Position Paper on Resolution No.
4 of Section 33(B) on the Issuance of
       Permit to operate a Psychology or Psychometrics Office,
                      Center, Clinic, or Facility
                       Ervin D. Salupare, PhD SPED and IE
      As a future psychologist, I firmly oppose the recently issued resolution No.
4, which outlines regulations for implementing Section 33(B) of Republic Act No.
10029, or the Philippine Psychology Act of 2009. This section pertains to issuing
permits for psychology or psychometrics offices, centers, clinics, or facilities.
While the intention is to ensure high-quality psychological services, I believe that
the requirements laid out in the resolution might overreach their goals,
potentially leading to the closure of numerous mental health services across the
nation.
      I would like to shed light on the current state of cataclysm within the
realm of Philippine professional psychology. In this position paper, I will critically
assess the impact of these regulations and advocate for a more balanced
approach that upholds the accessibility and quality of mental health services in
the Philippines.
       I understand that practicing psychology in the Philippines requires at least
a master’s degree, and those engaged in clinical practice must undergo training
in graduate-level clinical or counseling psychology programs. However, what
concerns me is that our existing psychology law fails to distinguish between
clinical and nonclinical psychologists, thereby allowing various specializations to
obtain licensure. Among the roughly 1,400 licensed psychologists in 2021, only
more than half are actively involved in clinical practice (The Manila Times, 2021).
Given this scarcity, it is not surprising that waitlists in psychology clinics can
extend for several months.
      It is puzzling to me that, in light of this scarcity, the Board of Psychology
has introduced requirements that could potentially hinder mental health services
in the Philippines. The stipulated requirements dictate that each clinic or center
must be led by a psychologist with at least seven years of experience, including
three years in a supervisory role. However, projections suggest that only around
100 psychologists in the country meet this criterion. Given that the Mental Health
Act mandates mental health services in diverse institutions, I am concerned that
the number of qualified psychologists falls significantly short of what is needed.
      Furthermore, there are situations where only few psychologists serve an
entire province. If this resolution is enforced, it would prevent these
professionals from establishing or maintaining a clinic, forcing individuals to
travel across provinces to access mental health support. Moreover, the
requirement for a full-time head of psychological services could adversely impact
nonprofit and community organizations that lack the resources for such
appointments. Presently, many psychologists lead such initiatives on a voluntary
or consultant basis, aligning with limited budgets while juggling multiple
responsibilities. Forcing a full-time position without adequate compensation
poses financial difficulties.
       With the resolution taking effect, I am compelled to urge the Board of
Psychology to consider the concerns of professionals in the field. I believe that it
is crucial for the board to implement a moratorium on the resolution until well-
thought-out policies can be formulated. These policies should aim to enhance the
quality of mental health services without jeopardizing their availability. I strongly
believe that finding the right balance between regulatory oversight and the
urgent need for accessible and effective mental health services is paramount. By
heeding these considerations, I plead the Board of Psychology to navigate this
complex terrain and ensure that the regulations introduced uphold the
accessibility and diversity of psychological practices across the Philippines.
References:
The Manila Times (2021) Championing mental health for a more dignified life,
      The Manila Times. Available at:
      https://www.manilatimes.net/2021/02/04/opinion/columnists/championing
      -mental-health-for-a-more-dignified-life/836649 (Accessed: 26 August
      2023).