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Nevada, perpetually ranked one of the worst states in the nation for mental health services, is the only state that requires applicants for licensure as a psychologist to pass a test that is deemed by critics to be racially biased, and was scrapped last year by the national organization that developed it.
“In Nevada we are struggling with mental health support to begin with,” says Dr. Christopher Shewbarran, president of the Nevada Psychological Association. The test in question, the Examination for Professional Practice in Psychology Part 2 (EPPP-2) is “an additional barrier to getting licensed psychologists in our state.”
Nevada has 673 licensed psychologists, according to the Nevada Board of Psychological Examiners (NBOP). It’s unknown how many are employed full-time.
The state has the lowest ranking in the nation (51st) for mental health services for youth, determined by the prevalence of mental illness and low rates of access to care, according to a 2022 study from Mental Health America, a national advocacy organization.
Statewide, there is one mental health professional for every 460 residents, and every Nevada county is federally designated as having a mental health provider shortage, according to a separate 2023 study from the UNLV/Brookings Mountain West. Nevada would need 235 mental health professionals to eliminate the shortage designation.
In the last three years, the state has approved licenses for an average of 116 new psychologists a year, according to NBOP.
The EPPP-2 is designed to measure clinical skills, such as interacting with patients and navigating ethical issues, and is taken by applicants who successfully complete the EPPP, which evaluates knowledge.
The EPPP-2 was to become a requirement for licensure in all states beginning in 2026, however, regulators in Georgia and Nevada adopted the requirement in 2019. Last year, the Association of State and Provincial Psychology Boards (ASPPB), which developed the test, issued a statement saying it is putting the requirement on ice.
“In response to ongoing feedback from our membership and the broader professional, educational, and training communities, the Board has decided it is time to shift from conflict to resolution,” the ASPPB board said in a statement. Instead, the ASPPB will “explore the feasibility of creating a single-session exam that integrates both knowledge and skill assessment.”
The decision came after Texas regulators led the fight to eliminate the test, alleging it was racially biased and costly.
Georgia regulators reacted to the news by allowing applicants to seek a waiver relieving them of the requirement to take the EPPP-2, however, the Nevada board has taken no action.
“Most applicants apply for licensure by endorsement and are not required to take the EPPP-2,” says Laura Arnold, executive director of the Nevada Board of Psychological Examiners , which regulates psychologists. The board’s members declined to be interviewed for this story.
In Nevada, the EPPP-2 is required for unlicensed applicants as well as those licensed in other states after November 1, 2020. It costs $450 to $500, on top of the $800 charged for the EPPP. Applicants who take the tests more than once are charged each time.
The extra step to licensure places Nevada at a competitive disadvantage with other states, according to critics.
“We do have great schools here in Nevada, with the University of Nevada, Reno and University of Las Vegas training graduate students,” Shewbarran of the NPA said during a phone interview Tuesday. “But the EPPP-2 has been a barrier for those students considering licensure in Nevada.”
According to Shewbarran, a number of post graduates who have completed the requirements for licensure with the exception of passing the EPPP-2, “have actually taken the exam multiple times, and have chosen to get licensed in another state.”
In September, the NBOP reported that since Jan.1, 2000, 72% of applicants for licensure in the state were successful. Of the 28% who were not licensed, 80% did not complete their application, 11% withdrew from the process, and 9% of the applications were denied.
Some 150 applicants are in various stages of the licensure process, which takes more than six months on average, according to NDOP board minutes. The duration of the process is unlikely to go down because in 2020 and 2022, the board office “was not adequately staffed,” executive director Arnold told the board.
The requirement places “an additional burden that other states do not currently have in place, which will likely result in disincentivizing psychologists from pursuing licensure in this state,” Dr. Sam del Castillo wrote to the board in 2023, asking it to reconsider its policy. “This additional burden effectively limits licensure portability and equivalency across states, which ASPPB has expressed seeking to create more uniform requirements for licensure.”
Requiring the exam when it’s not a requisite in other states “is the opposite of creating uniform standards,” del Castillo wrote.
The policy could create public confusion and “perhaps open psychologists to legal liability given that this would essentially nullify their license in the state” until they are able to pass the exam, according to del Castillo.
He notes that Gov. Joe Lombardo issued an order directing state boards to suspend the issuance of new regulations in an effort to streamline licensure processes, and says Lombardo “rightfully points to Nevada as among the most onerous states in terms of licensing requirements.”
On Friday, the NBOP, which regulates psychologists, will hear from a representative of the ASPPB. The board declined to discuss the matter with the Current.
Widening the gap of disparity
Psychology is a discipline dominated by white people.
In 2019, the American Psychological Association (APA) found about 83% of U.S. psychologists are white, down only slightly from 2009, when 85% were white. Hispanics make up 7% of psychologists, 4% are Asian, and 3% are Black.
“Typically, folks are going to be more likely to seek out a provider” with whom they identify, says Shewbarran of the NPA, noting that lack of racial diversity among clinicians “is absolutely a barrier” to treatment in urban areas such as Las Vegas and Reno.
To achieve racial parity with the state population they serve, 60% of practitioners would be white, 30% Latino, 11% Black, and 10% Asian, according to the U.S. Census Bureau.
The EPPP and the EPPP-2 widen the gap of disparity by serving “as gatekeeping tools preventing psychologists of color and those from lower socioeconomic backgrounds from accessing the profession they have spent years in training,” del Castillo wrote in public comment to the NDOP in October 2023.
A 2009 study reported the percentage of ethnic minority students in doctoral programs was significantly and negatively associated with the EPPP pass rates.
In 2019, New York data spanning a quarter of century found that of 4,892 applicants, African American applicants who took the EPPP had a failure rate of 38.5%, Hispanic test takers had a failure rate of 35.6%, and white applicants had a failure rate of 14%.
The study, replicated in Connecticut in 2021, found a failure rate of 5.75% among white applicants, 23% among Blacks, and 18.6% among Hispanics.
A primary concern with Nevada’s early adoption of the test, del Castillo wrote, is “the dearth of peer-reviewed scientific literature on the validity” of the test, a concern echoed by others.
By requiring the EPPP-2, the board “is creating a problem that doesn’t exist,” del Castillo argued, adding “there is no evidence of an increase in complaints against psychologists, demonstrating that current safeguards are working as intended. Why create additional burdens in the licensure process when there is no issue in quality of care or patient safety?”