Can I Open a Counseling Practice Without a License?

Hi Dr. Centore,

I am currently in Massachusetts and hold an MA in Psychology-Mental Health Counseling. I am now working toward my LMHC at a community mental health clinic. I am set to take the licensing exam in a few months as well, and have completed half of the total hours needed for state licensure.
My question to you is this: If someone holds a MA in Psychology and wanted to open a 100% cash practice without diagnosing or billing insurance, is this okay? If the client is fully aware that the person is unlicensed and is not representing themselves as a licensed clinician. I have read articles by you that stated that certain terms (i.e. “mental health counselor”, etc) are regulated by the licensing board and cannot be used by unlicensed clinicians. Do you happen to know which terms in Massachusetts are and are not regulated?
I have read several of your publications and admire and respect your work. Any information you can offer me would be greatly appreciated.

Thank you in advance for your time!

-Eager Student

Greetings Eager Student,

This is a very good and specific question! I am going to tell you what I believe you can and can’t do. I am not going to tell you that I recommend it, or that I think it is a good idea, however. That being said, I think it’s fair for you to fully understand your options under the rules and law of Massachusetts.

First, the ACA (American Counseling Association) officially discourages intern-level providers to work in private practice settings, even under close supervision.

Second, as of the last time I checked (circa 2008) the regulated term in Massachusetts was “mental health counselor.” At that time, and perhaps still, a provider could work as a “counselor”, “psychotherapist,” “life coach,” “consultant,” or any number of creative designations.
This is a very good and specific question! I am going to tell you what I believe you can and can’t do. I am not going to tell you that I recommend it, or that I think it is a good idea, however. That being said, I think it’s fair for you to fully understand your options under the rules and law of Massachusetts.

First, the ACA (American Counseling Association) officially discourages intern-level providers to work in private practice settings, even under close supervision.
Second, as of the last time I checked (circa 2008) the regulated term in Massachusetts was “mental health counselor.” At that time, and perhaps still, a provider could work as a “counselor”, “psychotherapist,” “life coach,” “consultant,” or any number of creative designations.

However, if one were working as a “psychotherapist” he/she would not be able to use those hours toward their licensure hours. Also I believe that MA requires that a supervisor be on-premises during the time of services, for pre-licensure hours to count.

Things to consider if you plan on opening a “psychotherapy” practice.

Some people in the industry, including the licensure board, may perceive that you are running a practice by finding a loophole in the rules.
Your clients will no have counselor-client confidentiality privilege.
Again, you won’t be able to use the hours spent doing “psychotherapy” for your hours toward counseling licensure.
You might want to do some research into getting liability insurance that will cover the type of practice you plan to operate.
The rules may have changed since last time I looked into this. And I don’t warranty any part of my answer.

Put simply, while I believe it is possible to run the type of practice you are referring to, I think this is risky clinically, and I would recommend that you just hammer out your hours and your supervision, and get your license. You’re so close to being finished, and running a “coaching” or “psychotherapy” practice will only delay you!

[schema type=”person” name=”Anthony Centore” url=”https://plus.google.com/102833343989004980284/”]I hope this helps!

–Anthony

Dr. Anthony Centore is CEO of Thriveworks is Private Practice Consultant for the American Counseling Association, and Author of “How to Thrive In Counseling Private Practice.” Learn more at https://thriveworks.com/counseling-private-practice-book/