New-york Limited Permit Requirements & Hours Tracker

New York’s Office of the Professions (NYS Education Department) uses a limited permit in psychology to allow doctoral graduates (and some out‑of‑state licensees) to practice under supervision while they meet the full licensure requirements. Understanding exactly what the permit allows, how many hours are required, and what “counts” under Board rules is essential, because hours that don’t meet those rules can be rejected.

---

1. What a Limited Permit in Psychology Is (and Is Not)

Under Part 72 of the Commissioner’s Regulations, the Department may issue a limited permit to practice psychology at an authorized site in New York to an applicant who has met all requirements except the examination and/or experience requirements. (op.nysed.gov)

In practice, there are two distinct limited-permit situations in psychology:

1. Limited permit for applicants gaining supervised experience for licensure (Form 5A)

   • For people who have completed a qualifying doctoral program (including the dissertation) and still need to accumulate post‑doctoral supervised experience hours.

2. Limited permit for already‑licensed out‑of‑state psychologists (Form 5B)

   • For people who hold a psychology license elsewhere, have moved to NY recently, and need to sit for the EPPP in New York. (op.nysed.gov)

Most students and early‑career psychologists are dealing with the first type, so the rest of this article focuses on that route.

---

2. Basic Eligibility for the Limited Permit (Form 5A Route)

For a limited permit to gain hours toward licensure, you must:

1. Have completed a qualifying doctoral degree in psychology

   • You must have finished all requirements of the doctoral degree including your dissertation, from a program that meets NY’s professional study requirements (i.e., NY‑registered, accredited, or deemed substantially equivalent). (op.nysed.gov)

2. Have met all other licensure requirements except exam and/or experience

   • This includes:
     • Moral character
     • Acceptable doctoral education
   • You may be missing:
     • The EPPP (exam), and/or
     • The full supervised experience requirement.

3. Be supervised by a NY‑licensed psychologist at an authorized site

   • The permit is issued for a specific setting and supervisor.
   • The supervisor must be licensed and registered to practice psychology in New York and must be the owner, employee, or consultant of the setting where you will gain experience. (op.nysed.gov)

4. File the correct forms and pay required fees

   • Form 1 – Application for licensure
   • Form 2 – Certification of professional education
   • Form 4 – Report(s) of professional experience (your internship and, later, post‑doc)
   • Form 5A – Application for Limited Permit (persons gaining experience for licensure)
   • Pay the licensure fee and the separate permit fee. (op.nysed.gov)

The Board explicitly warns that hours gained without a limited permit and/or not in an exempt setting may be considered illegal practice and will not count toward licensure. (op.nysed.gov)

---

3. Total Supervised Experience Hours Required for Full Licensure

The psychology license itself (not the permit) has a single unified experience requirement, not a split of “X direct hours and Y supervised hours.”

3.1 Total required hours

Part 72.2 states that for licensure you must complete:

• Two years of full‑time supervised experience, or the part‑time equivalent, totaling 3,500 clock hours. (op.nysed.gov)

The State Board further clarifies on Form 4 instructions that:

• “A year is defined as 1,750 hours.”
• So the experience requirement = 3,500 hours of supervised experience (2 × 1,750). (op.nysed.gov)

3.2 How pre‑doctoral and post‑doctoral hours fit together

New York allows you to credit part of your doctoral internship/practicum toward the 3,500 hours:

• You may count no more than 1,750 clock hours of supervised internship, completed as part of your doctoral degree, toward the 3,500‑hour requirement.
• The remaining hours must be completed after you receive the qualifying doctoral degree (i.e., post‑doctoral), typically under a limited permit or in an exempt setting. (op.nysed.gov)

Functionally this means:

• Typical pattern
  • 1,750 hours (one “year”) of acceptable pre‑doctoral internship
  • 1,750 hours (one “year”) of post‑doctoral supervised experience
    = 3,500 hours total

3.3 No separate “direct client vs. indirect” hour requirement

Unlike some other NY professions (e.g., psychoanalysis or mental health counseling), psychology licensure regulations do not carve the 3,500 hours into “direct client contact” versus “indirect” hours with specific numeric minimums. (op.nysed.gov)

Instead, the Board focuses on:

• Total supervised clock hours (3,500),
• Qualifying settings,
• Defined weekly supervision, and
• The experience consisting of a “planned programmed sequence of supervised employment or engagement in appropriate psychology activities.” (op.nysed.gov)

So there is not a requirement such as “1,500 hours of direct experience and 1,500 hours of other supervised hours” for psychologists in New York. The controlling requirement is 3,500 total supervised hours under the conditions described below.

---

4. What Counts as Acceptable Supervised Experience (Including Hour Structure)

The Board is specific about how hours must be structured for them to count.

4.1 Time‑based definitions

For post‑doctoral and other experience:

• Full‑time experience

  • At least 35 hours per week, and not more than 45 hours per week (op.nysed.gov)

• Part‑time experience

  • At least 16 hours per week but not more than 34 hours per week, spread over at least two days per week (op.nysed.gov)

• Continuous experience

  • Experience must be essentially continuous; for academic experience, this means at least one semester and, for teaching, at least six credit hours per semester. (op.nysed.gov)

The Board does not accept experience with fewer than 16 hours per week, and it will not count more than 45 hours per week toward the 1,750‑hour “year.” (op.nysed.gov)

4.2 Content and setting

Your supervised experience must:

• Be a “planned programmed sequence” of psychology activities consistent with the statutory definition of the practice of psychology (evaluation, diagnosis, treatment, etc.). (op.nysed.gov)
• Occur in a setting authorized to provide psychological services, such as:
  • Licensed private practices or professional entities,
  • Programs or facilities operated, funded, or approved by various NY State agencies (e.g., OMH, OCFS),
  • Federal programs authorized to provide psychological services,
  • Other entities authorized under NY or other jurisdiction’s law to provide services that are within the scope of psychology. (op.nysed.gov)

The setting must also:

• Be responsible for the services provided by you as an unlicensed individual gaining experience, and
• Use a title for you that complies with NY law (not implying independent psychologist status). (op.nysed.gov)

---

5. Supervision Requirements (Verbatim Structure from the Regulations)

The supervision requirements are rigid and tied to your schedule (full‑time vs. part‑time).

5.1 Who can supervise

• Supervision must be provided by a licensed psychologist in the jurisdiction where the experience occurs.
• In New York, the supervisor must be licensed and registered under Article 153 (psychology) or have qualifications the Department finds acceptable after review.
• The supervisor must be the owner, employee, or consultant to the entity in which the experience occurs. (op.nysed.gov)

5.2 Supervision intensity

For your experience to be acceptable, the regulations require:

• If you are full‑time (35–45 hours/week):

  • At least one hour per week of face‑to‑face individual supervision about services you rendered, and
  • An additional one hour per week of either:
    • Face‑to‑face supervision,
    • Group supervision,
    • Seminars or workshops, or
    • Apprenticeship activities. (op.nysed.gov)

• If you are part‑time (16–34 hours/week):

  • Two hours of supervision within every two‑week period, including:
    • One hour of face‑to‑face supervision, and
    • One hour that may be face‑to‑face, group supervision, seminars/workshops, or apprenticeship activities. (op.nysed.gov)

“Face‑to‑face” supervision may be delivered via secure video‑conferencing if acceptable to the Department and if confidentiality is protected. (op.nysed.gov)

These supervision amounts are part of the supervised experience; there is no separate numerical category for “supervision hours” versus “practice hours” in the way some states or professions might outline.

---

6. How the Limited Permit Itself Works (Duration and Limits)

6.1 Validity period and extensions

For the limited permit used to gain experience (the Form 5A route), Part 72.4 and Board guidance provide:

• Initial validity: up to 12 months.
• The permit may be extended for no more than two additional 12‑month periods, at the Department’s discretion, with a new permit application and fee each time, for a total of up to three years. (op.nysed.gov)
• The Department may authorize one additional 12‑month extension beyond those three years if you show “good faith efforts” to complete the exam and/or experience requirements or have other good cause; total permit time may not exceed 48 months (4 years). (op.nysed.gov)

The Q&A emphasizes that no more than four years under the permit are allowed by law. (op.nysed.gov)

6.2 Relationship to the EPPP

• The requirements to obtain a limited permit are the same as the requirements for admission to the licensing exam (EPPP): application for licensure, fees, and verification of an acceptable psychology degree. (op.nysed.gov)
• New York currently requires only EPPP Part 1 (Knowledge) for licensure; Part 2 (Skills) has not been adopted. (op.nysed.gov)

6.3 Restrictions on practice under a limited permit

The Board is clear about the limitations:

• A limited‑permit holder may not open an independent/private practice; practice must be under supervision in an authorized setting. (op.nysed.gov)
• The permit is site‑specific and supervisor‑specific. If you change settings or supervisors, you may need a new or modified permit.
• If you do not have a limited permit and you are not in a legally exempt setting, your practice may be considered illegal practice of psychology, and the experience will not be accepted for licensure. (op.nysed.gov)

---

7. Step‑by‑Step: Using a Limited Permit to Reach Full Licensure

Putting the requirements together, the typical pathway for a new doctoral graduate in psychology is:

1. Complete doctoral degree in psychology

   • Ensure the program is NY‑registered, accredited, or deemed equivalent.
   • Finish the dissertation and verify that your internship can qualify for up to 1,750 hours of supervised experience toward licensure. (op.nysed.gov)

2. Apply for licensure and limited permit

   • Submit Form 1 (Licensure), Form 2 (Education), licensure fee.
   • Have your internship supervisor(s) submit Form 4 documenting up to 1,750 hours of pre‑doctoral experience.
   • Submit Form 5A (Limited Permit) with the permit fee, including site and supervisor details. (op.nysed.gov)

3. Obtain the limited permit before starting post‑doc hours

   • Confirm the permit has been issued for the site and supervisor in question.
   • If you’re in an exempt setting (e.g., certain government or institutional settings), a limited permit may not be required—but the burden is on you to confirm that the setting is legally exempt. (op.nysed.gov)

4. Accrue the remaining supervised experience

   • Typically 1,750 hours of post‑doctoral experience to bring your total to 3,500 hours.
   • Work at least 16 and no more than 45 hours per week in a continuous block.
   • Ensure required supervision:
     • Full‑time: 1 hour/week of individual face‑to‑face supervision + 1 additional hour of approved supervision activities.
     • Part‑time: 2 hours of supervision every two weeks (1 face‑to‑face + 1 additional hour of approved activities). (op.nysed.gov)

5. Have supervisors document all experience

   • Supervisors submit additional Form 4 reports directly to the Department documenting your post‑doctoral hours and supervision.
   • The Department will review these forms to determine if the 3,500‑hour requirement has been met under the regulations. (op.nysed.gov)

6. Complete the EPPP and finalize licensure

   • Once your education and at least 1,750 hours of supervised experience have been approved, you may sit for the EPPP. (op.nysed.gov)
   • After you pass the EPPP and the Department confirms your full 3,500 hours of acceptable supervised experience, you can be granted the license in psychology and no longer need the limited permit.

---

8. Key Hour‑Related Takeaways in Board Language

To summarize the Board’s own framing of hours:

• Licensure requires “two years of full‑time supervised experience, or the part‑time equivalent…, such experience to consist of 3,500 clock hours.” (op.nysed.gov)
• “A year is defined as 1,750 hours. Full time experience is from 35 to 45 hours weekly. Part time experience is from 16 to 34 hours weekly.” (op.nysed.gov)
• No more than 1,750 hours of your doctoral internship may count; the remainder must be post‑doctoral. (op.nysed.gov)
• Acceptable experience must include the specified weekly/bi‑weekly supervision structure, provided by a qualified, licensed psychologist in an authorized setting. (op.nysed.gov)

Within that framework, the limited permit is simply the legal mechanism that allows you to practice psychology under supervision in New York while you complete the required 3,500 clock hours and the EPPP.