Maryland Registered psychology associate Requirements & Hours Tracker

Maryland’s “registered psychology associate” (RPA) status is a Board registration for master’s‑ or doctoral‑level clinicians who practice only under supervision of a licensed psychologist. It is also one of the main ways to accrue the supervised hours needed for full psychologist licensure.

Below is a step‑by‑step outline of what Maryland actually requires, with specific hour language taken from statute and COMAR (state regulations).

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1. Legal status and definition

Maryland law distinguishes between:

• Licensed psychologists, and
• Registered psychology associates (RPAs), who must always work under supervision.

Key definitions and constraints:

• A registered psychology associate is defined in regulation as an individual who meets the requirements of the Maryland Psychologists Act and is “registered by the Board to practice psychology under the supervision of a licensed psychologist.” (law.cornell.edu)
• Full‑time for an RPA is defined as providing psychological services “through direct client contact at least 26 hours per week.” (law.cornell.edu)
• By statute, an RPA may practice psychology only if:
  1. The RPA “is supervised by a licensed psychologist in accordance with regulations adopted by the Board,”
  2. The supervising psychologist “is jointly responsible for the provision of psychological services,” and
  3. The RPA uses the title “registered psychology associate” and no other title. (law.justia.com)

In other words, registration is mandatory to practice, but RPAs are not independent providers; supervision and title restrictions are built into the law.

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2. Basic eligibility to register as a psychology associate

Maryland Code §18‑302 sets general requirements for anyone seeking either a license or registration, plus specific education requirements for RPAs. (law.justia.com)

2.1 General statutory requirements (apply to RPAs)

To qualify for registration as an RPA, you must:

• Be an individual who meets the requirements of §18‑302.
• Be of good moral character.
• Be at least 18 years old.
• Reside or practice, or intend to reside or practice, in Maryland, unless the Board finds that registering a non‑resident is in the interest of Maryland’s citizens or government.
• Submit to a criminal history records check under §18‑302.1. (law.justia.com)

These are legal prerequisites, separate from the clinical training requirements.

2.2 Education pathways specific to Registered Psychology Associates

Under §18‑302(g), to qualify as a registered psychology associate, you must meet one of the following education pathways (all from programs accredited by the Council for Higher Education Accreditation, unless foreign‑educated): (law.justia.com)

1. Master’s in psychology

   • A master’s in clinical psychology, counseling psychology, or school psychology; or

2. Master’s in education with specialization in psychology

   • A master’s in education with a field of specialization in psychology or counseling psychology; or

3. Doctoral candidacy route

   • Be formally admitted to candidacy for a doctoral degree in:
     • Clinical psychology, counseling psychology, school psychology, or
     • Education with a field of specialization in psychology or counseling psychology
   • AND have completed at least 3 years of postgraduate education in psychology and passed preliminary doctoral examinations; (law.justia.com)

4. Completed doctoral degree route

   • Have completed a doctoral degree in psychology or in education with a specialization in psychology or counseling psychology; or

5. Foreign‑educated route

   • Have at least a master’s‑level degree from a non‑U.S. program that the Board determines is equivalent to one of the degrees in #1, #2, or #4. (law.justia.com)

There is no separate requirement in statute or regulation that you accrue a specific number of pre‑registration clinical hours (e.g., 1,500 direct service hours) before becoming an RPA. Instead, hours are controlled via supervision rules (see below) and, later, via the psychologist licensure requirements.

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3. Examination requirement for RPAs

For RPAs, Maryland requires only the state jurisprudence exam, not the national EPPP.

Two provisions establish this:

• Statute: An “applicant for a psychology associate registration shall successfully pass the State jurisprudence examination.” (law.justia.com)
• COMAR 10.36.01.06(B): “The Board requires applicants for registration to receive a passing score of at least 75 percent on the Maryland Examination prepared and scored by the Board.” (regulations.justia.com)

The Maryland Examination is a jurisprudence/ethics exam that covers the Code of Ethics, professional conduct regulations, and other laws related to the practice of psychology. (regulations.justia.com)

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4. Application and registration process (what you actually do)

Putting the law and regulations together, becoming a registered psychology associate typically involves:

1. Secure a qualifying degree or doctoral candidacy

   • Confirm your program fits one of the allowed categories in §18‑302(g). (law.justia.com)

2. Arrange supervision

   • Identify a Maryland‑licensed psychologist with at least 2 years of post‑licensure experience (the definition of “supervisor” in COMAR 10.36.07.02). (law.cornell.edu)
   • The supervisor must agree to accept “joint responsibility” for your services, as required by §18‑301. (law.justia.com)

3. Submit the Board’s Application for Psychology Associate Registration

   • The Maryland Department of Health site lists: General Information, Application for Psychology Associate, and Supervisory Form under “Psychology Associate Registration.” (health.maryland.gov)
   • You must disclose your supervisor(s), criminal history, and education and pay the required non‑refundable fee (exact dollar amount is set administratively, not in COMAR).

4. Complete the criminal history records check

   • This is mandatory per §18‑302(e). (law.justia.com)

5. Pass the Maryland jurisprudence exam (Maryland Examination)

   • Score at least 75% on the Board’s examination. (regulations.justia.com)

6. Receive your registration as a psychology associate

   • Once registered, your name appears in the Board’s online “Psychology Associates” verification system, which serves as the official primary source of your registration. (mdbnc.health.maryland.gov)

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5. Required supervision and “hours” while practicing as an RPA

Maryland does not say “You must complete X total RPA hours” in order to hold the RPA registration. Instead, it regulates:

• How many hours of client contact makes you full‑time, and
• How many hours of supervision you must receive, especially if you are accruing hours toward full licensure.

5.1 What counts as “full‑time” practice for an RPA?

COMAR 10.36.07.02 defines:

• Full‑time = “the provision of psychological services through direct client contact at least 26 hours per week.” (law.cornell.edu)

This definition matters because supervision minimums are set “for full‑time provision of psychological services.”

5.2 Minimum weekly supervision for RPAs

COMAR 10.36.07.03 (Responsibilities of Supervisors) specifies what constitutes “adequate and appropriate supervision” for a full‑time RPA: (law.cornell.edu)

For full‑time RPAs, supervision must be at least:

1. 1 hour or more per week

   • If the RPA has earned a doctoral degree in psychology; or

2. 2 hours or more per week

   • If the RPA has been admitted to doctoral candidacy in an approved psychology or counseling psychology program and has:
     • Completed at least 3 years of postgraduate education in psychology, and
     • Passed preliminary doctoral exams; or

3. 3 hours or more per week

   • For all other registered psychology associates (e.g., master’s‑level associates not yet in doctoral candidacy).

Additional required supervision tied to specific types of hours:

• Comprehensive testing hours:
  Beyond the weekly minimums above, supervision must also include at least 1 hour of supervision for every 5 hours of “comprehensive evaluation and testing of a client.” (law.cornell.edu)

Reductions over time:

• If an RPA has 3 years of full‑time experience (or its equivalent) as a psychology associate, the Board allows the required supervision amount to be reduced by one‑half.
• Supervision may also be reduced proportionally for part‑time RPAs. (law.cornell.edu)

Other supervision standards:

• Supervision must be face‑to‑face (which can include videoconferencing), and it must be clinical (exclusive of purely administrative oversight). (law.cornell.edu)
• If the supervisor is off‑site, quarterly site visits to the RPA’s practice location are required. (law.cornell.edu)

5.3 Recordkeeping for supervision and clinical work

COMAR 10.36.07.05 requires both supervisor and RPA to maintain detailed records of supervisory sessions and clinical documents: (regulations.justia.com)

• Written documentation must cover:
  • Dates and duration of supervision,
  • Client identifiers for cases reviewed,
  • Outcome of each case reviewed, and
  • Signatures of both supervisor and RPA.
• Supervision records must be kept at least 5 years.
• The supervisor must co‑sign clinical documents such as evaluations, releases, treatment plans, and reports (with some flexibility for routine progress notes, as long as there is no misrepresentation). (regulations.justia.com)

These documentation requirements are critical if you plan to count your RPA experience toward psychologist licensure.

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6. How RPA hours relate to full psychologist licensure in Maryland

Even though you’re asking about becoming registered as an RPA, Maryland’s regulations are written so that RPA experience is often used to meet the supervised experience requirements for psychologist licensure. That’s where you start seeing specific hour totals.

6.1 Total supervised professional experience required for licensure

COMAR 10.36.01.04 (“Professional Supervised Experience Required for Licensure – General”) establishes:

• An applicant for psychologist licensure must complete 2 years of supervised professional experience before taking the required exams.
• Those 2 years must include at least 3,250 hours of “supervised professional experience.” (law.cornell.edu)

The regulation explicitly notes:

• “Psychology associates accruing supervised professional experience toward licensure shall receive the required amount of supervision specified in COMAR 10.36.07.03.” (law.cornell.edu)

So, when you are an RPA accumulating licensure hours, your time is counted under the umbrella of “supervised professional experience” and must follow the weekly supervision standards described earlier.

6.2 Breakdown of hours for practice‑oriented doctoral programs

COMAR 10.36.01.04‑2 provides more detailed hour language for applicants from practice‑oriented programs (e.g., clinical, counseling, school psychology): (dsd.maryland.gov)

• Internship hours:
  • The internship must consist of a minimum of 1,750 hours of supervised experience, completed within 24 months.
• Pre‑internship and pre‑doctoral post‑internship hours:
  • You may count up to 1,500 hours of pre‑internship and pre‑doctoral post‑internship experience toward the 3,250‑hour supervised professional experience requirement.
• Post‑doctoral hours:
  • A maximum of 1,500 hours of post‑doctoral supervised professional experience may be used if you do not already have 3,250 pre‑doctoral hours.

These are licensure‑level hour requirements, but the regulation expressly contemplates that some of the post‑doctoral supervised experience may be accrued as a registered psychology associate under COMAR 10.36.01.04‑4. (law.cornell.edu)

6.3 Special respecialization route that uses the RPA role

Maryland Health Occupations §18‑302 also outlines a route for applicants who completed a postdoctoral respecialization certificate. For that pathway, the statute ties specific hour totals directly to time spent as an RPA: (codes.findlaw.com)

• The applicant’s respecialization program must include a minimum of 1,750 hours in a supervised internship.
• In addition, the applicant must complete “a minimum of 1,500 hours of postcertification advanced training hours or precertification hours of service as a registered psychology associate,” in accordance with Board regulations.

This is the only place where the law explicitly states both:

• 1,750 hours of internship, and
• 1,500 hours of advanced or RPA service hours,

as fixed numbers linked directly to the registered psychology associate role.

So, if you are using the respecialization route, your time as an RPA must meet that 1,500‑hour threshold as “advanced training hours” or “precertification hours of service as a registered psychology associate.”

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7. Public representations and independence limits

Once registered:

• You must refer to yourself as a “registered psychology associate under the supervision of a licensed psychologist” in all promotional materials and communications about your services.
• You may not refer to yourself as a psychologist, orally or in writing. (regulations.justia.com)
• You must ensure that those who are billed for your services are informed that the services were provided under supervision. (regulations.justia.com)
• You cannot practice independently or give the appearance of independent practice; independence would violate both statute (§18‑301) and COMAR 10.36.07.04. (law.justia.com)

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8. Practical summary of “hours” you need to think about

To become a Registered Psychology Associate (RPA) in Maryland:

• There is no Board‑mandated minimum number of pre‑registration clinical hours (such as “1,500 hours of direct experience”) merely to obtain the RPA registration.
• You do need:
  • A qualifying master’s or doctoral‑level degree (or candidacy),
  • A supervising psychologist,
  • To pass the Maryland jurisprudence exam (≥ 75%), and
  • To complete the criminal history records check and Board application.

Once you are registered, if you are using the RPA role to accrue hours toward psychologist licensure:

• You must accumulate part of the 3,250 hours of “supervised professional experience” required for licensure under COMAR 10.36.01.04. (law.cornell.edu)
• Your weekly supervision while practicing as an RPA must be:
  • 1, 2, or 3 hours per week for full‑time practice, depending on your degree level, plus
  • At least 1 hour of supervision for every 5 hours of comprehensive evaluation and testing of a client,
  • With possible reductions after 3 years of full‑time experience. (law.cornell.edu)
• If you are in the postdoctoral respecialization pathway, you must complete:
  • 1,750 hours of supervised internship, and
  • 1,500 hours of postcertification advanced training hours or precertification hours of service as a registered psychology associate. (codes.findlaw.com)

Those are the key hour‑related requirements as defined by the Maryland Board of Examiners of Psychologists and the Maryland Psychologists Act for someone who wants to become—and then effectively use—the Registered Psychology Associate credential.