Clinicians
ADHD Testing and LPC Scope of Practice: How the Rules Vary by State
· 14 min read
Last updated
The most common question I get from master’s level clinicians is some version of “am I allowed to do this?” It is a fair question with an unsatisfying answer: it depends on your state, and it depends on which of three separate gates you are asking about. Most confusion in this area comes from collapsing those three gates into one.
Gate one: your state licensing statute and board rules
Your license defines your legal scope of practice. Counselor licensure acts generally authorize assessment as part of counseling practice, but states differ substantially in how they word it — some explicitly include appraisal, assessment, or the use of standardized instruments; some are silent; a few restrict specific categories of psychological testing to psychologists. The operative language is usually in the licensure act itself plus the board’s administrative rules, and the two do not always read the same way. The name of the license also varies: LPC in many states, LPCC, LCPC, LMHC, or LPCMH in others, and the scope language travels with the title.
What to look for specifically: whether your act names assessment, appraisal, or testing; whether it limits you to instruments within your training and competence (most do); whether it carves out any instrument class by name; and whether your board has issued guidance, FAQs, or declaratory rulings on psychological testing by counselors. Board guidance documents are often more explicit than the statute and are the fastest way to get a real answer.
Gate two: test-publisher qualification levels
Separate from law, publishers restrict who may purchase and administer their instruments, typically using qualification tiers commonly labeled A, B, and C. Broadly, A-level materials are widely available, B-level materials require relevant graduate training in testing and measurement plus an appropriate license or supervision, and C-level materials generally require doctoral training with specific coursework in psychological assessment or equivalent credentialing. This is a contractual and professional gate, not a statutory one — which means a state can permit something your publisher will not sell you, and clearing a publisher’s tier does not by itself make an instrument within your legal scope.
Practically, this is what determines your usable instrument set
A large portion of the rating scales, symptom inventories, and functional impairment measures used in ADHD evaluation sit at the B level and are available to appropriately trained and licensed master’s level clinicians. Several of the broad-band personality and psychopathology instruments sit at C. If a C-level instrument is central to your differential, the usual paths are supervision or collaboration with a doctoral-level provider, or selecting a B-level alternative that answers the same clinical question. Confirm current tiers directly with each publisher; they are revised, and third-hand summaries go stale.
Gate three: payers
Whether you may perform an evaluation and whether you will be paid for it are entirely different questions. Testing and assessment codes carry payer-specific rules about which provider types may bill them, in what settings, with what documentation, and how many units are allowed. Some plans credential master’s level counselors for testing codes; some reimburse only when a doctoral-level provider is the rendering or supervising provider; some do not cover ADHD-specific testing at all and treat it as an out-of-pocket service. This varies not just by state but by plan and by contract year.
Ethics sits underneath all three
Both the ACA Code of Ethics and the Standards for Educational and Psychological Testing hold you to practicing within the boundaries of your competence — education, training, supervised experience, and demonstrated skill — regardless of what a statute permits or a publisher will sell you. Being legally allowed to administer an instrument and being competent to interpret it in a differential context are not the same claim. This is the standard your work will actually be judged against if it is ever challenged.
How to verify your own state, in order
First, read your licensure act and your board’s administrative rules, searching for the terms assessment, appraisal, testing, diagnosis, and psychological. Second, check your board’s guidance, FAQs, newsletters, and any declaratory rulings on testing by counselors. Third, confirm qualification levels with each test publisher for every instrument you plan to use. Fourth, verify billing eligibility with each payer you are contracted with, in writing, for the specific codes you intend to bill. Fifth, document your training pathway for each instrument — coursework, supervised administrations, ongoing consultation — because competence is the standard you will be held to.
Two patterns worth naming
Doctoral supervision or collaboration widens what is available to you in most states, and it is a legitimate long-term arrangement rather than a temporary workaround; many practices run this way permanently. And scope questions rarely turn on whether a counselor may assess at all — they usually turn on a specific instrument, a specific diagnostic claim, or a specific billing code. Framing your question narrowly gets a usable answer from a board far faster than asking whether counselors can do testing.
How much titles vary, and why that matters
The reference table below lists the licensed counselor title and the licensing board for all fifty states and the District of Columbia. It is worth scanning even if you only practice in one of them. The counselor license is called LPC in roughly half the country, but it is LMHC in Florida, Massachusetts, New York, Washington, and several others; LPCC in California, Kentucky, and New Mexico; LCPC in Illinois, Maine, Maryland, and Montana; LCMHC in North Carolina and Vermont; CMHC in New Hampshire and Utah; CPC in Nevada; LMHP or LIMHP in Nebraska; and LPCMH in Delaware. Several states run two tiers, where the higher tier carries independent diagnostic authority the entry tier does not.
That two-tier structure is where scope questions most often turn. In states with a tiered system, the clinically independent tier is generally the one that carries independent diagnosis and unsupervised practice, and it is usually the tier that matters for testing and for payer credentialing. If you hold the entry-level or associate credential, assume you are working under supervision for assessment purposes until your board tells you otherwise in writing.
A note on multi-state practice
Telehealth has made it common to see clients across state lines, and the counseling compact is changing how that works. Practicing into another state generally means meeting that state’s rules, not just your home state’s, and that includes assessment scope. If you are testing a client who is physically located in another state at the time of service, the other state’s board is the one whose rules apply to that service.
What is coming in this series
I am building state-by-state articles on this topic. Each one will cite the actual statute and rule language and the board that issued it, rather than summarizing a general pattern, because a general pattern is not what a clinician needs when a payer denies a claim or a board asks a question. Until a state’s article is published, treat this framework as the map, the table below as your starting point, and your board as the authority.
All 50 states and the District of Columbia
Use this to find the right authority fast. The license title tells you which statute and rule set applies to you, the board is who issues the binding interpretation, and the last column summarizes the license structure you are working inside — not a ruling on whether testing is permitted, which only your board can give you.
| Jurisdiction | License | Licensing board | What this means for testing |
|---|---|---|---|
| Alabama | LPC | Alabama Board of Examiners in Counseling | Alabama licenses at two levels in practice: the ALC associate works under a board-approved supervisor, the LPC independently. Assessment questions turn on the board’s competence and supervision rules, so have training records and supervision agreements in order before adding a battery. |
| Alaska | LPC | Alaska Board of Professional Counselors | Alaska’s LPC statute is written broadly and the board publishes comparatively few advisory opinions. Expect to build your own competence case in writing rather than pointing to state guidance. |
| Arizona | LPC | Arizona Board of Behavioral Health Examiners | The AZBBHE regulates counselors, social workers, MFTs and substance abuse counselors under one roof. Read the counselor-specific rule chapter rather than the general practice standards, since scope language differs by profession. |
| Arkansas | LPC | Arkansas Board of Examiners in Counseling | Arkansas runs an LAC-to-LPC path and issues a separate supervisor credential. Testing questions here are usually resolved through direct board technical assistance rather than published rules. |
| California | LPCC | California Board of Behavioral Sciences | California’s LPCC scope statute is unusually explicit about what falls outside the license, and psychological testing has long been treated as psychologist territory. Competence alone does not settle it here — read the BBS scope statute directly. |
| Colorado | LPC | Colorado State Board of Licensed Professional Counselor Examiners | Colorado registers pre-licensure candidates and licenses LPCs through DORA. The statute grants broad scope, with the board’s competence and mandatory disclosure rules doing most of the limiting work. |
| Connecticut | LPC | Connecticut Department of Public Health | Licensing runs through the Department of Public Health rather than an independent counseling board, so there are no board minutes or advisory opinions to cite. The statute is your primary source and DPH staff interpretation is the practical one. |
| Delaware | LPCMH | Delaware Board of Mental Health and Chemical Dependency Professionals | The LPCMH sits above an LACMH associate credential, under a board that also regulates chemical dependency professionals. The mental-health-specific rule chapter is the one that governs assessment. |
| District of Columbia | LPC | DC Board of Professional Counseling | DC counseling sits inside a broad health-professional licensing structure, and reciprocity questions come up constantly given how many clinicians work across the DC–Maryland–Virginia line. Verify scope in every jurisdiction you see clients in, not just where you live. |
| Florida | LMHC | Florida Board of Clinical Social Work, Marriage & Family Therapy and Mental Health Counseling | Florida licenses LMHCs after a registered-intern period and houses three professions under one board. The psychology practice act also speaks to testing, so read both acts before adding an instrument. |
| Georgia | LPC | Georgia Composite Board of Professional Counselors, Social Workers and MFTs | Georgia’s composite board covers counselors, social workers and MFTs, with an APC associate tier below the LPC. Scope language lives in the composite rules, and only the counselor subsection binds you. |
| Hawaii | LMHC | Hawaii Board of Mental Health Counselors | Hawaii’s LMHC statute is compact and the board publishes relatively little interpretive guidance. Documented training and a defensible written rationale carry more weight here than any list of permitted instruments. |
| Idaho | LPC / LCPC | Idaho Division of Occupational and Professional Licenses | Two tiers: LCPC is the independent clinical credential, LPC the supervised one. Licensing sits inside a consolidated occupational licensing division, so look for division rules rather than a standalone board opinion. |
| Illinois | LPC / LCPC | Illinois Department of Financial and Professional Regulation | Two tiers: LCPC carries independent practice, LPC works under supervision. IDFPR administers licensing, and Illinois payers generally credential only at the LCPC level for assessment work. |
| Indiana | LMHC | Indiana Behavioral Health and Human Services Licensing Board | Indiana runs an LMHCA-to-LMHC path under a board that also licenses addiction and marriage-and-family professionals. State rules tie assessment to demonstrated training, so keep instrument-specific coursework documented. |
| Iowa | LMHC | Iowa Board of Behavioral Science | Iowa issues a temporary tLMHC before full licensure and regulates counselors through the Board of Behavioral Science. Scope determinations here typically come out of the board’s declaratory ruling process. |
| Kansas | LPC / LCPC | Kansas Behavioral Sciences Regulatory Board | Two tiers: LCPC is the clinical credential that carries independent diagnosis; LPC practices under supervision. Kansas is explicit that the clinical tier is what unlocks independent diagnostic work. |
| Kentucky | LPCA / LPCC | Kentucky Board of Licensed Professional Counselors | Two tiers: LPCA is the associate credential, LPCC the independent one. Kentucky’s board has an active advisory-opinion practice, which makes it one of the easier states in which to get a written answer before you start. |
| Louisiana | LPC | Louisiana LPC Board of Examiners | Louisiana’s statute names appraisal as part of LPC practice while carving out instruments reserved to psychologists. That carve-out, not your training record, is the first thing to check any planned battery against. |
| Maine | LCPC | Maine Board of Counseling Professionals Licensure | Maine’s LCPC sits above a conditional credential, under a board that also licenses pastoral counselors and marriage and family therapists. Chapters differ by profession, so read the counseling-specific one. |
| Maryland | LCPC | Maryland Board of Professional Counselors and Therapists | The LGPC-to-LCPC path means supervision status, not competence alone, decides what you may sign. Given how many Maryland clinicians also hold DC or Virginia licenses, verify scope separately in each. |
| Massachusetts | LMHC | Massachusetts Board of Allied Mental Health and Human Services Professions | Massachusetts licenses LMHCs through an allied mental health board covering several professions at once. Scope questions here are usually resolved by reading the board’s regulations alongside the psychology practice act. |
| Michigan | LPC | Michigan Board of Counseling (LARA) | Michigan runs a limited license (LLPC) before full LPC, both administered by LARA. The counseling rules were substantially revised in recent years, so confirm you are reading the current rule set rather than an older summary. |
| Minnesota | LPC / LPCC | Minnesota Board of Behavioral Health and Therapy | Two tiers: LPCC carries independent diagnosis and treatment; LPC does not. In Minnesota the distinction is unusually consequential for both scope and payer credentialing. |
| Mississippi | LPC | Mississippi State Board of Examiners for LPCs | Mississippi issues a provisional credential before full licensure and maintains a board supervisor registry. Assessment questions are answered against the board’s competence and supervision rules. |
| Missouri | LPC | Missouri Committee for Professional Counselors | Missouri runs a PLPC provisional tier under a committee inside the state’s professional registration division. Committee interpretation, rather than a large body of published guidance, tends to settle scope questions. |
| Montana | LCPC | Montana Board of Behavioral Health | A single LCPC credential under a behavioral health board covering several professions. Montana’s rural telehealth reality makes cross-state scope verification a routine part of testing practice here. |
| Nebraska | LMHP / LIMHP | Nebraska Board of Mental Health Practice | Two tiers, and the distinction matters more than in most states: LIMHP is required for independent diagnosis and treatment of mental illness, and LMHP alone is not sufficient. Confirm your tier before taking on evaluation work. |
| Nevada | CPC / CPC-Intern | Nevada Board of Examiners for Marriage and Family Therapists and Clinical Professional Counselors | Nevada uses the CPC title with a CPC-Intern tier below it, under a board shared with marriage and family therapists. The board publishes scope guidance worth reading before adding any standardized instrument. |
| New Hampshire | CMHC | New Hampshire Board of Mental Health Practice | New Hampshire licenses CMHCs through a board covering several mental health professions. The statute is competence-based, so the burden sits on your documentation rather than a published instrument list. |
| New Jersey | LPC | New Jersey Professional Counselor Examiners Committee | New Jersey runs an LAC-to-LPC path under an examiners committee within the Division of Consumer Affairs. The scope rules sit in the administrative code, and the committee is the body that interprets them. |
| New Mexico | LPCC | New Mexico Counseling and Therapy Practice Board | LPCC is the independent clinical credential, with LMHC as a mid-level license below it. The board covers several counseling professions, so read the LPCC-specific rule sections. |
| New York | LMHC | New York State Education Department, Office of the Professions | New York draws the sharpest line in the country here: psychological testing has long been treated as reserved territory under the Education Law, and LMHC scope is correspondingly narrow. Do not add a battery in New York on a competence argument alone. |
| North Carolina | LCMHC | North Carolina Board of Licensed Clinical Mental Health Counselors | North Carolina renamed its credentials to LCMHC and LCMHCA, so older guidance using LPC language still circulates. Make sure any rule you rely on reflects the current titles. |
| North Dakota | LPC / LPCC | North Dakota Board of Counselor Examiners | Two tiers on paper, three in practice: LAPC at entry, LPC in the middle, LPCC as the independent clinical credential. Only the top tier reliably carries unsupervised diagnostic work. |
| Ohio | LPC / LPCC | Ohio Counselor, Social Worker and Marriage & Family Therapist Board | Two tiers, and Ohio is explicit about it: LPCCs may diagnose independently, LPCs may not. The CSWMFT board publishes clear scope guidance, which makes this one of the more answerable states. |
| Oklahoma | LPC | Oklahoma State Board of Behavioral Health Licensure | Oklahoma licenses LPCs under a consolidated behavioral health board covering several professions. Supervision status and documented competence are the operative constraints on assessment work. |
| Oregon | LPC | Oregon Board of Licensed Professional Counselors and Therapists | Oregon’s board licenses professional counselors and marriage and family therapists together and keeps an active rulemaking calendar. Check the current administrative rules rather than an older summary before adding testing. |
| Pennsylvania | LPC | Pennsylvania State Board of Social Workers, MFTs and Professional Counselors | Pennsylvania houses counselors, social workers and MFTs under one board, and its scope regulation is written in general terms. Competence documentation does most of the work here. |
| Rhode Island | LMHC | Rhode Island Department of Health, Board of Mental Health Counselors and MFTs | Licensing runs through the Department of Health rather than an independent board, so guidance takes the form of department regulation. Many Rhode Island clinicians also hold Massachusetts or Connecticut licenses — verify each separately. |
| South Carolina | LPC | South Carolina Board of Examiners for Licensure of Professional Counselors, MFTs and Psycho-Educational Specialists | South Carolina’s board also licenses psycho-educational specialists, which puts a neighboring credential squarely in the assessment space. Read the LPC scope alongside that one to see where the line falls. |
| South Dakota | LPC / LPC-MH | South Dakota Board of Examiners for Counselors and MFTs | Two tiers: LPC-MH is the mental health credential carrying independent diagnosis; LPC alone does not. Payers in the state generally credential at the LPC-MH level. |
| Tennessee | LPC / LPC-MHSP | Tennessee Board for Professional Counselors, MFTs and Clinical Pastoral Therapists | Two tiers, and the MHSP designation is the one that matters: it is what permits independent practice and what payers look for. Adding testing without it is the most common scope error in the state. |
| Texas | LPC | Texas State Board of Examiners of Professional Counselors | Texas runs an LPC-Associate tier and issues a separate supervisor designation. Board rules address testing directly and tie it to training, so read the rule chapter rather than relying on general competence language. |
| Utah | CMHC | Utah Division of Professional Licensing | Utah licenses clinical mental health counselors through a consolidated professional licensing division rather than a standalone board. Division rules and the psychologist practice act together define the outer boundary. |
| Vermont | LCMHC | Vermont Board of Allied Mental Health Practitioners | Vermont’s allied mental health board covers several professions, with licensing handled through the Office of Professional Regulation. Scope is competence-based, with no published instrument list to rely on. |
| Virginia | LPC | Virginia Board of Counseling | The Resident in Counseling credential precedes the LPC, and the Board of Counseling publishes unusually detailed regulations. Virginia is one of the better states for getting a documented answer before you start. |
| Washington | LMHC | Washington State Department of Health | Licensing sits with the Department of Health rather than an independent board, and Washington also credentials associates (LMHCA). Department rules, not board opinions, are the source to cite. |
| West Virginia | LPC | West Virginia Board of Examiners in Counseling | West Virginia’s board also administers the ALPS supervisor credential and publishes scope guidance for counselors. Check the current rule series before adding an instrument. |
| Wisconsin | LPC | Wisconsin Marriage and Family Therapy, Professional Counseling and Social Work Examining Board | Wisconsin regulates counseling, MFT and social work through one examining board with separate sections. Read the professional counseling section specifically; the general board rules do not answer scope questions. |
| Wyoming | LPC | Wyoming Mental Health Professions Licensing Board | Wyoming licenses LPCs through a board covering several mental health professions and issues a provisional credential first. With few published opinions, documented training and a written rationale are your main protection. |
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