Report Examines Pathways to Licensure for Behavioral Health Providers and Identifies Policy Changes to Reduce Barriers

Makes recommendations to strengthen the behavioral health workforce amidst increasing demand for services

BOSTON — Today, the Massachusetts Health Policy Commission’s (HPC) Behavioral Health Workforce Center released Strengthening the Behavioral Health Workforce, which examines the pathways to behavioral health (BH) provider licensure and identifies areas in the licensure process that may be barriers to building and maintaining a high-quality, diverse BH workforce. This report is part of a series of studies the Legislature directed the Behavioral Health Workforce Center to complete.  

Massachusetts has one of the highest per capita counts of BH providers in the country. However, patient access barriers persist, and many individuals and families report challenges with finding needed care, as demand for BH services in Massachusetts is growing. Between 2017 and 2025, the percentage of Massachusetts residents who reported using BH services climbed from 18.6% to 22.8%. In 2025, 1 in 10 residents in Massachusetts aged 5 years and older reported an unmet need for behavioral health care in the past 12 months. Black and Hispanic residents and those with lower family incomes were most likely to report unmet needs.

At the same time, there have been shifts in employment of BH providers. Between 2019 and 2025, the number of individuals primarily employed as a social worker in community health centers or human service agencies in the Commonwealth declined by 8%, and the number of people primarily employed as a counselor or psychologist in such settings rose, 12% and 54% respectively. The number of behavioral health providers whose primary employment is self-employment has increased across psychologists, counselors, and social workers, although most providers remain primarily employed in other settings. Because providers may hold multiple roles, additional data is needed to better understand where behavioral health services are delivered across the Commonwealth.

Alongside analyses of the composition of the workforce, the report identified challenges in the process for BH providers to become licensed to provide care, including a complex and time-consuming licensure process and potential barriers to entry for providers and trainees from historically underrepresented communities.

“Massachusetts’ behavioral health workforce is experiencing capacity challenges alongside significant shifts in the workforce, perpetuating access issues for Commonwealth residents during a time of increased behavioral health care demand.” said Martin Cohen, Vice Chair of the HPC Board. “We must reassess our behavioral health care licensure process to reduce barriers to entry, particularly for providers and trainees from historically underrepresented communities, or we risk fewer future clinicians choosing to enter the field, and ultimately, fewer residents able to access the critical behavioral health care they need.”

“With increasing need for behavioral health care services, it’s clear that the Commonwealth needs to act to strengthen our behavioral health care system, and this should begin with strengthening our workforce,” said Kiame Mahaniah, EOHHS Secretary for Health and Human Services. “Massachusetts has a strong track record of innovation and investment in the BH workforce, and the Commonwealth has an opportunity to be a national leader by taking action to address avoidable barriers to obtaining BH licensure while maintaining high standards for quality care.”

“Massachusetts has already begun taking action to streamline the licensure process for providers, which has resulted in reduced processing times over the past 3 years. However, there is more that can be done to support our current and future workforce, by simplifying pathways and ensuring processes are equitable for all applicants, which will ultimately help to strengthen the behavioral health care delivery system,” said Amy Doyle, HPC Behavioral Health Workforce Center Director. “The HPC’s Behavioral Health Workforce Center will continue to work alongside our partners in EOHHS and stakeholders across the health care system to continue developing a path forward.”

Key Findings:

• The graduate-level BH workforce, such as clinical psychologists and Licensed Certified Social Workers (LCSWs), is primarily composed of individuals between the ages of 25 and 54. However, more than 25% of the current BH workforce is at or within 10 years of the retirement age of 65. Counseling and social work providers tend to be slightly younger, while psychiatry and psychology providers tend to be slightly older.
• The BH workforce examined in this report has experienced shifts in employment patterns across professions in recent years, including increases in psychologists and counselors employed by health and human services organizations and agencies and a decline in social workers employed in these settings. These trends do not necessarily reflect changes in the overall number of providers working in behavioral health, however, as available data do not clarify the extent to which social workers are transitioning to private practice, moving to other fields, or retiring.
  
  • The number of employed psychologists and counselors in Massachusetts grew between 2019 and 2025, 54% and 12% respectively. 
  • However, as of May 2025, the number of employed social workers in the Commonwealth was 8% lower than in May 2019, which may suggest social workers are shifting into different roles within the BH field, entering private practice, or leaving the field entirely.
• The clinical supervision requirement is an important component for independent BH licensure.  However, because it is challenging for many to find qualified, available supervisors, it is and is a significant barrier in the licensure process.
• Numerous practical and equity-related concerns have been raised about Massachusetts’ requirement that master’s-prepared social workers pass the Association of Social Work Boards (ASWB) Masters Exam prior to applying for the non-independent LCSW license. 
  
  • Some license-seeking providers in Massachusetts have expressed concerns about the cultural inclusivity of test questions and a possible disconnect between exam performance and preparedness to be a practicing provider. 
  • Among first-time test takers of the ASWB Masters Exam in Massachusetts from 2018-2021, 91.1% of White test takers passed on the first attempt, compared to 54.1% of Black test takers and 71.7% of Hispanic/Latino test takers.
• While BH licensure processing times have improved since 2023, license-seeking providers still report that the licensure process can be time consuming, with certain license types demonstrating long initial licensure application review times.  
• Persistent barriers are likely negatively impacting BH providers and trainees from historically underrepresented communities. 
  
  • Analysis of BH providers by racial/ethnic group found under-representation of Black and Hispanic people among psychologists and psychiatrists in Massachusetts. Only 6% of psychologists and 5% of psychiatrists in Massachusetts identified as Black, and only 9% of psychologists and 7% of psychiatrists identified as Hispanic or Latino. 
  • Clinicians of color and clinicians for whom English is not their first language may struggle to find culturally and linguistically responsive mentorship and supervision.

Key Recommendations:

1. The Massachusetts Legislature should invest in efforts to sustain and expand state funding to support clinical supervision programs. Funds should be directed to BH care organizations to compensate for non-billable time dedicated to supervision, as well as compensating clinical supervisors directly, to alleviate the financial burden on these organizations and clinicians.  
2. The Massachusetts Department of Public Health should consider updating social work licensure regulations to enable LCSWs pursuing independent licensure to receive cross-discipline supervision for up to fifty percent of required hours by expanding the definition of acceptable independently licensed clinical supervisors. The expanded definition should be applied in accordance with each provider’s scope of practice. 
3. The Massachusetts Board of Registration of Social Workers and Department of Public Health should consider updating licensure regulations to temporarily remove the ASWB Masters Exam requirement from the LCSW application process for a trial period of four years; and evaluate the subsequent impact on size, quality, and makeup of the BH workforce for use in consideration of future requirements. 
4. The Massachusetts Legislature should provide new funding to waive licensure fees for all BH provider types working in community-based settings, including allied mental health professionals, to reduce barriers for early career practitioners through June 2030.  
5. The Massachusetts Legislature should invest in efforts to support expedited processing of BH initial licensure applications.  
6. The Massachusetts Department of Public Health should consider updating social work licensure regulations to allow Licensed Independent Clinical Social Workers (LICSW) to earn up to eight (8) Continuing Education (CE) credits per licensure period for providing clinical supervision to graduate social work students or LCSWs who are pursuing independent licensure.  
7. The Massachusetts Legislature should direct and allocate funding to the Massachusetts Health Policy Commission’s Behavioral Health Workforce Center, in partnership with the Massachusetts Department of Public Health, to develop educational resources outlining the steps in the licensure process and the specific requirements associated with each license type identified in this report. 

Learn more about the report’s findings and recommendations on the HPC’s website. 

This research will be presented at a webinar jointly hosted by William James College, Who Gets to Practice? Examining Barriers to Behavioral Health Licensure in Massachusetts, on Thursday, December 1st from 12:00 – 3:00 pm.