November the 8th, 2021
Dear Mr. President,
We are thousands of psychologists with a foreign diploma (degree) based in Spain that face the impossibility to validate our diploma due to the regulations in force since 2014. This affects not only our right to work, but also our health because since 2018 to date, we have been caught in between administrative obstacles and red tape, subjected to arbitrary changes in directives, and a series of mistreatments that leave us defenseless, and with lack of a professional future.
Until very recently our claims were isolated, or at most grouped in organizations by country, being the one that brings together Venezuelan Psychologists the most active among them. Most recently, as a result of a massive mailing of letters by the Ministry of Universities carried out during 2021, the situation escalated to a point that led us to unite our forces and give shape to the MOVEMENT OF MIGRANT PSYCHOLOGISTS. It currently brings together citizens from 16 countries, with foreign qualifications from both European and non-EU countries. It also includes Spanish returnees, who after migrating and training abroad, have encountered this problem upon returning to their homeland.
With the publication of RD 967/2014, of November 21, the #PsicologosMigrantes began to see the homologation of their degrees impossible. Until then, foreign degrees were homologated without any problem by the Spanish degree, a degree that today is valued by the current regulations as MECES Level 3 (BOE 236, of October 2, 2015). However,, at the moment, the same degrees cannot be homologated even at a lowest level: Spanish Bachelor's Degree in Psychology (MECES Level 2).
We understand that RD 967/2014 was drafted with good intentions: to : ease the procedures for those professions that are not regulated by granting an equivalency, which requires less documentation, and in theory should be granted more quickly (although until this day, this has remained only a promise, since the minimum wait is 2 years). However, in doing so, it did not take into account the existing legal system, nor the interaction between the new rules and other long-standing legal institutions. Thus,, the failure to include Psychology among the regulated professions (Annex 1, RD 967/2014, of November 21) collided both with the legal requirements for membership before the Official College of Psychology (COP), as well as with the legal requirements for access to the Master's Degree in General Health Psychology (MPGS). The contradictory situation arises in which both require a "Spanish degree and homologation" when the latter no longer exists and is, since the publication of the BOE, an "impossible" requirement to comply with.
From that point on, those who submitted their applications after the regulation was enacted were at a disadvantage in comparison to those who had submitted them before the new normatives began. Instead of obtaining MECES Level 3 recognition, they obtained an equivalence that was not enough to become a member of the official college of psychology, nor to access the Master's Degree of General Health Psychologist. From there, a series of complaints arose and the Ombudsman issued a recommendation that the state comply with the mandate of the Public Health Law and regulate the Psychology degree. The same criteria was followed by the judiciary in 2016, when it ruled in a presentation made by the Superior Council of Psychology that the solution was not the judicial route but the regulation of the degree by the State.
At the end of 2018 these recommendations and indications seemed to be heard, and in the BOE of December 11, 2018 the Order CNU/1309/2018 regulating the contents of the Degree in Psychology was published. From that point on, the Ministry issued a series of press releases and circulars informing that it will begin to homologate, but that it will do so at the level of Master's Degree in General Health Psychology. In doing so, it would evaluate whether the submitted degree meets the requirement of 90 Health ECTS credits while assessing the existence of another 90 additional Health ECTS credits to homologate a joint Degree+Master's Degree. This information was communicated by the Ministry, the government delegations, the NARIC, and also by the Colleges of Psychology that were ordered to do so.
It is then, when thousands of psychologists, encouraged by the Ministry, NARIC, and government officials, start to process the necessary paperwork in their countries, pay the fees, and submit the paperwork. These procedures are evaluated by the officers and accepted as valid. And that’s when the endless wait begins:: files that do not appear in the system, files that show no progress, etc. Finally in 2021, after the change in the political level of the Ministry, an order is issued without any regulatory support, and hundreds of letters are sent contradicting what was done in 2018 and demanding the "Spanish degree in psychology" under the threat of closing the files in 90 days.
We are dealing with an arbitrary manifest, which leaves thousands of #PsicologosMigrantes in a state of administrative defenselessness, and even after 3 years of promises and lies, they do not even have a firm resolution against which to appeal in the administrative litigation. The acts of government must be consistent with previous actions, and what is observed here is that changes of officials generate changes of criteria that modify resolutions that should be supported by the regulations in force and only by them.
Therefore, we are appealing to the President of the Government in order to provide him with a possible solution and to ask him to intercede on our behalf in order to manage the realization of the solution as far as possible.
We understand, as does the judiciary, the ombudsman, and the General Council of Psychology of Spain, that it is necessary to comply with the mandate of the Public Health Law and regulate the Psychology Degree. Doing so, not only will allow us to apply for the homologation of our degrees and then be able to register and continue our studies by accessing the Master PGS; but also, it will allow Spanish psychologists to improve the employment opportunities of their undergraduate career that, today, is obstructed by the lack of regulation of the same. Without a clear regulation of the skills of the degree, Spanish graduates are increasingly required to have a Master's degree in non-health areas, thus excluding many of them from access to employment, who, not thinking of going into the health field, have not completed the Master's degree. That is why we believe that its regulation is an optimal solution, not only for us as a migrant group, but also for our Spanish colleagues who find it difficult to find employment.
We therefore request:
The regulation of the Spanish degree in psychology and the authorization of homologation for psychologists with foreign degrees. Also, as part of the group of mental health professionals, we join the call for more PIR and PEPC positions in order to jointly address the mental health crisis in which we are immersed. Also, as part of the group of mental health professionals, we join the call for more PIR and PEPC positions in order to jointly address the mental health crisis in which we are immersed.
In this regard, the impossibility of working in the profession we have studied and being trapped for years in such a state of helplessness, with no future horizon, takes us beyond the mere discussion on the legal or rights level: the impact on our health is evident. Anxiety problems, depression, loss of meaning in life, sleeping problems, irritability and a general feeling of malaise are some of the most common symptoms among this group, according to a recent study (APSAE 2021) conducted on a sample of 107 migrant psychologists from 12 countries.
So we remain at your disposal to work together to solve this problem, to meet, to provide the documentation that supports our claim, and any action that you consider necessary and in which we can add our contribution.
Movement of Migrant Psychologists