Protesting Rules for N.J. Certified Psychoanalysts sign now



PETITION TO THE NEW JERSEY CERTIFIED PSYCHOANALYSTS ADVISORY COMMITTEE AND THE DIVISION OF CONSUMER AFFAIRS

TO: Elaine DeMars
Managing Executive Director
Certified Psychoanalysts Advisory Committee
P.O. Box 45050
124 Halsey Street
Newark, New Jersey 07101

& TO: Reni Erdos,
Director, New Jersey Division of Consumer Affairs
P.O. Box 45027
Newark, N.J. 07101


We, the undersigned, are psychoanalysts who practice throughout New Jersey. We are responding to the Proposed New Rules, N.J.A.C. 1342A, promulgated by the Director of the Division of Consumer Affairs, with the assistance of the Certified Psychoanalysts Advisory Committee, to implement the provisions of N.J.S.A. 45:14BB-1 et seq., the Psychoanalysts State Certification Act.

DANGER TO PUBLIC SAFETY

We have serious concerns about and strenuous objections to the rules as proposed. We believe these rules will place at risk those residents of New Jersey who seek help from a "certified psychoanalyst" and will endanger, rather than protect, the public safety.

Psychoanalysis is a unique and intensive form of treatment. Properly conducted, it can promise transformative emotional change and growth for an individual unlike any other type of treatment. Insufficiently intensive, the patient will not experience the structural emotional change he or she desires and thereby will have been misled by the therapist. Even more, psychoanalysis is capable of actually harming a patient when the psychoanalyst is not adequately trained or when the patient is not suitable for an analysis. Because strong emotional attachments occur in psychoanalysis regardless of the skill of the therapist, it becomes very difficult for patients with a poor psychoanalytic experience to move on, let alone seek better treatment.

Thus, careful training of psychoanalysts is essential, and what is most essential in fact, what differentiates psychoanalysts from psychotherapists is that the psychoanalyst's training must be intensive also. Without an in-depth awareness of his or her own psychological vulnerabilities, a psychoanalyst may react adversely to the strength of the emotionsoften negative and directed toward the analystthat the patient necessarily experiences in psychoanalysis. If the analyst responds with defensiveness when faced with a patient's rage, pain, contempt, fear, hostility, or denial, the analyst will not only be less than helpful; he or she also risks doing considerable psychological damage.

THREE TIMES WEEKLY: A STANDARD OF PSYCHOANALYTIC TRAINING
Intensive training in psychoanalysis throughout almost all the psychoanalytic community in New Jersey (as well as in the United States and in the world) requires a frequency of at least three times a week analysis for the prospective analyst himself (the training analysis) and three times a week for the patients he or she treats during training under the supervision of an experienced analyst (the control analyses). However, at no place in the Advisory Committee proposed rules is there any frequency requirement whatsoever.

We cannot emphasize the importance of this omission strongly enough: once - or twice-weekly treatment is not sufficient to ensure either (a) the prospective analyst's or candidate's appreciation of what it is like to be in a deeply meaningful, emotionally powerful therapeutic relationship, or (b) adequate resolution of personal problems that might interfere with the candidate's clinical judgment. Although some individuals can experience an in-depth psychoanalytic process at lower frequency, the aim of preparing prospective analysts to work with all types and degrees of psychopathology requires trainers and credentialers to err in the direction of more rather than less intensity.

INDIVIDUAL SUPERVISION: A STANDARD OF PSYCHOANALYTIC TRAINING


In addition, the almost universal standard for training in New Jersey, the United States, and the international community is that the control analysis be conducted in individual supervision, rather than group supervision. In this way the incredibly intense emotional forces, that affect both the patient and the candidate analyst during a control analysis, are followed and addressed in minute detail (what we call "process") with regard in particular to transference and countertransference reactions. However, section 13:42A-2.2 (a)(iv) of the proposed regulations permits there to be 50 hours of group supervision -- an anomaly that would deprive the candidate analyst of a full emotional understanding of the individual analytic process.

DISREGARD OF THE MAJORITY PSYCHOANALYTIC STANDARDS

The standards articulated above represent the minimal training requirements of the wider psychoanalytic community in New Jersey and the United States. The following national organizations have ratified such standards: National Membership Committee on Psychoanalysis in Clinical Social Work (Jan. 13, 2001); Division of Psychoanalysis, American Psychological Association (Jan. 27, 2001); American Psychoanalytic Association (a largely medical group; May 3, 2001) and American Academy of Psychoanalysis (December 7, 2000). Over 300 psychoanalysts in New Jersey are members of one or more of these organizations.

In addition, these are the standards of the majority of institutes and psychoanalytic societies in New Jersey, despite their often very different theoretical approaches to treatment: the Institute for Psychoanalysis and Psychotherapy in New Jersey (IPPNJ)-- the largest New Jersey institute at well over 150 members; the Contemporary Center for Advanced Psychoanalytic Studies (CCAPS), a free-standing institute affiliated with FDU; The New Jersey Psychoanalytic Society, most of whose members trained at long established institutes in New York City affiliated with the International Psychoanalytic Association or the American Psychoanalytic Association; The New Jersey Institute for Training in Psychoanalysis (NJITP), in existence for 32 years in Teaneck; the extension division in Englewood of the New York Institute for Psychoanalytic Self Psychology (NYIPSP).

In fact, we are concerned that the failure to adopt sufficiently stringent proposed standards is a consequence of the Advisory Committee psychoanalyst members being composed exclusively of members of only one minority group, the Society of Modern Psychoanalysis, or "Spotnitzians". This group does not represent the majority of psychoanalysts in New Jersey mentioned above, nor the standards of the majority of psychoanalysts in New Jersey who, no matter their academic mental health training, or psychoanalytic orientation, believe that three time a week training is essential, as is individual supervision. Nor is there any evidence that the Advisory Committee during its four years has made any effort to consult with any of the New Jersey or national organizations referred to above in making its determination about appropriate qualifications for certification. A fair and balanced Advisory Committee is essential to protect the public safety and welfare.

In addition, a fair and balanced Advisory Committee is essential in preparing an examination which will be appropriate. At present, the proposed examination will not be influenced by the psychoanalytic thought of the wider psychoanalytic community.

LACK OF CLARITY CONCERNING FOUR LICENSED PROFESSIONS

There is no comment in these rules on the status of New Jersey psychoanalysts who have been practicing pscyhoanalysis, many for decades, in accordance with their professional licenses ( in Medicine, Psychology, Social Work, or Advanced Practice Nursing), who belong to local and national organizations whose membership requirements are more stringent than those proposed, and who may elect not to seek a State Certified Psychoanalyst title.

MISLEADING THE GENERAL PUBLIC

Finally, we believe that the State -- as embodied in the term "State Certified Psychoanalyst" --calling once- or twice-weekly treatment "psychoanalysis" will cruelly mislead patients who desire significant change in their functioning to believe they are obtaining the transformative benefits of the most intensive type of treatment, when in fact this will not be the case. Psychotherapy can be very helpful in alleviating symptoms, and for many people it is the treatment of choice, but it should be an informed choice that distinguishes it from the benefits that can be obtained through more intensive psychoanalysis.

RECOMMENDATIONS

First, we recommend clarification from the Division of Consumer Affairs:

#That it be clarified as to the status of those who have been practicing psychoanalysis in the four licensed professions (Medicine, Social Work, Psychology, and Advanced Nursing) as part of their right to conduct psychotherapeutic treatment, who wish to continue to do so but who may not want to be State Certified Psychoanalysts.
Next, we suggest in the future:

#That the composition of the psychoanalytic members of the Advisory Committee be changed, as an added protection to the general public, to be more fully balanced and to be more fully representative of the wider psychoanalytic community in this State.

Lastly, we strongly recommend the following three specific changes to the rules proposed by the Division of Consumer Affairs and the Certified Psychoanalysts Advisory Committee:

One: IT BE REQUIRED THAT TRAINING, THAT IS PERSONAL, ANALYSIS BE CONDUCTED AT LEAST THREE TIMES WEEKLY. [Amend 13:41A-2.2(a)2.iii to read "Three hundred hours of personal psychoanalysis at a frequency of at least three times weekly . "]


Two: IT BE REQUIRED THAT CONTROL, THAT IS SUPERVISED, CASES BE
CONDUCTED AT A FREQUENCY OF AT LEAST THREE TIMES WEEKLY. [Amend 13:41A-2.2(a)2.iv to read "One hundred fifty hours supervision of psychoanalytic cases seen at a frequency of at least three times weekly. . . ."]


Three:. IT BE REQUIRED THAT ALL CONTROL CASES BE SUPERVISED IN
INDIVIDUAL SUPERVISION ONLY. [Amend 12:42A-2.2(a)2.iv as follows:
" . . .plus a minimum of 100 individual supervision with at least one other supervisor" and cross out "at least 50 of those 100 hours shall be individual supervision")

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Christine FlowersBy:
People and OrganizationsIn:
Petition target:
Elaine De Mars, Advisory Committee & Reni Erdos, Director N.J Division of Consumer Affairs

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