The California Board of Behavioral Sciences is proposing significant changes to the exam and licensure process for LMFTs, LPCCs, and LCSWs. This is a summary of the proposed changes as of April 29, 2025. Taken together, the changes are large and complex, and will require changes to a lot of pieces of law and regulation. The entire process of implementing these changes will take years.
You also should bear in mind that, while the BBS has been working on these for a while, at this point they are still proposals. They may happen as planned, but they also could change significantly along the way, or not happen at all.
1. Changing the six-year rule to a seven-year rule
The “six-year rule” actually refers to two connected-but-different rules. An associate registration is valid for up to a total of six years, and when you apply for licensure, the board will count backward up to six years to determine what supervised experience you can count.
Under the BBS proposal, both of those six-year rules would become seven-year rules. And there’s an added twist: As of now, someone on a subsequent registration number (that is, they went through all six years on an initial registration, and so they applied for and received a separate registration to keep gathering experience toward licensure) cannot work in a private practice setting. Under the BBS proposal, someone nearing the end of their initial (what would be seven) years of registration could apply for a one-time hardship extension that would allow them to continue working in a private practice under a subsequent registration for up to two years while they finish up their licensure requirements.
If all goes smoothly, the BBS anticipates that these changes would take effect on January 1, 2027.
2. Changing exam timing
Under current rules, associates must take their Law & Ethics Exam in their first year of associate registration, and continue attempting it at least once per year until they pass it. (Under most circumstances, once you pass it, you never need to take it again.) Associates then finish up their 3,000 hours of supervised experience, and only at that point can they be declared eligible to take their Clinical Exam.
Under the current BBS proposal, associates would still be eligible to take the Law & Ethics Exam once they’re registered, but the requirement to attempt the Law & Ethics Exam in the first year of registration would go away. There’s still accountability for keeping up with changes in professional standards, thanks to the BBS requirement that all associates take a 3-hour CE course in Law and Ethics each year prior to associate registration renewal.
More importantly, the BBS proposal would allow associates to apply for Clinical Exam eligibility once they have completed 850 clinical hours of supervised experience toward licensure. You would still need to complete 3,000 hours before getting licensed, but in effect, you could start attempting the Clinical Exam earlier along the road to licensure.
This is, at least in part, an effort to address the significant and disparate negative effects of clinical exams, which – regular reminder here – have never been shown to correlate with actual safety or effectiveness in clinical practice. They’re also not developed in accordance with industry standards. But I digress. TLDR: Small but important step in the right direction.
If all goes smoothly, the BBS anticipates that the changes to the timing of the Law & Ethics Exam would take effect on January 1, 2027. The changes in clinical exam timing would not take place until at least January 1, 2028. Those clinical exam changes may not take effect at the same time for all three professions (MFT, PCC, CSW), since the BBS has to work with different external organizations to get their approval for the changes, in addition to changing the laws and regulations that specifically govern the BBS.
3. Changing the MFT Clinical Exam
This one is the simplest to explain. The BBS is actively working on a planned change away from the California MFT Clinical Exam and to the National MFT Exam (sometimes called the AMFTRB Exam, since AMFTRB – the Association of MFT Regulatory Boards – is the organization that develops the test).
I've previously discussed the impacts of this specific change. While the national exam will improve license portability, it does not by itself grant those who pass it any additional practice privileges. MFT licensure, and the associated practice privileges, are still awarded state by state.
Even if all goes smoothly, the BBS currently anticipates that the changeover would not happen until at least January 1, 2028.
Planning for the changes
At this point, there’s really nothing to do or to worry about related to these. They’re good proposals (I think), and they’ve been through a lot of discussion and preparation at the BBS, and they’re starting the long process of getting legislative and regulatory approval.
In terms of advocacy, the BBS will continue to discuss progress in board meetings. Whether you support, oppose, or are indifferent to these proposals, you can always voice your opinion to the board at their public meetings.
An official summary of the BBS proposal can be found here.
