Declaratory Statement NO. 08-01

A question has been raised concerning the propriety of employment of counseling practicum students as interns during times when the university is closed (such as during semester breaks) and the students in question are not actively “enrolled” in a practicum or internship class at that time.

If the school affirmatively acknowledges that the individuals in question are “students” and provides the same level of supervision as that provided during the semester, as otherwise required by applicable Board rules, this practice is permissible and the students in question would meet the “student” exception to licensing requirements.  Unless both of  these requirements are met, this activity would constitute practicing without a license.