TITLE 18. PROFESSIONAL AND OCCUPATIONAL LICENSING

BOARD OF PSYCHOLOGY

Fast-Track Regulation

Title of Regulation: 18VAC125-20. Regulations Governing the Practice of Psychology (amending 18VAC125-20-55).

Statutory Authority: § 54.1-2400 of the Code of Virginia.

Public Hearing Information: No public hearing is currently scheduled.

Public Comment Deadline: December 2, 2026.

Effective Date: December 17, 2026.

Agency Contact: Maria S. Stransky, Executive Director, Board of Psychology, 9960 Mayland Drive, Suite 300, Henrico, VA 23233, telephone (804) 367-4697, or email maria.stransky@dhp.virginia.gov.

Basis: Section 54.1-2400 of the Code of Virginia authorizes the Board of Psychology to promulgate regulations that are reasonable and necessary to effectively administer the regulatory system.

Purpose: This action is essential to protect the health, safety, and welfare of citizens because more individuals will be able to earn licensure as an applied psychologist, strengthening the workforce in Virginia.

Rationale for Using Fast-Track Rulemaking Process: This action is expected to be noncontroversial and is therefore appropriate for the fast-track rulemaking process because it expands the pathway to licensure for those who would not normally meet the qualifications and reduces barriers to licensure as an applied psychologist.

Substance: The action adds a new subsection to 18VAC125-20-55 to allow coursework taken outside of a doctoral program to be accepted by the board to meet educational requirements of the section and to stipulate that any coursework completed outside of the doctoral program must be completed at the graduate level.

Issues: The primary advantage to the public is an increased applied psychology workforce as more individuals can meet licensure requirements. There are no disadvantages to the public. There are no advantages or disadvantages to the agency or the Commonwealth.

Department of Planning and Budget Economic Impact Analysis:

The Department of Planning and Budget (DPB) has analyzed the economic impact of this proposed regulation in accordance with § 2.2-4007.04 of the Code of Virginia and Executive Order 19. The analysis presented represents DPB's best estimate of the potential economic impacts as of the date of this analysis.¹

Summary of the Proposed Amendments to Regulation. The Board of Psychology (board) proposes to allow applicants seeking licensure as an applied psychologist to use graduate level coursework that was completed outside of an applied psychology doctoral degree program to satisfy the educational requirements for the license.

Background. Education requirements for applied psychologists (18VAC25-20-55) requires applicants for licensure as applied psychologists to hold a doctorate from a professional psychology program. This section contains doctoral program requirements, including core curriculum content areas. In addition, this section specifically requires a minimum of 18 semester hours in a "concentrated program of study in an identified area of psychology, for example, developmental, social, cognitive, motivation, applied behavioral analysis, industrial/organizational, human factors, personnel selection and evaluation, program planning and evaluation, teaching, research or consultation." The board reports that Virginia is one of the only states to license applied psychologists separately from clinical psychologists, which also requires a doctorate, and that doctoral programs in professional psychology often do not include the necessary coursework listed.² As a result, the board has had to defer or deny applications without the appropriate coursework; those applicants do not currently have a path to licensure as an applied psychologist because the regulation does not allow for coursework completed outside of a doctoral program. Thus, the board seeks to insert language allowing coursework completed outside the doctoral degree program to be used to satisfy the requirements of this section. The proposed text would specify that such coursework must be completed at the graduate level.

Estimated Benefits and Costs. The proposed amendments would benefit those individuals seeking licensure in Virginia as applied psychologists whose prior education does not meet the current requirements of this regulation. These individuals could submit coursework they may have already completed as part of a separate master's program or enroll in graduate level courses to meet the requirements. The proposed amendments would also benefit entities seeking to employ applied psychologists to the extent that increasing the flexibility for applicants to meet the coursework requirements for licensure results in a larger labor pool of licensed professionals.

Businesses and Other Entities Affected. The Department of Health Professions (DHP) reports that currently only 26 applied psychologists hold a license from the board,³ of which 15 are in Virginia and 11 are out-of-state. DHP reports that applied psychologists tend to be employed in areas like business, health, education, and forensics. They may do pre-employment testing (for example, for police departments) or work on improving workplace issues. As mentioned previously, the proposed amendments would benefit individuals seeking licensure as applied psychologists by increasing the flexibility of the educational requirements. The proposed amendments would also benefit businesses or other entities that seek to hire licensed applied psychologists. Incumbents in the profession may face competitive pressures from new entrants into the profession; their ability to negotiate higher salaries or raises may be diminished as a result. In addition, DHP reports that there is some overlap in the training and scope of practice between applied psychologists and clinical psychologists (of which 5,180 are licensed by the board). Thus, some clinical psychologists who are currently employed in roles that may be better suited to applied psychologists may eventually be displaced or have fewer opportunities for employment in those settings. The Code of Virginia requires DPB to assess whether an adverse impact may result from the proposed regulation.⁴ An adverse impact is indicated if there is any increase in net cost or reduction in net benefit for any entity, even if the benefits exceed the costs for all entities combined.⁵ Although prospective applied psychologists and the entities that employ them would likely benefit from the proposed amendments, the potential increased supply of applied psychologists may restrict the wage growth of incumbents. Thus, an adverse impact is indicated.

Small Businesses⁶ Affected.⁷ The proposed changes would benefit small businesses that are currently affected by the shortage of applied psychologists to the extent that they lead to an increase in the labor pool available to small businesses.

Localities⁸ Affected.⁹ No locality would be disproportionately affected. Local governments would not be affected.

Projected Impact on Employment. The proposed amendments would increase the number of licensed applied psychologists in the labor market; given the reported shortage, the proposed amendments would also increase the number of individuals employed as applied psychologists.

Effects on the Use and Value of Private Property. Private businesses that employ applied psychologists may face lower hiring costs and may also be able to expand their practices as more applied psychologists become licensed; as a result, the value of such private businesses would increase. Real estate development costs would not be affected.

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¹ Section 2.2-4007.04 of the Code of Virginia requires that such economic impact analyses determine the public benefits and costs of the proposed amendments. Further the analysis should include but not be limited to: (1) the projected number of businesses or other entities to whom the proposed regulatory action would apply, (2) the identity of any localities and types of businesses or other entities particularly affected, (3) the projected number of persons and employment positions to be affected, (4) the projected costs to affected businesses or entities to implement or comply with the regulation, and (5) the impact on the use and value of private property.

² The two separate licenses are required by statute; see § 54.1-3600 of the Code of Virginia https://law.lis.virginia.gov/vacode/title54.1/chapter36/section54.1-3600/.

³ See https://www.dhp.virginia.gov/about/stats/2026Q2/04CurrentLicenseCountQ2FY2026.pdf.

⁴ Pursuant to § 2.2-4007.04 D: In the event this economic impact analysis reveals that the proposed regulation would have an adverse economic impact on businesses or would impose a significant adverse economic impact on a locality, business, or entity particularly affected, the Department of Planning and Budget shall advise the Joint Commission on Administrative Rules, the House Committee on Appropriations, and the Senate Committee on Finance. Statute does not define "adverse impact," state whether only Virginia entities should be considered, nor indicate whether an adverse impact results from regulatory requirements mandated by legislation.

⁵ Statute does not define "adverse impact," state whether only Virginia entities should be considered, nor indicate whether an adverse impact results from regulatory requirements mandated by legislation. As a result, DPB has adopted a definition of adverse impact that assesses changes in net costs and benefits for each affected Virginia entity that directly results from discretionary changes to the regulation.

⁶ Pursuant to § 2.2-4007.04, small business is defined as "a business entity, including its affiliates, that (i) is independently owned and operated and (ii) employs fewer than 500 full-time employees or has gross annual sales of less than $6 million."

⁷ If the proposed regulatory action may have an adverse effect on small businesses, § 2.2-4007.04 requires that such economic impact analyses include: (1) an identification and estimate of the number of small businesses subject to the proposed regulation, (2) the projected reporting, recordkeeping, and other administrative costs required for small businesses to comply with the proposed regulation, including the type of professional skills necessary for preparing required reports and other documents, (3) a statement of the probable effect of the proposed regulation on affected small businesses, and (4) a description of any less intrusive or less costly alternative methods of achieving the purpose of the proposed regulation. Additionally, pursuant to § 2.2-4007.1 of the Code of Virginia, if there is a finding that a proposed regulation may have an adverse impact on small business, the Joint Commission on Administrative Rules shall be notified.

⁸ "Locality" can refer to either local governments or the locations in the Commonwealth where the activities relevant to the regulatory change are most likely to occur.

⁹ Section 2.2-4007.04 defines "particularly affected" as bearing disproportionate material impact.

Agency Response to Economic Impact Analysis: The Board of Psychology concurs with the economic impact analysis prepared by the Department of Planning and Budget.

Summary:

The amendments allow the Board of Psychology to accept graduate-level coursework completed outside of an applied psychology degree program to qualify toward the educational requirements for licensure as an applied psychologist.

18VAC125-20-55. Education requirements for applied psychologists.

A. The applicant shall hold a doctorate from a professional psychology program from a regionally accredited university that meets the following criteria:

1. The program is within an institution of higher education accredited by an accrediting agency recognized by the U.S. Department of Education or publicly recognized by the Association of Universities and Colleges of Canada as a member in good standing. Graduates of programs that are not within the United States or Canada must provide documentation from a credential evaluation service acceptable to the board that demonstrates that the program meets the requirements set forth in this chapter.

2. The program shall be recognizable as an organized entity within the institution.

3. The program shall be an integrated, organized sequence of study with an identifiable psychology faculty and a psychologist directly responsible for the program and shall have an identifiable body of students who are matriculated in that program for a degree. The faculty shall be accessible to students and provide them with guidance and supervision. The faculty shall provide appropriate professional role models and engage in actions that promote the student's acquisition of knowledge, skills, and competencies consistent with the program's training goals.

4. The program shall encompass a minimum of three academic years of full-time graduate study or the equivalent thereof.

5. The program shall include a general core curriculum containing a minimum of three or more graduate semester hours or five or more graduate quarter hours in each of the following substantive content areas:

a. Biological bases of behavior (e.g., physiological psychology, comparative psychology, neuropsychology, sensation and perception, health psychology, pharmacology, neuroanatomy).

b. Cognitive-affective bases of behavior (e.g., learning theory, cognition, motivation, emotion).

c. Social bases of behavior (e.g., social psychology, group processes, organizational and systems theory, community and preventive psychology, multicultural issues).

d. Psychological measurement.

e. Research methodology.

f. Techniques of data analysis.

g. Professional standards and ethics.

B. The board may accept coursework completed outside the doctoral degree program to satisfy the requirements of subsections A and C of this section. Coursework completed outside the doctoral degree program must be completed at the graduate level.

C. Demonstration of competence in applied psychology shall be met by including a minimum of at least 18 semester hours or 30 quarter hours in a concentrated program of study in an identified area of psychology, for example, developmental, social, cognitive, motivation, applied behavioral analysis, industrial/organizational, human factors, personnel selection and evaluation, program planning and evaluation, teaching, research, or consultation.