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 this 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 upheaval 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. The introduction of the first Philippine psychology board
exam in 2014 resulted in 35 successful candidates out of 53 applicants (Inquirer.net). Among
the roughly 1,700 licensed psychologists at present, only about 800 are actively involved in
clinical practice. 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 set to 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.