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Want to Fix Mental Health Workforce Shortages? Speed up the Licensing Boards: An interview with Dr. Ben Caldwell

Curt and Katie interview Benjamin E. Caldwell, PsyD, about licensing board inefficiencies leading to incredible delays in folks getting licensed. We talk about the impacts of paperwork processing delays as well the inadequate infrastructure of most licensing boards. We also explore policy and individual options to mitigate or address these problems.


Click here to scroll to the podcast transcript.

An Interview with Benjamin E. Caldwell, PsyD

Photo ID: Dr. Ben CaldwellBenjamin E. Caldwell, PsyD, is a California Licensed Marriage and Family Therapist, adjunct faculty for California State University Northridge, and the President of High Pass Education. His research and trainings focus on ethics, technology, supervision, and therapist development. He is the author of Saving Psychotherapy and Basics of California Law for LMFTs, LPCCs, and LCSWs, and served as Editor for the User’s Guide to the 2015 AAMFT Code of Ethics. He lives near Los Angeles. His books, courses, and exam prep programs can be found at

In this podcast episode, we talk about how the mental health workforce shortages are exacerbated by licensing boards

Curt and Katie decided to invite Dr. Ben Caldwell back onto the podcast to talk about how licensing board inefficiencies are exacerbating mental health workforce shortages.

Impacts of delays of paperwork processing on clients and clinicians

“We have this amazing consensus that there is a huge problem in terms of access to [mental health] care… We’re just seeing, so far, a wildly inadequate response to what is very clearly a moment of critical need.” – Dr. Ben Caldwell, LMFT

  • Delays of folks increasing income as a licensed clinician
  • Lack of mental health clinicians in the work force
  • Prospective clinicians dropping out of the process to become licensed due to the time and financial burden

Licensing board infrastructure is often inadequate to get individuals licensed timely

  • Computer systems that licensing boards use are not typically modern
  •  The contracts for streamlining processes are often restrictive to specific systems or to how quickly these improvements can move
  • There is little that is automated, but rather includes manual entry which is inefficient and introduces opportunities for error

What are potential solutions for the pervasive inefficiency found in licensing boards?

“…simplifying applications, so that board staff are taking less time on edge cases or confused applicants. Anything you can do to make those applications themselves easier to understand, easier to fill out, is going to improve the process for everybody.”  – Dr. Ben Caldwell, LMFT

  • Scanning and using optical recognition software for applications and counting hours
  • Contracting with private technology companies that are already gathering this data
  • Finding automated systems that are set up properly from the beginning to minimize training needs
  • Legislation to put pressure on state licensing boards to update computer systems
  • Hiring more people to take on these tasks
  • Using financial reserves to improve systems
  • Mitigating the effects of the delays on the workers (i.e., being able to take required exams for licensure while accruing your hours)
  • Simplifying processes wherever possible (i.e., less buckets of hours with minimum and maximum hours that need to be met)
  • Simplifying applications to make them more understandable for both applicants and reviewers
  •  Policy analysis related to the rules – boards make the inaccurate assumption that if a rule exists it must be good
  •  Using the legislative process to hold licensing boards accountable for not getting through applications timely and potentially even giving folks provisional licenses while waiting for the application to be reviewed

What can individual therapists do to address the delays in processing licensing paperwork?

  • Be as clear as possible in applications and communication to the board to decrease confusion
  • Don’t apply for licensure early (i.e., before requirements are completed)
  • Show up to board meetings and let the licensing board know that delays are a huge problem
  • Advocate with your professional org and/or to your legislators

Resources for Modern Therapists mentioned in this Podcast Episode:

We’ve pulled together resources mentioned in this episode and put together some handy-dandy links. Please note that some of the links below may be affiliate links, so if you purchase after clicking below, we may get a little bit of cash in our pockets. We thank you in advance!

Ben’s website :

Illinois lawmakers look to address health care licensing delays – Advantage News

Illinois lawmakers address delays at IDFPR – Advantage News

Lawmakers pass bill aimed at modernizing professional licensing in Illinois – IPM News

Gov. Whitmer Signs Executive Directive to Speed Up State Permitting, Making Michigan More Competitive – Press Release: Govener Gretchen Whitmer 

EXECUTIVE DIRECTIVE No. 2023-4 from Govenor Whitmer

Senator Stafsholt’s Workforce Licensing Bills Signed Into Law – Dryden Wire

Nurses, therapists, other professionals are waiting months to receive their licenses in Wisconsin as problems persist at state agency. – Milwaukee Journal Sentinal

Nurses, therapists, other professionals are waiting months to receive their licenses in Wisconsin as problems persist at state agency. –

California Board of Behavioral Sciences

California Assembly Bill 282


Relevant Episodes of MTSG Podcast:

Addressing Racism in Clinical Licensing Exams: An Interview with Ben Caldwell and Tony Rousmaniere

The Fight to Save Psychotherapy, An Interview with Benjamin Caldwell, Psy.D.

COVID-19 Legal and Ethical Updates, An Interview with Ben Caldwell, PsyD, LMFT

Noteworthy Documentation: An Interview with Dr. Ben Caldwell, LMFT

Waiving Goodbye to Telehealth Progress, An Interview with Dr. Ben Caldwell, LMFT


Who we are:

Picture of Curt Widhalm, LMFT, co-host of the Modern Therapist's Survival Guide podcast; a nice young man with a glorious beard.Curt Widhalm, LMFT

Curt Widhalm is in private practice in the Los Angeles area. He is the cofounder of the Therapy Reimagined conference, an Adjunct Professor at Pepperdine University and CSUN, a former Subject Matter Expert for the California Board of Behavioral Sciences, former CFO of the California Association of Marriage and Family Therapists, and a loving husband and father. He is 1/2 great person, 1/2 provocateur, and 1/2 geek, in that order. He dabbles in the dark art of making “dad jokes” and usually has a half-empty cup of coffee somewhere nearby. Learn more at:

Picture of Katie Vernoy, LMFT, co-host of the Modern Therapist's Survival Guide podcastKatie Vernoy, LMFT

Katie Vernoy is a Licensed Marriage and Family Therapist, coach, and consultant supporting leaders, visionaries, executives, and helping professionals to create sustainable careers. Katie, with Curt, has developed workshops and a conference, Therapy Reimagined, to support therapists navigating through the modern challenges of this profession. Katie is also a former President of the California Association of Marriage and Family Therapists. In her spare time, Katie is secretly siphoning off Curt’s youthful energy, so that she can take over the world. Learn more at:

A Quick Note:

Our opinions are our own. We are only speaking for ourselves – except when we speak for each other, or over each other. We’re working on it.

Our guests are also only speaking for themselves and have their own opinions. We aren’t trying to take their voice, and no one speaks for us either. Mostly because they don’t want to, but hey.

Stay in Touch with Curt, Katie, and the whole Therapy Reimagined #TherapyMovement:


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Consultation services with Curt Widhalm or Katie Vernoy:

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Connect with the Modern Therapist Community:

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Modern Therapist’s Survival Guide Creative Credits:

Voice Over by DW McCann

Music by Crystal Grooms Mangano

Transcript for this episode of the Modern Therapist’s Survival Guide podcast (Autogenerated):

Transcripts do not include advertisements just a reference to the advertising break (as such timing does not account for advertisements).

… 0:00
(Opening Advertisement)

Announcer 0:00
You’re listening to the Modern Therapist’s Survival Guide where therapists live, breathe and practice as human beings. To support you as a whole person and a therapist, here are your hosts, Curt Widhalm and Katie Vernoy.

Curt Widhalm 0:15
Welcome back modern therapists. This is the Modern Therapist’s Survival Guide. I’m Curt Widhalm, with Katie Vernoy. And this is the podcast for therapists about the things that we do in our practices, the things that are going on in our profession, and hopefully, eventually making the mental health world better for both clinicians and consumers. And we are aware that a lot of the licensing boards across the country are creating or trying to address problems where it comes to addressing the mental health workforce shortage. Those of us who are licensees and registrants, and our licensing boards are not helping do that any faster. Because all across the country, there are places with tremendous delays in processing registration and licensing paperwork or licensing renewals. And we are addressing that, coming up with hopefully some suggestions as far as where our field should go, as well as hopefully where some individuals can advocate for themselves in that. And joining us in this conversation today is our good friend, Dr. Ben Caldwell from his new business High Pass Education. And we are so glad to have you back here.

Dr. Ben Caldwell 1:30
Thank you, Curt. Hey, Katie. It’s good to be with you both again. And it’s I appreciate you calling out the new business. It’s not a new business, it’s a name change. It’s Ben Caldwell Labs is now High Pass Education.

Katie Vernoy 1:40
We’re so glad to have you back. I think we’re gonna call this our once a year, start the year with Ben Caldwell episode. But for folks who haven’t heard of you before, tell us a little bit more about who you are and what you’re putting out into the world.

Dr. Ben Caldwell 1:54
Well, thank you. I’m Ben Caldwell, I’m a licensed MFT here in California. And I have exam prep stuff for folks who are planning to take BBS exams. I also have a book on California law that’s used at a lot of graduate programs around the state, and some other CE stuff and related resources all at

Curt Widhalm 2:14
So, we have been reading some stories, we’ll include some links in our show notes over at for reference, but we’ve been reading stories about this from all across the country. And this has also affected my practice, which is maybe why I’m a little bit passionate about this as some of the clinicians who work for me have been stuck in limbo for months waiting to get their registrations approved here in California by the California BBS. And I have been around long enough, and I appreciate the California BBS’s transparency as far as how long it’s taking them to process applications. But I point out how long I’ve been around in that when I first submitted my hours for approval to test and become a licensed therapist. I like to point out to my students that I submitted my paperwork. I got it an initial feedback back from the licensing board nine days later. And they gave me that feedback. They audited my hours. And I had to submit some new paperwork and submitted that and I got my full approval in 16 days just over two weeks from beginning to end. And that’s when a fully staffed California BBS was way back before the Great Recession was in place. And over the years due to watching a lot of how the government systems work as there’s been hiring freezes and budget crunches in these organizations, I recognize that there are sometimes just very systemic problems that arise. But the last time that I checked, it is now 2024. And a lot of things like the internet and automated systems that we have talked about, have been implemented. Like now when I go to renew my license, it’s just a couple of clicks and entering my credit card number and my license generally gets renewed within seconds. But that’s not the case at all places across the country. Some of the stories that we’re reading is: like a psychologist in Wisconsin that took nearly six months to have a license approval by their licensing board. And this being 2024, this is just a very bad thing as far as technology that’s available and as our mental health workforce shortages, dealing with mental health crisis kinds of things. This is affecting jobs and contracts and all of that kind of stuff. And hopefully we’re here to say, hey, here’s here’s the kinds of conversations that we should be having to be able to light some fires under some licensing boards.

Dr. Ben Caldwell 5:00
Yeah, I would just add to that, that the impacts of delays in paperwork processing, it can sound very bureaucratic and administrative and the kind of thing that we sort of grumble about, but accept as a reality. To your point number one, it doesn’t need to be a reality, the technology certainly exists to make a lot of these processes a lot faster and more efficient than they are today. And secondly, the negative impact of these kinds of delays, fall really disproportionately on the people who can least afford those kinds of delays. So if you’re in the process of trying to become a therapist, and you are not well paid, and you don’t have a lot of independent financial resources, can you afford an extra four to six months of a pre licensed person’s salary, while you are waiting for paperwork to get processed? Maybe not. And when we look at the mental health workforce shortage and how there is general consensus that we need to move more therapists into the workforce, and onward to licensure, part of the reason why the field is not representative of the communities that we serve, is because it takes so long and it’s so expensive to become a therapist. Part of the expens is dollars, part of it too is time. And a lot of the people who drop out along the way, who would be wonderful therapists, but we lose them from the field, we lose them because they just don’t have the resources that allow them to wait long enough to become a therapist.

Katie Vernoy 6:40
When I’m hearing you talk about this, I also think about how many clients aren’t able to find therapists because there just aren’t enough. I mean, to me, the ripples are pretty impactful all the way across our whole society. I mean, we talk about this big mental health, you know, pandemic or whatever we were calling it before. And I don’t think we’ve done anything to move the needle to get more therapists seeing more clients.

Dr. Ben Caldwell 7:05
100% agree. We we have this amazing consensus that there is a huge problem in terms of access to care. And the the policy and practice responses to it have been so nothing. They’ve been outreach and scholarship and stipend programs that only reach a tiny, tiny sliver of people who might ultimately become therapists. We see a little bit of policy movement in terms of network adequacy and trying to make sure that insurers have enough providers in their networks, but not with the real enforcement teeth that would be necessary to move the needle for insurance companies. We’re just seeing, so far, a wildly inadequate response to what is very clearly a moment of critical need.

Katie Vernoy 7:57
Well and it seems like in this case, addressing the licensing and registration and all of those delays, is actually right in the wheelhouse of the government. And being like trying to get more folks to apply and want to be therapist. Yeah, that’s great. Sounds like you’re saying it’s ineffective, but it’s but it’s it’s not something that feels like it squarely in the in the responsibility of government entities.

Dr. Ben Caldwell 8:23
Well, whether it is or it’s or it’s not, I think is arguable. I do tend to think that it is. But whether you think it is or is not part of government’s job to like attract people to the field, it certainly is the case that our licensing boards and bureaus can get better about moving people through the process when those people are appropriately qualified.

Katie Vernoy 8:45
Yeah, that’s what I was trying to say. So thank you.

Curt Widhalm 8:49
And also, just to kind of further put this into context, we’re focusing on mental health professionals here. But this is a problem that is existing across all professions in many states. So this is even at the organization’s above getting here in California, the Board of Behavioral Sciences is the one who oversees the licenses of the three of us on this podcast, but up to above them as the Department of Consumer Affairs that oversees a number of other licensing boards. And, you know, part of what I imagine is going on in some of these systems, as I mentioned earlier, is it would be awesome to automate this because part of what I’ve heard in the past from the executive directors of the licensing boards, California BBS’s, you know, sometimes these delays are caused by shortages in their workforces. And they have to hire people and train people in how to look through the applications that people send in for registration and licensure and make sure all the T’s and the I’s and the lowercase j’s are crossed and dotted respectively. But I’ve heard from executive directors on this stuff in the past that it takes a lot of time to hire and then train someone. Now I’m jumping maybe to a solution here. But you know what doesn’t need to be trained every time somebody leaves one of these licensing board positions? Automated systems. Like this seems to be a way that we should no longer be having these problems anymore. But I also have the sense that many states computer operating systems were developed in the last century and may not be set up for this.

Dr. Ben Caldwell 10:31
Yeah, the computer systems that licensing boards use, they tend to be not the most modern is probably a friendly way to put it. And there are some systemic reasons for that. But I don’t want you to hear this as a defense of outdated systems, it’s not meant that way, I just mean this more as explanation. Part of the reason why state boards wind up in the positions that they are in have to do with how those government contracts for automation are done. So, you look at the BreEZe system here in the state of California licensing database system that we use to renew our licenses. That BreEZe system is developed under one single contract that a private entity has with the Department of Consumer Affairs. And within the BreEZe system are the licensing processes for, last I checked, 32 different boards and bureaus, each one of which has its own multiple processes, often multiple types of licenses and registrations. So, you have a whole mess of subsystems operating under this single contract, where boards and bureaus are sort of fighting for position to get their stuff updated, get their stuff moved into it. And the contract only allows for so much work to happen so quickly. It is, after all, a government contract, which means that it typically is going to go to the lowest well qualified bid. And so it just winds up taking a long time to get good systems put into place. And what we’re seeing, I think in California and around the country, is movement in the direction of automation, but it is frustratingly slow. And Curt to your point, you don’t have to retrain automated systems, every time a new employee comes in, or an old employee leaves. Obviously, you have to set up those systems well in the first place. But we’d much rather have a one time process of setting up that system well, than having to essentially recreate the wheel anytime you’ve got a new employee. I can tell you that for the BBS a lot of what they spend their application processing time on, is receiving those paper documents, looking at the numbers that are on those paper documents, and typing those into essentially an Excel spreadsheet, that to do some of the math and see whether the math looks right. And, you know, of course, you want to make sure that the Excel spreadsheet itself is capturing things appropriately. But that introduces tremendous sources of error, right? People might miss read what is handwritten on a form, people might key it in incorrectly, there could be an error in that Excel spreadsheet. But just think about how much time is taken by that manual entry process that, if nothing else, could be replaced by scanning all of those documents, and using optical character recognition to plug in numbers and just take what’s written on the, on the form or typed on the form and just plug it directly into the spreadsheet. If we could get out that manual entry, even without submitting things electronically, that would be a huge, huge benefit. And I don’t know why we’re not getting there.

… 13:59
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Curt Widhalm 14:00
Oh, it also seems that I know that there’s a number of programs to Track Your Hours, Tevera, these kinds of things that are already computer entry. Here’s the hours that I worked that I’m sure that some smart computer engineering kinds of people or software engineering kind of people could match up one system to another so that way, it all becomes centralized. And then rather than even having to scan documents, it’s just a lot more electrons that get annoyed as buttons get pushed on computers.

Dr. Ben Caldwell 14:38
Yeah, and when it comes to those kinds of software systems, you know, there have been discussions on and off in the past about well, should licensing boards just contract with one of those providers, because they already have the resources and systems and people are filling out essentially their licensing paperwork online. Why not just connect that system of Track your Hours or whomever, to the system of the BBS to pass data through. And any government entity has to be careful about not requiring licensees to purchase a sort of private commercial product. But there are ways to solve that problem. And…

Katie Vernoy 15:20
It doesn’t need to remain a private commercial product. Like it could be part of the system that yes, they probably would raise our licensing fees. But like, this needs to be managed. Like this is ridiculous that people are manually entering people’s hours, that is crazy.

Dr. Ben Caldwell 15:40
Yeah, like I said, just think about the hours that that takes. But there are lots of ways to solve that problem. So, one of the private companies could license their technology, or there’s 12 other ways to solve that problem. There’s lots of ways to get around it, that might be a really good and fairly expedient solution is to take a software product that has been built by a private company that already exists already functions pretty well, and is built specifically to flag issues for the the therapists, the clinician. Why not have that integrated with the information that’s going into the the licensing board? It would make their jobs a heck of a lot easier.

Curt Widhalm 16:25
One place that is seemingly trying to address this is the state of Illinois has a bill that was introduced by state rep Bob Morgan, to update their computer system, which as I’m reading some of these articles, the Illinois system for all of their licensing boards is a computer system that was built in the 1990s. And some of us remember the 1990s, being about 10 years ago, but checking this out at least 15 years too short…

Dr. Ben Caldwell 16:59
I’m sorry, what now?

Curt Widhalm 17:03
But this is one state that is looking at kind of more globally addressing these kinds of things by, within three months, as the bill reads, of approval by the governor, the the state licensing board has to put out for contract to update their computer systems to automate more of this to specifically reduce the processing time for applications and renewals. And this is one of the ways that I’m hoping that some of our listeners can also put pressure on your own states as a way of, hey, look, this is being done. And a lot of times what happens in government is, hey, here’s a bill that was written in another state, make this one specific to our state. So if I’m in, say, Wisconsin and facing the same kinds of things, I could go to my state rep and say, Hey, look at this thing that happened over in Illinois. Can you make this happen here? This is one of the policy ways of addressing things that you were talking about earlier. Are there other policy ways of going about this kind of stuff that might be a little bit faster than getting something introduced through the legislature and passed by a governor, that might also be available for some of the licensing boards?

Dr. Ben Caldwell 18:21
Yeah, sure. So on a on a policy level, certainly we want boards to do more hiring to bring in more people. Board sometimes keep more money on hand than they should. Our California BBs just as an example, they’re going to finish out the current fiscal year with almost two years of budget in reserve, that’s more than they need. And they should be spending that money on things that will actually improve processes. And yes, there are timelines with all of that. But there are also things that could be started now, that would result in more hiring, more people, better systems, and so on and so forth. We also, on a policy level, can look at mitigating the effects of delays. And what I mean by that is, you know, you right now, if you’re in California, you’re waiting, let’s say four to six months for your hours to get approved, once submitted, that would enable you to take your clinical exam. If you then don’t pass the clinical exam, you’re waiting four more months to retake your clinical exam. And so this process can drag on for years, even after you’ve already finished your hours, which is wild. And so I’m a really big fan of what our Board of Psychology is doing. And this was Assembly Bill 282 last year, and that was partly in response to some of the controversy around the the E Triple P (EPPP) part two in the world of psychology, but they really they did it as a workforce bill and as a like processing licensees bill, where they’ve made it so you’re eligible as a psychologist in California, to take all of the required exams for psychologist licensure as soon as you finish your academic coursework requirements. You don’t have to wait until you’re done with your hours, you can be taking your exams along the way. So the time of studying for an exam, scheduling the exam, actually sitting for the exam, if you don’t pass it having to wait and then retake that, that all can occur side by side with your gathering of clinical hours of experience for licensure. And there’s no reason why other boards couldn’t do that. There are massive problems with clinical exams and Tony Rousmaniere and I talked about that on a on a prior episode. But even leaving the exams kind of as they are, just make it so that people can take them earlier, then you don’t have the potential of the licensing process dragging on for months and months and even years and years after somebody is done with their hours. That’s a matter of mitigating the effects, not really ultimately solving the problem. But it’s a good step halfway there.

Katie Vernoy 21:19
Well and it also offers the opportunity for folks, if they realize that they’re not going to be able to pass an exam to not even go through the licensing process. I mean, I guess that’s a little pessimistic. But it seems to me that the whole thing is one piece. And so why not submit your hours with your exams already taken. Like that, that makes a lot of sense to me. I feel like there’s probably an argument on the flip side, though, that the clinical exam is supposed to wait till you have the sufficient clinical experience. But we’ll refer everybody to the episode about how they don’t really test anything anyway.

Dr. Ben Caldwell 21:53
It would be it would be one thing, if exams were well scientifically validated in that regard, that they were reliant on those 3000 hours of experience. But the best data that we have suggests that the more quickly you take an exam after graduating, the better your odds of passing that exam. It’s not like you get better at exam taking with more years of clinical work.

Curt Widhalm 22:18
The current system as you’re put against it, and maybe another just kind of smartass way of saying this is that by forcing people to take an exam that they could pass theoretically, on day one of being a registrant is more or less just having people exist for longer before they take their exam. That if it’s just a matter of knowing the content to be able to pass it existing longer, as you’re saying, doesn’t necessarily make sense.

Dr. Ben Caldwell 22:50
Yeah, there’s there is no scientifically justified reason to make people wait until the end of their supervised clinical experience to take their clinical exam. And again, the data that we have suggests that clinicians will be better served by being able to take those exams earlier.

Katie Vernoy 23:12
So, we have some ideas around automating the systems, using money that you already have and holding less reserves, and letting folks take exams earlier. Were there other policy ideas that you had, Ben?

Dr. Ben Caldwell 23:26
That really addresses the the majority of kind of policy responses. I mean, there’s, there’s more extreme stuff, too, that people can do. I, I’m an advocate that we shouldn’t be doing clinical exams at all. They have no discernible benefit on public safety. They certainly make it harder to become a therapist, especially if you’re a clinician of color. I think the appropriate policy response would be to get rid of them. But I also understand the political realities that make that a difficult thing to do. And if you wanted to go a step further, you’d be surprised at how thin the evidence is supporting the notion that licensure in general actually protects public safety. So, we’re not going to go too far down that road, just because it is what it is. And it’s…

Katie Vernoy 24:09

Dr. Ben Caldwell 24:10
I’m not sure that’s a very fruitful discussion. But in terms of the realistic policy solutions, yes, automate, yes, bring in more people and spend board’s money to do that. Move exams to earlier. And then another thing that, you know, boards can do to increase increase their efficiency of getting this stuff done, is to simplify processes wherever they can. You know, here in California back in 2016. We simplified the structure of hours for licensure for MFTs and counselors. Where previously MFTs had to meet I think was nine different minimums and maximums in various categories and subcategories, and we streamlined that to have it just be clinical hours and non clinical hours. Which made a lot of sense. Certainly the the more detailed minimums and maximums weren’t helping much, they were just making it take longer for people to get licensed. So, that kind of streamlining can be helpful. And even simplifying applications, so that board staff are taking less time on edge cases or confused applicants. Anything you can do to make those applications themselves easier to understand, easier to fill out, is going to improve the process for everybody.

Katie Vernoy 25:30
Yeah, I mean, is there any real reason that these crazy little complicated rules should arguably be there?

Dr. Ben Caldwell 25:39
Sometimes. I think it depends on the rule. There are some weird anomalies that exist for good reason. And as an example, MFTs in California, we have to do 500 hours of clinical experience with couples, families and kids. I think that’s actually a good rule. I think that is part and parcel of working as an MFT. And if somebody wanted to get rid of that, I’d say, whoa, whoa, whoa, hold on. The number is arbitrary, but the fact that somebody calling themselves an MFT should have some experience working with systems, I think is important to the identity of the profession. So, some of those little rules, there’s reason for them to exist, but a lot of them there is not reason.

… 26:18
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Katie Vernoy 26:20
And so it just would be a matter of actually doing the work, where the board’s doing the work of simplifying their processes, and going through the slow bureaucratic process of approving changes to how things how applications are put together.

Dr. Ben Caldwell 26:33
Sure, and some of that’s policy analysis about, you know, does this rule really improve safety? Does it improve care? Or, or is it necessary? And boards quite often make the inaccurate assumption that simply because a rule exists, it must therefore be good. And I think it’s worth looking at those rules with a bit of a more critical eye. But even separate from the rules themselves, simplify forms, simplify instructions, make it so that you you have to spend less time on on edge cases.

Curt Widhalm 27:08
I’m looking at what Michigan put into place in 2023. And this was a directive from Michigan Governor Gretchen Whitmer, about speeding up their permitting process and holding licensing boards responsible for not meeting processing time things. And we have yet to see kind of in the long term, how this affects anything. What’s keeping more places from putting that kind of a regulatory thing in place that says, hey, you actually have to meet some minimum standards on this stuff. I mean, it kind of during the Great Recession, it was taking 18 months to process applications here in California, which was crazy bananas. This is a a year and a half to get hours approved to move into licensure. I’ve heard excuses as far as California BBS say: we just have to follow the law that’s in place. But why not make more laws like this that hold these agencies and licensing boards more accountable?

Dr. Ben Caldwell 28:12
Well, I’ll tell you, as a matter of principle, I like the idea of requiring boards to either process an application within a certain limited timeframe, or if you’re not going to get to it, issue the person a provisional license or a provisional permit that allows them to work under the higher level of practice privileges. Until such time as the application can be processed. I think that hold board’s feet to the fire in a way that is good. Because it it puts people out into the workforce while they are waiting for their applications to be reviewed. I think the reason why it’s often very difficult to do that is because boards in general and healthcare boards, in particular, operate on a mission of public protection. They exist to ensure that consumers are safe from exploitive kinds of situations. And if a rule like that were to be proposed, I could very easily see boards coming back and saying, Whoa, whoa, whoa, hold on. You can’t give people a limited permit when we haven’t made sure that they’re qualified. We haven’t run a background check. We haven’t established that they have the education experience necessary to practice safely. And…

Curt Widhalm 29:30
Can I, can I argue back with this board’s like just on that particular point, because…

Dr. Ben Caldwell 29:36
And to be clear, I am not them.

Curt Widhalm 29:39
I know. But in this particular moment, I know that you know their argument. We have here in California for MFTs. We have the 90 day rule where people are provisionally able to practice without that stuff in place. And I know that there’s, you know, some background checks, live scans that people have to do as part of their traineeship in order to get there. But we already have evidence that this can work in at least temporary bases. Maybe I’m just crafting what I need to respond when I reached out to my state senator to create this bill.

Dr. Ben Caldwell 30:14
The 90 day rule thing is a good example, because that actually got a little bit hung up in the legislature a few years ago out of public safety concerns. And the 90 day rule actually was very close to being eliminated in California for a while. And the LiveScan requirement was there to ensure, was put there to ensure that we don’t have people out in practice, who haven’t at least had that background check. So, some of it’s a matter of striking a balance, where can we say that somebody is under supervision, and they’ve had their background checked, there is still an application that needs to be evaluated, but they are, they’re not given free rein to go out on their own. I think it’s an easier argument to make for that kind of registering as an associate than it is to grant somebody a provisional full license when they haven’t had their application reviewed yet. That being said, I’m just giving the argument I actually line up with you, Curt, I would like to see board’s put more of, our legislators put more of those kinds of rules in place that will allow people into the workforce, while boards are just dragging their heels on processing paperwork.

Katie Vernoy 31:24
And I think that the piece that I keep hearing when we talk about consumer protections is that we’re looking at consumer protections from bad actors. But I feel like we need to protect folks in the populace from a lack of mental health care to like…

Dr. Ben Caldwell 31:39
I heartily agree.

Katie Vernoy 31:40
I understand that no bad mental health better than bad mental health. But no mental health is really bad.

Dr. Ben Caldwell 31:48
100% agree with you. And I wish that boards would make clear that serving their public protection mission requires a balance, where yes, you want to make sure that anybody you’re letting into practice is appropriately qualified, appropriately vetted. And also, you have to balance that responsibility against the responsibility to ensure that the public has an adequate supply of mental health professionals that they can access. And part of that balance should be weighing out when there is the potential for a new educational requirement, the potential to increase the number of units in a graduate degree required for licensure. Well, you might make a public safety argument for why that thing should be added or should be newly required. But is it also going to have a negative impact on how easy it is for people to become therapists. And over the long term, the availability of qualified therapists for our community, a good board should understand its public protection mission as serving both of those aims. And I think a lot of boards, unfortunately, lean way too heavily on the enforcement and qualifications side, without realizing how restrictive that winds up being on the public’s ability to actually access care when they need it.

Curt Widhalm 33:15
You also mentioned that there’s some things that individuals can do in not just waiting for government and boards and bureaucrats to get joined into the process. But what can individuals do with this process, too?

Dr. Ben Caldwell 33:28
Yeah, I think that a lot of individual therapists look at a problem like this and they think, well, it sucks, and they rightly complain about it. But you know, if I am Jane therapist, I’m one person, I’m new in my career, like, what can I do about this that’s going to have any possible impact? And let me assure you, Jane, you can absolutely have some impact on this. There are a few things that you can do that will make a difference. One thing that you can do is just on an individual level, when you are interacting with your board, when you are submitting documents for the licensure process, be as clear as you can possibly be in those documents and in your communications, because Board staff winds up spending a lot of time on confusion, either on their end or on the applicants end. And if you can avoid taking up their time with confusion and just let them process your stuff, you’re making the process faster for you, and faster for everybody else. Secondly, don’t apply early. This is something I’ve been hearing about from folks, especially in California, but I know what happens in other states too, where people think well, gosh, there’s a delay in processing applications, so what I should do is apply early before I’ve completed all of the requirements, so that I’ll get a deficiency letter back but I’ll be essentially at the front of the line. Number one: you’re making In the process take longer for everybody else. And number two: boards are on to that. They’re, they are wise to that strategy. And you will not, in fact, remain at the front of the line for when you finish out your hours. If you apply, and in your application, you don’t even claim to have all the required hours of experience done, what I hope happens is that the board just refuses to accept your application and kicks you to the back of the line. Apply when you have stuff done. Now, don’t wait longer than you need to. People talk about do I need a buffer of hours of experience beyond what’s required? No, please don’t do that. That’s just waiting too long for licensure. But wait until you’re ready, you’ve got everything done, be as clear as day in your applications. And that’s sort of the individual stuff. On a on a more systemic level: show up and make clear what a big problem this is, make clear how this is impacting you. I think a lot of licensing boards do not grasp the the widespread human impact of these delays. Because they don’t hear about it enough from actual licensees and registrants. They just see data points in like an executive officers report. At the last Board of Behavioral Sciences meeting here in California, I went in person, and I always find it valuable to go in person because then I get some inside information, which is great. And to be part of the process. That’s all great too, and can have kind of some outsized influence on policymaking. And I like that. I’m a policy nerd, that’s all fine. But what I think is worth pointing out here is that the Board of Behavioral Sciences currently governs 140,000 licensees and registrants in California. That is, by a mile, the biggest licensee population of any mental health licensing board in the country. And out of those 140,000 clinicians, at the last open public quarterly meeting of our licensing board, I was the only member of the public to show up in person. There are some other people attending online as well. And you can participate online, online and by all means you should. But the fact that no one else is even showing up to these meetings to raise a concern, it’s understandable if the board thinks, well, this isn’t great, but it’s not that big of a problem. They really need to hear from you that this is a problem. And you might be surprised because so few people actually go to these meetings, the board is eager to hear from people who are impacted by problems in application processing so that they know what needs to get fixed and they can direct Board staff to actually engage in those fixes. But unless more people show up in front of the board, and make their voice heard to say you’ve got to fix this. I don’t think there’s going to be urgency.

Curt Widhalm 38:12
We will include links to our stuff in our show notes over at For people who have forgotten since the beginning of the episode, Ben where can people find out you and your work and the stuff that you’re doing?

Dr. Ben Caldwell 38:26
You can find me at That’s H-I-G-H-P-A-S-S .com.

Curt Widhalm 38:33
We will include a link to High Pass Education over in our show notes at As well as some links to the articles and follow us on our social media. Join us in our Facebook group, the Modern Therapists Group. I’m at least at the time of recording, I’m motivated to reach out and see if my legislature representatives will be interested in doing something like this in order to help actually do things to address mental health workforce shortages in a consistent basis. As we progress on that I’m more than happy to share either my successes or my continued struggle on this but until next time, I’m Curt Widhalm with Katie Vernoy and Dr. Ben Caldwell.

… 39:21
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