The opinion
Third District Court of Appeal
State of Florida
Opinion filed September 09, 2015.
Not final until disposition of timely filed motion for rehearing.
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No. 3D15-417
Lower Tribunal No. 14-2670
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Ruth C. Prevor,
Appellant,
vs.
Department of Health, Board of Psychology,
Appellee.
An Appeal from the Department of Health, Board of Psychology.
Ruth C. Prevor, in proper person.
Pamela Jo Bondi, Attorney General, and Rachel W. Clark (Tallahassee),
Assistant Attorney General, for appellee.
Before SUAREZ, C.J., and ROTHENBERG and LAGOA, JJ.
ROTHENBERG, J.
Ruth C. Prevor (“Dr. Prevor”) appeals from a final order entered by the State
of Florida, Board of Psychology (“the Board”), denying her Application for
Licensure by Endorsement. As the Board properly concluded that Dr. Prevor
failed to meet the educational requirements for licensure by endorsement, we
affirm.
Dr. Prevor filed an Application for Licensure by Endorsement pursuant to
section 490.006(1)(c), Florida Statues (2014), which provides as follows:
(1) The [D]epartment [of Health] shall license a person as a
psychologist . . . who, upon applying to the department . . . ,
demonstrates . . . to the [B]oard [of Psychology] that the applicant:
....
(c) Possesses a doctoral degree in psychology as described
in s. 490.003 and has at least 20 years of experience as a licensed
psychologist in any jurisdiction or territory of the United States within
25 years preceding the date of application.
Section 490.003(3)(b), Florida Statutes (2014), provides in relevant part that a
“doctoral degree in psychology” means “a Psy.D., an Ed.D. in psychology, or a
Ph.D. in psychology” from an accredited educational institution with a psychology
program that, “at the time the applicant was enrolled and graduated, had
programmatic accreditation from an agency recognized and approved by the
United States Department of Education.” § 490.003(3)(b)2. (emphasis added). To
meet the programmatic accreditation requirement of section 490.003(3)(b)2., the
psychology program must be accredited by the American Psychological
Association (“APA”).
Dr. Prevor, a psychologist licensed in Puerto Rico with more than twenty
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years of experience, graduated with a Ph.D. in psychology from Carlos Albizu
University in Puerto Rico in 1988. At that time, the psychology program at Carlos
Albizu University was not accredited by the APA.1 Based on the lack of
“programmatic accreditation,” the Board concluded that Dr. Prevor’s degree did
not meet the educational requirements of section 490.003(3), and therefore, it
denied her application. We find no error in the Board’s interpretation of sections
490.006(1)(c) and 490.003(3)(b).
Dr. Prevor further argues that, even if her degree does not satisfy the
educational requirements, the Board should nonetheless allow her to submit a
comparability study that would allow her to establish that the Ph.D. degree she
obtained at Carlos Albizu University in 1988 meets the requirements of an APA-
accredited program. In making this argument, Dr. Prevor emphasizes the fact that
the Board allowed one of her similarly-situated classmates to submit a
comparability study, and thereafter, the Board approved his application for
licensure by endorsement under section 490.006(1)(c).2
The Board acknowledges that it allowed Dr. Prevor’s classmate to submit a
comparability study and that it subsequently approved his application. The Board,
1 Carlos Albizu University became accredited in 1994.
2Like Dr. Prevor, her classmate graduated from Carlos Albizu University in 1988
with a Ph.D. in psychology; is not licensed to practice psychology in another state,
but is licensed to practice psychology in Puerto Rico; and has at least twenty years
of experience as a licensed psychologist in Puerto Rico within the preceding
twenty-five years.
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however, correctly submits that it mistakenly did so because there is no provision
in section 490.006(1)(c) or 490.003(3)(b) that provides that an applicant seeking
licensure by endorsement under section 490.006(1)(c) can establish the educational
requirements through a comparability study. However, the Board’s mistake in
granting a previous application on an invalid basis does not entitle Dr. Prevor to a
license on that same erroneous basis. In other words, the Board’s prior mistake
does not require the Board to accept comparability studies for future applications
for licensure by endorsement under section 490.006(1)(c). We therefore affirm the
order under review denying Dr. Prevor’s application.
The remaining arguments raised by Dr. Prevor do not merit discussion.
Affirmed.
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