Letter from NBCC to Governor O'Bannon

October 19, 1998

Governor Frank O’Bannon
State of Indiana
Office of the Governor
State House
Room 206
Indianapolis IN 46204

Re: Law #868IAC 2-1-1
Authority IC 25-33-1-3
Affected IC 25-33-1-14

Dear Governor O’Bannon:

I am writing on behalf of 395 National Certified Counselors (NCCs) who are residents of Indiana. These counselors are practicing in mental health clinics, state-supported hospitals, schools and universities and are all master’s level or above trained professionals. They will be impacted by a rule promulgated by the Indiana State Psychology Board (ISPB)and administered by ISPB. That rule is required in 868IAC 2-1-1.

The National Board for Certified Counselors, Inc. (NBCC) requires that all NCCs complete a master’s degree in counseling; many such programs are supported by your state funds. We also require that students be trained in psychological testing and research foundations. Again, your state funds support those courses as each of the university programs (both state institutions and state-recognized private institutions) requires testing training as a part of the required curriculum. Further, each NCC (as well as each licensed mental health professional in Indiana) must answer test items relating to psychological testing.

Yet, ISPB, by law, is required to present a list of psychological tests which would be restricted to their licensed use only. NBCC categorically challenges each test listed as an infringement upon the ability to use instruments of our profession, counseling. Further, we individually challenge the list of 318 instruments in the pages to follow.

Before listing our specific objections to each instrument, we officially ask for a freedom of information release from ISPB for the following:

1. Criteria used for selecting the 318 instruments.
2. The names, degrees and current work settings of all personnel who deliberated on the test selection.
3. Dates and minutes of all deliberations involving the selection of the 318 tests.
4. A list of the resources used to accumulate information about these 318 tests.
5. A description of the resource library used by the Board and an invitation to access that library.

We also request an extension to the period of comment so that we may analyze the information in the freedom of information request.

Below is a list of National Certified Counselors who are among our 395 Indiana certificants and can be contacted directly by your office. And, on request, we will supply the full list of 395, should you wish to correspond with them.

John Bloom, NCC, Butler University, Indianapolis
Ronald Goodman, NCC, Butler University, Indianapolis
Thomas Keller, NCC, Butler University, Indianapolis
Rex Stockton, NCC, Indiana University, Bloomington

Thank you for your attention to this matter. Following our signatures, please note the challenges to the list as part of this letter.

Sincerely,

Sandra I. Lopez-Baez, Ph.D., NCC, LPC   Thomas W. Clawson, Ed.D., NCC, LPC

SIL/TWC/mwf

cc: Jeffrey A. Modisett, Attorney General
 Vaneeta Kumar, Deputy Attorney General
 Barbara M. McNutt, Director, Indiana State Psychology Board
 William M. King, Ed.D., Heartland Counseling
 William Keown, Esquire