of School Psychologists is the only organization in Michigan that represents School Psychologists through professional development, advocacy, governance, and peer publications.

While MASP represents the profession, we understand that the rules – and proposed rule changes – exist to help protect the public. MASP appreciates the difference. In that spirit of the Department’s proposed changes, MASP provides input to the proposed changes in the chart below.

The changes MASP proposes are limited to specific areas of concern. MASP’s concerns arise from the ability of each School Psychologist to do their best, most unimpeded job for the students under our professional care.

Thank you in advance, and we look forward to working with the Department of Education and the Office of Regulatory Reinvention on the proposed rules throughout the process. If you have any questions, you can reach me at .

ORR Proposed Change / MASP Suggestion / Rationale
R 380.203 Rule 3. A school psychologist may function in roles established and defined by standards approved by the state board. / A school psychologist may function in roles aligned with the National Association of School Psychologist’s Model for
Comprehensive and Integrated School Psychological Services.
Retain examples of the specific roles of a school psychologist
(a-n). / Offers public assurance of the highest standards of professional conduct and ensures consistency of service delivery throughout the state.
Provides concrete examples to help guide educational institutions and inform public.
R 380.202 (3) An individual who is a fully licensed psychologist in Michigan can provide
psychological services in a school district, either as an employee or on a contract basis. / An individual who has completed a minimum of 60 hours of graduate level course work in school psychology and who has completed a 1200 hour supervised internship in schools performing the full school psychology role under a fully certified school psychologist, as delineated in other subrules. If this involves opening rules in other documents (e.g. MARSE) our organization with work toward that. / Fully licensed psychologists do not receive comparable coursework and training in school-based history, ethics and law (IDEA & MARSE), curriculum and instruction, schools systems needs and applications including MDE sponsored initiatives such as: Positive Behavioral Interventions and Support (PBIS), Multi-Tiered Systems of Support (MTSS), etc. The entire training program for school psychologists, with three years of ongoing, embedded pre-practicum, practicum, and internship experiences, and additional extensive requirements by our national accreditors, is philosophically and practically oriented around the whole child academic and social-emotional learning dynamics and needs and the complex instructional context of our schools. This is vastly different than what is taught in clinical and counseling psychology programs that emphasize private clinic psychotherapy and lead to the Licensed Psychologist credential. While school psychology and general psychology overlap in some foundational knowledge, the school psychology certification requires a uniquely different training and skill set that significantly differentiates it from the roles and competencies of the general psychologist.