BILL ANALYSIS                                                                                                                                                                                                    Ó







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        |Hearing Date:June 23, 2014         |Bill No:AB                         |
        |                                   |2198                               |
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                      SENATE COMMITTEE ON BUSINESS, PROFESSIONS 
                               AND ECONOMIC DEVELOPMENT
                              Senator Ted W. Lieu, Chair
                                           

                         Bill No:        AB 2198Author:Levine
                        As Amended:  April 21, 2014Fiscal:  Yes

        
        SUBJECT:  Mental health professionals: suicide prevention training.
        
        SUMMARY:  Requires a psychologist, marriage and family therapist,  
        educational psychologist, professional clinical counselor and clinical  
        social worker, who began graduate study on or after January 1, 2016,  
        to complete a minimum of 15 hours of coursework on suicide prevention,  
        before being issued a license.  Further requires, commencing January  
        1, 2016, a person licensed in these professions who began graduate  
        study prior to January 1, 2016, to take a six-hour continuing  
        education course on suicide prevention in order to renew a license.

        Existing law:
        
        1)Requires the director of the Department of Consumer Affairs (DCA),  
          by regulation, to develop guidelines to prescribe components for  
          mandatory CE programs administered by any board within DCA and  
          requires that those guidelines ensure that mandatory CE is used as a  
          means to create a more competent licensing population, thereby  
          enhancing public protection.  (Business and Professions Code (BPC) §  
          166)

        2)Establishes the Psychology Licensing Law which provides for the  
          licensure and regulation of licensed Psychologists.  (BPC § 2901 et  
          seq.)

        3)Requires an applicant for licensure as a psychologist to comply with  
          the following requirements:

           a)   Not be subject to denial, as specified;






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           b)   Possess an earned doctorate degree, as specified;

           c)   Have engaged for at least two years in supervised professional  
             experience under the direction of a licensed psychologist, as  
             specified;

           d)   Take and pass an examination, as specified; and,

           e)   Show by evidence satisfactory to the Board of Psychology (BOP)  
             that he or she has completed training in the detection and  
             treatment of alcohol and other chemical dependency, as specified.  
              (BPC § 2914)

        4)Requires BOP to develop guidelines for the basic education and  
          training of psychologists whose practices include patients with  
          medical conditions and patients with mental and emotional disorders  
          who may require psychopharmacological treatment and whose management  
          may require collaboration with physicians and other licensed  
          prescribers, as specified.  (BPC § 2914.3 (b))

        5)Establishes the Licensed Marriage and Family Therapy Act  
          administered by the Board of Behavioral Sciences (BBS) to regulate  
          marriage and family therapists (MFT) and interns.  (BPC § 4980.04 et  
          seq.) 

        6)Establishes the requirements of educational programs for applicants  
          for licensure as an MFT, as specified.  (BPC § 4980.36, 4980.39)

        7)Requires each educational institution preparing applicants to  
          qualify for registration or licensure to notify each of its students  
          by means of its public documents or otherwise in writing that its  
          degree program is designed to meet the requirements, as specified,  
          and certify to the BBS that it has so notified its students.  (BPC §  
          4980.38)

        8)Specifies that an applicant for registration or licensure submit to  
          the BBS a certification by the applicant's educational institution  
          that the institution's required curriculum for graduation and any  
          associated coursework completed by the applicant meets specified  
          requirements.  
        (BPC § 4980.38)

        9)Establishes the Licensed Educational Psychologists Practice Act to  
          regulate educational psychologists (LEPs).  (BPC § 4989.10 et seq.) 

        10)States the practice of educational psychology is the performance of  





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          any of the following professional functions pertaining to academic  
          learning processes or the educational system or both:  (BPC 4989.14)

           a)   Educational evaluation; 

           b)   Diagnosis of psychological disorders related to academic  
             learning processes;

           c)   Administration of diagnostic tests related to academic  
             learning processes including tests of academic ability, learning  
             patterns, achievement, motivation, and personality factors;

           d)   Interpretation of diagnostic tests related to academic  
             learning processes including tests of academic ability, learning  
             patterns, achievement, motivation, and personality factors;

           e)   Providing psychological counseling for individuals, groups,  
             and families;

           f)   Consultation with other educators and parents on issues of  
             social development and behavioral and academic difficulties;

           g)   Conducting psychoeducational assessments for the purposes of  
             identifying special needs;

           h)   Developing treatment programs and strategies to address  
             problems of adjustment; and,

           i)   Coordinating intervention strategies for management of  
             individual crises.  

        11)Requires an LEP seeking to renew his or her license to certify to  
          BBS, on a prescribed form, completion in the preceding two years of  
          not less than 36 hours of approved continuing education in, or  
          relevant to, educational psychology.  (BPC § 4989.34)

        12)Establishes the Clinical Social Worker Practice Act to license and  
          regulate licensed clinical social workers (LCSWs).  (BPC § 4991 et  
          seq.)

        13)Establishes the licensure requirements for an LCSW and requires  
          each applicant to furnish satisfactory evidence to BBS that he or  
          she has complied with specified requirements including adequate  
          instruction and training in the subjects of alcoholism and other  
          chemical substance dependency; spousal or partner abuse assessment,  
          detection, and intervention; human sexuality, as specified; and,  





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          child abuse assessment and reporting, as specified.  (BPC § 4996.2  
          (e-h))

        14)Requires an LCSW to complete continuing education coursework in  
          aging and long term care, as specified.  (BPC § 4996.26)

        15)Establishes the Licensed Professional Clinical Counselor Act to  
          license and regulate professional clinical counselors (PCCs).  (BPC  
          § 4999.10 et seq.)

        16)Establishes the licensure requirements for a PCC and requires each  
          applicant to furnish satisfactory evidence to BBS that he or she has  
          complied with specified education and practicum requirements.  (BPC  
          § 4999.32)

        17)Prohibits the BBC from renewing a PCC license unless the applicant  
          certifies to BBS, on a form prescribed by BBS, that he or she has  
          completed not less than 36 hours of approved continuing education  
          in, or relevant to, the field of professional clinical counseling in  
          the preceding two-years, as specified.  (BPC § 4999.76)

        This bill:
         
        For Psychologists  :

        1)Requires an applicant for licensure as a psychologist, who began  
          graduate study on or after January 1, 2016, to complete as a  
          condition of licensure, a minimum of 15 contact hours of coursework  
          in suicide assessment, treatment, and management and prohibits the  
          BOP from issuing a license to a psychologist applicant until the  
          applicant has met the specified educational requirements.

        2)Requires a licensed psychologist, who began graduate study prior to  
          January 1, 2016, to complete a six-hour continuing education course  
          in best practices for suicide assessment, treatment, and management  
          during his or her first renewal period, as specified, and submit  
          acceptable evidence to BOP of the person's satisfactory completion  
          of that course, and prohibits BOP from issuing a license to a  
          psychologist until the applicant has met the specified educational  
          requirements.

        3)Permits continuing education courses taken in suicide assessment,  
          treatment and management, to be applied to the 36 hours of approved  
          continuing education required, as specified.

        4)Delays the implementation of the continuing education requirement  





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          until January 1, 2016.

         For Licensed Marriage and Family Therapists  :

        5)Requires a qualified applicant for licensure as a marriage and  
          family therapist, who began graduate study on or after January 1,  
          2016, to complete, as a condition of licensure, a minimum of 15  
          contact hours of coursework in suicide assessment, treatment, and  
          management.

        6)Requires a MFT, who began graduate study prior to January 1, 2016,  
          to complete a six-hour continuing education course in best practices  
          for suicide assessment, treatment, and management during his or her  
          first renewal period, as specified, and submit acceptable evidence  
          to BBS of the person's satisfactory completion of that course.

        7)Permits continuing education courses taken in suicide assessment,  
          treatment, and management, to be applied to the 36 hours of approved  
          continuing education required, as specified.

        8)Delays the implementation of the continuing education requirement  
          until January 1, 2016.

         For Licensed Educational Psychologists  :  
         
        9)Requires an applicant for licensure as an educational psychologist,  
          who began graduate study on or after January 1, 2016, to complete as  
          a condition of licensure, a minimum of 15 contact hours of  
          coursework in suicide assessment, treatment, and management and  
          prohibits BBS from issuing a license to an educational psychologist  
          until the applicant has met the specified educational requirements.

        10)Requires a LEP, who began graduate study prior to January 1, 2016,  
          to complete a six-hour continuing education course in best practices  
          for suicide assessment, treatment, and management during his or her  
          first renewal period, as specified, and submit acceptable evidence  
          to BBS of the person's satisfactory completion of that course.

        11)Permits continuing education courses taken in suicide assessment,  
          treatment, and management, to be applied to the 36 hours of approved  
          continuing education required, as specified.

        12)Delays the implementation of the continuing education requirement  
          until January 1, 2016.

         For Licensed Clinical Social Workers  :





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        13)Requires an applicant for licensure as a clinical social worker,  
          who began graduate study on or after January 1, 2016, to complete as  
          a condition of licensure, a minimum of 15 contact hours of  
          coursework in suicide assessment, treatment, and management and  
          prohibits BBS 

        from issuing a license to a social worker until the applicant has met  
          the specified educational requirements.

        14)Requires a LCSW, who began graduate study prior to January 1, 2016,  
          to complete a six-hour continuing education course in best practices  
          for suicide assessment, treatment, and management during his or her  
          first renewal period, as specified, and submit acceptable evidence  
          to BBS of the person's satisfactory completion of that course.

        15)Permits continuing education courses taken in suicide assessment,  
          treatment, and management, to be applied to the 36 hours of approved  
          continuing education required, as specified.

        16)Delays the implementation of the continuing education requirement  
          until January 1, 2016.

         For Licensed Professional Clinical Counselors  :

        17)Requires a qualified applicant for licensure as a professional  
          clinical counselor, who began graduate study on or after January 1,  
          2016, to complete, as a condition of licensure, a minimum of 15  
          contact hours of coursework in suicide assessment, treatment, and  
          management.

        18)Requires a PCC, who began graduate study prior to January 1, 2016,  
          to complete a six-hour continuing education course in best practices  
          for suicide assessment, treatment, and management during his or her  
          first renewal period, as specified, and submit  acceptable evidence  
          to BBS of the person's satisfactory completion of that course.

        19)Permits continuing education courses taken in suicide assessment,  
          treatment, and management, to be applied to the 36 hours of approved  
          continuing education required, as specified.

         20)Delays the implementation of the continuing education requirement  
           until January 1, 2016.

        FISCAL EFFECT:  This measure has been keyed "fiscal" by Legislative  
        Counsel.  According to the Assembly Committee on Appropriations  





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        analysis dated May 14, 2014, the bill would cause minor an absorbable  
        workload and costs to the Board of behavioral Sciences and the Board  
        of Psychology for verifying that an applicant has completed required  
        coursework. 
        
        COMMENTS:
        
        1.Purpose.  This bill is sponsored by the  Author  .  According to the  
          Author, "Currently there are numerous requirements in California  
          Business and Professions Code governing graduate and continuing  
          education requirements.  There is however no specific law in  
          California that requires graduate training or continuing education  
          in suicide assessment?AB 2198 will lead to lives being saved through  
          mental health professionals identifying suicidal intentions before  
          they become life threatening."



        2.Background.  

               Suicide Prevention Strategies.  Suicide is a serious public  
             health problem and is one of the leading causes of death  
             worldwide.  Suicide is a complex phenomenon associated with  
             multiple biological, psychological, psychiatric and social  
             factors including age, sex, mental illness, physical illness and  
             interpersonal violence.  This complexity makes it especially  
             difficult to identify preventative efforts.  As such, there is a  
             paucity of consistent research findings on suicide prevention  
             strategies.

           A 2002 study posits that, "?improving the training and competence  
             of mental health professions is the most logical ways to prevent  
             suicide and save lives" (Schmitz et al, 2002).  Statements by the  
             Joint Commission and the Institute of Medicine are cited in this  
             study to support the need to have mental health practitioners  
             achieve competence in suicide risk assessment and management.   
             Several other peer reviewed research studies and publications  
             shed a different light on preventative efforts.  These studies  
             show that there are two preventative efforts that have been found  
             to be most effective in reducing suicide:  1) physician training  
             and 2) limiting the access to means for suicide e.g. medications,  
             firearms.

           The results of a systematic review of 5,020 studies, which examined  
             strategies to prevent suicide, was published in the Journal of  
             the American Medical Association in 2005.  The review reported  





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             that physician education in recognizing depression and  
             restricting access to lethal methods were the most efficacious  
             prevention interventions (Mann, et al, 2005).  The World Health  
             Organization's 2012 Health Evidence Network report entitled, For  
             Which Strategies of Suicide Prevention is There Evidence of  
             Effectiveness, examined suicide prevention strategies utilized in  
             Europe, the country with the highest suicide rates, and found  
             that limiting access to means was the most effective strategy.   
             Similarly, the American Foundation for Suicide Prevention  
             promotes teaching general practitioners to recognize and treat  
             depression and limiting access to means as the most successful  
             preventative efforts.   The U.S. Surgeon General's Call to Action  
             to Prevent Suicide suggests to, "?improve the ability of primary  
             care providers to recognize and treat depression, substance abuse  
             and other major mental illnesses associated with suicide risk and  
             increase the referral to specialty care."

               Suicide Interventions.  Research on interventions is slightly  
             more promising, but still lacking.  The American Foundation of  
             Suicide Prevention indicates that following up with patients  
             after hospitalization and providing psychopharmacology treatment  
             as effective intervention strategies.  Similarly, the World  
             Health Organization's study, described in the prior section,  
             endorses medication as an effective intervention.
            
                Centers for Disease Control and Prevention (CDC)  
             Recommendations for States' Efforts to Address Suicide.  A  CDC  
             research brief examined the efforts of various states to identify  
             the most successful suicide prevention plans.  This research  
             study emerged from the 2001 National Strategy for Suicide  
             Prevention position which called for "coordination of resources  
             at all levels of government to address the public health problem  
             of suicide mortality and morbidity."  In response, states across  
             the nation formulated state-level suicide prevention plans.   
             However, according to the CDC brief, "To date, little empirical  
             information has been available to provide guidance to these  
             states."  In response, the CDC conducted their own research study  
             to describe the "key ingredients" of successful state-based  
             suicide prevention planning.  Their suggestions included the  
              establishment of a "leadership group" or task force to examine  
             the issue within the state.   They also suggested involving  
             existing entities such as the public health and mental health  
             departments and agencies in prevention efforts.   They caution,  
             "State suicide prevention strategies must be developed within the  
             context of social, economic and political realities?states need  
             to carefully consider their vision and goals for suicide  





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             prevention before seeking legislative action."

                Academic Standards Addressing Suicide.  The licensees that  
             would be impacted by this bill receive academic and clinical  
             training that includes the identification and assessment of  
             psychopathology including the assessment of suicidality and  
             intervention strategies for dealing with patients in crisis.  The  
             American Psychological Association and the Council on Social Work  
             Education accredit programs of psychology and social work  
             respectively, and set standards for the coursework and clinical  
             training that students receive.  These bodies require that  
             coursework address areas such as, dysfunctional behavior or  
             psychopathology, theories and methods of assessment and diagnosis  
             and effective intervention.  For MFTs and LPCCs their required  
             courses are outlined in statute. Both the MFT and LPCC statutes  
             require that students receive training in, "the patient dangerous  
             to self or others."  The LPCC statute further requires training  
             in multidisciplinary responses to crises and emergencies, crisis  
             and trauma counseling, assessment strategies for clients in  
             crisis and principles of intervention for individuals with mental  
             or emotional disorders during times of crises.

               Current Mandated CE and Education Requirements for Mental  
             Health Professionals.   This bill would mandate 15 contact hours  
             in suicide assessment, treatment and management, or for those who  
             graduate prior to January 1, 2016, 6 hours of continuing  
             education.  Currently, for the groups that would be affected by  
             this bill, there are already various mandated continuing  
             education and pre-requisite education requirements for licensure.  
             Importantly, there are very clear reasons why these  
             pre-requisites are mandated.  

             At the time that most of the mandated continuing education and  
             pre-requisite education requirements were implemented, the  
             licensing boards did not have continuing education requirements  
             and training programs were not covering specific topics in their  
             curriculum.  For example, the human sexuality requirement was  
             added in the 1970's, when clinical diagnoses pertaining to  
             sexuality changed in the Diagnostic and Statistical Manual of  
             Mental Disorders, and training programs had not implemented  
             curriculum on human sexuality.  Similarly, the alcohol dependence  
             requirement was added in the 1980's when the cocaine epidemic was  
             in full force and training programs had not implemented  
             curriculum on substance abuse.  The remaining mandated education  
             requirements were added because the licensees affected by this  
             bill are mandated by law to report child abuse, elder abuse and  





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             to break confidentiality and warn victims if their patient  
             discloses intent to harm others.  The ongoing law and ethics  
             requirement is consistent with requirements for other health  
             professionals in order to ensure that health professionals stay  
             abreast of changes in the law that affect their practice.  This  
             bill would mandate coursework on suicide assessment, treatment  
             and management, however; instruction in this area is already  
             included in training program curriculum. 


             This chart reflects the requirements for the mental health  
             practitioners that would be affected by this bill.  With the  
             exception of the law and ethics courses, which must be repeated  
             upon renewal of one's license, all others are one-time  
             pre-requisites for licensure.

         
           --------------------------------------------------------------------- 
          |Psychologists|Licensed     |Licensed     |Licensed     |Licensed     |
          |             |Clinical     |Marriage and |Professional |Educational  |
          |             |Social       |Family       |Clinical     |Psychologists|
          |             |Workers      |Therapists   |Counselors   |             |
          |-------------+-------------+-------------+-------------+-------------|
          |Human        |Human        |Human        |Human        |n/a          |
          |Sexuality    |Sexuality    |Sexuality    |Sexuality    |             |
          |(10 hours)   |(10 hours)   |(10 hours)   |(10 hours)   |             |
                                |-------------+-------------+-------------+-------------+-------------|
          |Alcoholism/Ch|Alcoholism/Ch|Alcoholism/Ch|Alcoholism/Ch|Alcoholism/Ch|
          |emical       |emical       |emical       |emical       |emical       |
          |Dependence   |Dependence   |Dependence   |Dependence   |Dependence   |
          |(one quarter |(15 hours)   |(15 hours)   |(15 hours)   |(15 hours)   |
          |or semester  |             |             |             |             |
          |long course) |             |             |             |             |
          |-------------+-------------+-------------+-------------+-------------|
          |Child Abuse  |Child Abuse  |Child Abuse  |Child Abuse  |Child Abuse  |
          |(7 hours)    |(7 hours)    |(7 hours)    |(7 hours)    |(7 hours)    |
          |-------------+-------------+-------------+-------------+-------------|
          |Spousal/Partn|Spousal/Partn|Spousal/Partn|Spousal/Partn|n/a          |
          |er Abuse     |er Abuse     |er Abuse     |er Abuse     |             |
          |(15 hours)   |(7 hours)    |(7 hours)    |(7 hours)    |             |
          |-------------+-------------+-------------+-------------+-------------|
          |Aging/Long-Te|Aging/Long-Te|Aging/Long-Te|Aging/Long-Te|n/a          |
          |rm Care      |rm Care      |rm Care      |rm Care      |             |
          |(10 hours)   |(3 hours)    |(7 hours)    |(7 hours)    |             |
          |-------------+-------------+-------------+-------------+-------------|
          |             |             |             |             |             |





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          |-------------+-------------+-------------+-------------+-------------|
          |n/a          |HIV/Aids     |HIV/Aids     |HIV/Aids     |n/a          |
          |             |(7 hours)    |(7 hours)    |(7 hours)    |             |
           --------------------------------------------------------------------- 
            
        1.  Arguments in Support.  The  National Alliance on Mental Illness  
          (NAMI) Santa Clara County Board of Directors  ,  Community Solutions  ,  
           California Institute for Mental Health  and  Momentum for Mental  
          Health  similarly write in support of the bill, "?numerous  
          individuals and professionals in California are being trained to  
          recognize signs of suicide; however, no similar requirement mandates  
          that the people being referred, i.e., our mental health  
          professionals, are competently trained.  Patient safety should be  
          paramount and excellent suicide assessment, treatment and management  
          of professionals must always be ensured."
           
            NAMI California  supports the bill and writes, "By creating  
           standards for suicide prevention training for specified mental  
           health professionals, we can ensure that these mental health  
           professionals providing services to individuals living with mental  
           illness are in a position to identify and address potential signs  
           that the patient is at risk of death by suicide."

           The  California Catholic Conference of Bishops  supports AB 2198 and  
           writes, "?mental health professionals are on the front lines.  It  
           makes good sense and quality public policy to provide them with  
           effective training and tools for assessing and treating those that  
           seek their help."

           The  American Foundation for Suicide Prevention  supports the bill  
           and reports, "An American Association of Suicidology Task Force  
           Report finds that only 50% of psychologists, 25% of social workers,  
           6% of marriage and family therapists and 2% of counselors  
           nationwide are trained in suicide risk assessment and management.   
           We can and must do better for the state of California and for the  
           millions of Californians living with mental illness."

           The  Association of California Healthcare Districts  writes in  
           support of the bill, "Mental health is as important as physical  
           health.  Numerous studies have shown that when people receive  
           appropriate mental health care, their use of medical services  
           decline.  Untreated mental health illness can lead to suicide  
           attempts, and it is important that the appropriate mental health  
           professionals are trained accordingly to prevent patients with  
           mental illness from committing suicide."






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           The  Family & Children Services of Silicon Valley  supports the bill  
           and writes, "By creating standards of suicide prevention training  
           for specified mental health professionals, California will create a  
           foundation for promoting mental health and for mitigating the  
           tragic impact of suicide on individuals and families.  We welcome  
           the additional training obligation, so that we can continue to  
           ensure the very best outcomes for our clients and their families."

           The  El Camino Hospital  supports the bill and writes, "California  
           law requires a mental health professional to be certified by a  
           county mental health director to perform an involuntary detention  
           (Welfare and Institute Code 5151 et al).  There is, however, no  
           requirement that the individual performing the assessment,  
           treatment and management is certified or qualified in suicide  
           prevention.  By creating standards of suicide prevention training  
           for specified mental health professionals, California will create a  
           foundation for promoting mental health and for mitigating the  
           tragic impact of suicide on individuals and families."

           The  Didi Hirsch Mental Health Services  states their support, "Didi  
           Hirsch's staff members train mental health providers in Los Angeles  
           and Orange Counties?A simple act of legislation can make our work  
           "the norm" across the State.  It is a thrilling prospect.  So many  
           lives will be saved when mental health professionals identify  
           suicidal intentions before they threaten lives."

           The  Caltrain  writes, "Expanding education and training about  
           suicide assessment to mental health professionals is vital to  
           lowering suicide rates."

           The  California Professional Firefighters  supports the bill and  
           write, "As first responders, some of the most difficult calls our  
           members respond to are those involving suicide victims.  Because AB  
           2198 will help address the growing concern that more and more  
           Californians of all ages are losing their lives to suicide, we urge  
           your support for this bill."

         2. Support if Amended.  The  California Mental Health Directors  
           Association  (CMHDA) supports the bill but shares the concern,  
           "CMHDA supports AB 2198, but believes it will better accomplish its  
           intent if amended to require all healthcare professionals receive  
           training in suicide assessment, treatment and management."

         3. Arguments in Opposition.  The  California Psychological Association   
           opposes the bill and writes, "There currently exist a number of  
           mandated CEs on psychologists, including law and ethics, domestic  





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           violence, and aging and long-term care- all of these originated on  
           a piecemeal basis.  Moving towards a mandated CE will increase the  
           burden of professionals in this area, and will not allow them to  
           take other CE courses in areas that may be more appropriate to  
           their specialty.  The mandated CE creates less room for other  
           worthy topics such as multiculturalism, advance in cognitive  
           behavior therapy, current trends in family 


         courts and child custody proceeding, and new information on  
           psychopharmacology (to list a few)."

           The  California Board of Psychology  is opposed.  In their letter  
           they write, "The Board is aware that suicide is an extremely  
           important topic that has touched the lives of many families in our  
           state.  The Board is committed to educating our licensees and the  
           general public on this issue via various outreach and educational  
           tools.  The Board does not believe, however, that AB 2198 is the  
           appropriate vehicle for achieving competence in this area.   
           Specifically, the Board opposes the bill for the following reasons;

                     The coursework and CE hours mandated in the bill will  
                not help a licensee achieve competence in the area of suicide  
                assessment, prevention and training.  The Board is concerned  
                that attending a six hour course may provide a false sense of  
                subject area mastery to a licensee.

                     Suicide assessment, prevention and training is currently  
                integrated into the curriculum of most graduate training  
                programs.  Additionally, suicide assessment is a knowledge  
                point tested in both the national and state examinations.

                     The Board is opposed to CE courses being mandated by the  
                legislature when the Board, is better positioned to determine  
                what areas of study will further their professional  
                development."

           The  Alameda County Psychological Association  and the  San Joaquin  
           Valley Psychological Association  both oppose the bill and write,  
           "This bill is problematic and unnecessary.  Students are given  
           continuous and constant attention towards suicidality.  Suicidality  
           is addressed in program orientation training, case conference (3  
           trimesters), advanced ethics (commitment, Tarasoff and other laws),  
           Psychological Assessment (3 trimesters or more, many testing  
           instruments assess for suicidality), and intervention courses?[We]  
           oppose this piecemeal approach to mandated continuing education.   





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           Competency in recognizing and preventing suicide is taught in  
           graduate courses, in real life applications through practicum and  
           internship, and currently offered as specialty CE courses for  
           practitioners." 

           The  National Association of Social Workers- California Chapter  also  
           opposes the bill and they write, "We believe that a social work  
           education prepares graduates with training about suicide  
           prevention.  Professionals who work in areas where they are exposed  
           to suicidal clients have a variety of CE courses they can choose  
           from to strengthen their skills.  Social work is a very broad field  
           and not all social workers will pursue their license.  We believe  
           that these courses should be voluntary and professionals should be  
           trusted to pursue coursework that will be needed on the job."

           The  California Association for Licensed Professional Clinical  
           Counselors  also opposes this bill.  In their letter they state,  
           "Suicide prevention is an important issue.  This is why education  
           on this topic is included in the curriculum for the 60-unit  
           master's degree required for LPCC licensure.  Existing law  
           (4999.33) requires students preparing for the LPCC to pass a  
           three-unit course in Crisis of Trauma.  Much of this course is  
           devoted to suicide assessment, prevention and management.  In  
           addition, suicide prevention is threaded throughout the rest of the  
           curriculum.  Requiring additional continuing education on this  
           topic would be redundant and would not likely impact the suicide  
           rate in California."
           The  California Association of Marriage and Family Therapists  oppose  
           the bill.  In their letter they write, "We believe a licensee, who  
           already has a 36 hour continuing education requirement for license  
           renewal, will select courses that enhance their practices and  
           fulfill their individual deficiencies.  Content-specific continuing  
           education coursework tends to lose value when it is mandated by the  
           State of California.  Marriage and family therapists already have  
           in their educational training, among other things: the diagnosis,  
           assessment and treatment of mental disorders, including severe  
           mental disorders; trauma and abuse, health function, and health  
           promotion; resilience and coping with trauma, tragedy threat and  
           other stresses."

         1. Oppose Unless Amended.  The  Board of Behavioral Sciences  opposes  
           the bill unless it is amended.  In their letter they write, "The  
           board recommends the bill be amended to form a task force to  
           include members of this board, its stakeholders, the Board of  
           Psychology, county mental health officials, and university  
           educators.  This group should discuss the following areas of  





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           concern to determine the best course of action:

                   Current coverage of the topic of suicide assessment,  
               treatment and management in Master's level mental health degree  
               programs, including identifying courses that typically include  
               the topic, aspects of the topic that are already being  
               addressed, and aspects of the topic where improved training is  
               needed.

                   Whether college campus mental health care workers and  
               others who are likely to encounter suicidal individuals are  
               likely to be licensed mental health care professionals, and if  
               not, how to address their training needs; and

                  Lack of resources at the county mental health care level  
               which may be impeding treatment for those who need it."

           The  American Association for Marriage and Family Therapy  also  
           opposes the bill unless amended.  In their letter they note, "We  
           believe the bill's requirements are largely redundant with existing  
           law, and thus are unlikely to have any meaningful impact on the  
           state's suicide rate?The Centers for Disease Control and Prevention  
           identifies lack of access to treatment and stigma of seeking help,  
           among other factors- not inadequate suicide training of mental  
           health professionals- as key factors increasing the risk of  
           suicide?If you are interested in ensuring adequate care for  
           suicidal patients, the severe psychiatric bed shortage represents  
           low-hanging fruit?Every mental health professional in the state is  
           currently required to receive training in suicide assessment,  
           prevention and intervention as part of the qualifying degree?The  
           training program your bill requires would be redundant and thus  
           would likely fail to have a demonstrable impact on suicide."

         1. Policy Issue for Consideration.  It has been well documented that  
           the suicide rate across the nation is rising.  What remains unclear  
           is the reason for the rising rate and what the most appropriate  
           method for preventing suicide is.  As highlighted in the background  
           section of the analysis, the best methods to prevent suicide are:  
           1) physician education and training and 
         2) restricting access to lethal means.

           While the spirit of this legislation is laudable, there is a severe  
           paucity of evidence demonstrating that requiring mental health  
           professionals to take additional education courses is a proven  
           method for preventing suicide.  As noted in the background section  
           of the analysis, mental health professionals already receive  





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           coursework and training in suicide assessment and treatment  
           interventions.  As such, this requirement may not be a fruitful  
           strategy for achieving the Author's goal.  In fact, research  
           indicates that efforts to provide education and training on suicide  
           prevention and assessment should be focused on providers who  do not   
           have mental health training as part of their education and clinical  
           background. 

           Another feasible alternative may be to form a task force, as  
           suggested by the CDC's report.  The task force could include groups  
           such as the licensing boards who regulate practice and promulgate  
           regulations regarding continuing education, accrediting agencies  
           that set standards for coursework and the mental health  
           associations who represent practitioners.  The task force could be  
           charged with identifying the best practices for suicide prevention  
           that could be implemented in the state and report back to the  
           Legislature at a specified date.  


        SUPPORT AND OPPOSITION:
        
         Support:  

        American Foundation for Suicide Prevention
        Association of California Healthcare Districts
        California Catholic Conference of Bishops
        California Federation of Teachers
        California Institute for Mental Health
        California Professional Firefighters
        California State Sheriffs' Association
        Caltrain
        Didi Hirsch Mental Health Services
        El Camino Hospital
        Family & Children Services of Silicon Valley
        Momentum for Mental Health 
        NAMI California
        NAMI Santa Clara County Board of Directors
        Veterans Caucus for the California Democratic Party

         Opposition:  

        Alameda County Psychological Association
        Board of Behavioral Sciences
        Board of Psychology
        California Association for Licensed Professional Clinical Counselors
        California Association of Marriage and Family Therapists





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        California Psychological Association
        National Association of Social Workers- California Chapter
        San Gabriel Valley Psychological Association
        San Joaquin Valley Psychological Association
        8 individuals

        Consultant:Le Ondra Clark, Ph.D.