PA 114 of 2026
The Bureau is aware of the recent enactment of Public Act 114 of 2026, which makes several changes to requirements for Master’s or Doctoral Temporary Limited Licensed Psychologists (TLLPs) and Master’s Limited Licensed Psychologists (LLPs). Below are answers to common questions. This document will be updated as needed. To sign up for rules updates via email, please go to www.michigan.gov/bpl and scroll to the bottom of the page.
1. As of what specific date may currently licensed Master’s LLPs legally provide behavioral health services independently, without supervision by a fully licensed psychologist?
Answer: LLPs actively licensed on October 9, 2026 may engage in the practice of psychology without supervision and shall perform an act, task, or function within the practice of psychology for which the individual is qualified by education, training, or experience. LLPs shall not perform, offer to perform, or represent that the individual is qualified to perform any of the acts, tasks, or functions within the scope of practice of psychology that the individual is not qualified by education, training, or experience to perform, or that the individual is otherwise
prohibited by law from performing.
2. Is the independent practice authority established by PA 114 of 2026 contingent upon LARA, in consultation with the Michigan Board of Psychology, first promulgating updated administrative rules, or does that authority become effective automatically on the date established by the statute?
Answer: Statute provides independent authority as outlined above for LLPs licensed on October 9, 2026. This authority may be further defined by the promulgation of administrative rules.
3. How does the 12-month transition period referenced in the legislation affect currently licensed LLPs? Does this provision delay their ability to practice independently?
Answer: This provision of the law does not delay LLPs ability to practice independently. LLPs licensed on October 9, 2026 may engage in the practice of psychology without supervision and shall perform an act, task, or function within the practice of psychology for which the individual is qualified by education, training, or experience. LLPs shall not perform, offer to perform, or represent that the individual is qualified to perform any of the acts, tasks, or functions within the scope of practice of psychology that the individual is not qualified by education, training, or experience to perform, or that the individual is otherwise prohibited by law from performing.
4. Did the statutory requirement for ongoing supervision of existing LLPs terminate on October 9, 2026?
Answer: As mentioned above, LLPs licensed on October 9, 2026 may engage in the practice of psychology without supervision and shall perform an act, task, or function within the practice of psychology for which the individual is qualified by education, training, or experience. LLPs shall not perform, offer to perform, or represent that the individual is qualified to perform any of the acts, tasks, or functions within the scope of practice of psychology that the individual is not qualified by education, training, or experience to perform, or that the individual is otherwise prohibited by law from performing.
5. What should fully licensed psychologists and their existing LLP supervisees do
regarding supervision agreements and supervisory responsibilities?
Answer: LLPs that held an active license on October 9, 2026 are no longer required to have supervision per PA 114 of 2026. The law does not contemplate what supervisors and LLPs choose to do with their supervision agreements. You may wish to seek legal counsel for additional guidance.
6. PA 114 of 2026 also makes TLLPs eligible for another renewal cycle as well as relicensure. How can I apply to get my license back?
Answer: The Bureau is in the process of making updates to MiPLUS to effectuate these changes. Information will be shared via our website
(www.michigan.gov/psychology) when these changes are complete.
7. If I earn an LLP license after October 9, 2026, can I practice without supervision?
Answer: No. If you earn an LLP license between October 10, 2026 and October 8, 2027, the provision allowing you to practice without supervision does not take effect until October 9, 2027. On that date, you may practice without supervision and perform an act, task, or function within the practice of psychology for which you are qualified by education, training, or experience. LLPs shall not perform, offer to perform, or represent that the individual is qualified to perform any of the acts, tasks, or functions within the scope of practice of psychology that the individual is not qualified by education, training, or experience to perform, or that the individual is otherwise prohibited by law from performing.
8. If I apply for an LLP license after October 8, 2027, what requirements must I meet?
Answer: There are three separate tracks:
- If you have already been granted a master’s degree in psychology when PA 114 of 2026 was enacted and are satisfying the supervised postgraduate experience between October 9, 2026 and October 9, 2027: 1 year of supervised postgraduate experience, totaling not less than 2,000 hours, of supervised postgraduate experience.
- If you are granted a master’s degree in psychology before August 31, 2027: 2 years, totaling not less than 3,000 hours, of supervised postgraduate experience.
- If you are granted a master’s degree in psychology on or after August 31, 2027: 2 years, totaling not less than 4,000 hours, of supervised postgraduate experience.
The supervised postgraduate experience must take place in an organized health care setting or other arrangement as established by the Department in consultation with the Board. This experience must be supervised by a psychologist who has a license other than a limited license, or if a psychologist who has a license other than a limited license is not available, by a psychologist who has at least a master’s degree in psychology and at least 3 years of experience in the practice of psychology or by any other individual approved by the board.