Legal Boundaries: Psychologists, Psychiatrists, Allied Health Professionals, Psychotherapists, Coaches, Mediators, and School Inclusion Assistants

Across the mental health, disability, child protection, and family support sectors, several professions often serve the same populations. Law No. 45.18 draws clear statutory boundaries that neither practitioners nor employing institutions may cross.

1Comparative Legal Analysis by Profession

1. Clinical Psychologists (الأخصائي النفسي الإكلينيكي) and Neuropsychologists

• Relationship to Law No. 45.18: Clinical psychology and neuropsychology (psychopathological diagnosis, psychometric testing, clinical treatment of mental disorders) are not included among the 18 categories of Decree No. 2.22.604. Private clinical practice falls under authorizations issued by the General Secretariat of the Government (SGG) and health authorities.
• Overlap Scenario: A holder of a Bachelor's or Master's degree in psychology who is hired by an EPS, an association, or practices independently in one of the 18 regulated social work roles (such as Special Needs Educator in Categories 6 or 7, Reintegration Counselor in Category 5, Family Support Worker in Category 12, or Family Mediator in Category 4) must hold the corresponding ICHHAD accreditation. Conversely, an ICHHAD social work accreditation never authorizes a practitioner to perform clinical psychological diagnoses or use the title of Clinical Psychologist.

2. Psychiatrists / Child Psychiatrists (الطبيب النفسي) and Allied Rehabilitation Professionals (Speech Therapists, Psychomotor Therapists, Occupational Therapists)

• Relationship to Law No. 45.18: Completely separate statutory regimes. Psychiatrists are medical doctors governed by Law No. 131.13 on the practice of medicine and registered with the National Order of Physicians (CNOM). Speech therapists (orthophonistes), psychomotor therapists (psychomotriciens), and occupational therapists (ergothérapeutes) are governed by Law No. 45.13 on rehabilitation professions (under the Ministry of Health and the SGG).
• Multidisciplinary Teamwork (e.g., Autism and Disability Centers): A medico-social center or disability association typically employs both allied health professionals regulated under Law No. 45.13 and social workers regulated under Law No. 45.18 (Special Needs Educator in Category 7, School Inclusion Assistant in Category 13, Social Worker in Category 1). Each professional must hold the statutory authorization required by their respective governing law.

3. Psychotherapists (المعالج النفسي) and Psychoanalysts

• Relationship to Law No. 45.18: Excluded. Psychotherapy focuses on treating psychological disorders and emotional distress and does not constitute a social work intervention within the meaning of Article 2 of Law No. 45.18. An accredited social worker may not use their ICHHAD accreditation number to advertise themselves to the public as a psychotherapist.

4. Coaches (Life Coaches, Parenting Coaches, School or Career Coaches)

• Relationship to Law No. 45.18: The label "Coach" is not one of the 18 regulated categories and falls under general commercial service law.
• Criminal Liability Risk for Unlawful Practice: An unaccredited practitioner who, under the guise of "family coaching" or "parenting coaching", actually performs the statutory duties of a Family Mediator (Category 4), a Family Support Worker (Category 12), or a Socio-Professional Integration Assistant (Category 3) while using the protected titles of Decree No. 2.22.604 is subject to criminal prosecution for unlawful practice and usurpation of title (Part V of Law No. 45.18 and Article 381 of the Penal Code).

5. Family Mediators (الوسيط الأسري) and School Inclusion Assistants (AVS / AESH / Shadow Teachers)

• Full Integration under Law No. 45.18: One of the major advances of Decree No. 2.22.604 is the explicit regulation of these two roles:
  • The Family Mediator is regulated under Category 4 (Domain 1);
  • The Personal and Social Assistant in School and Educational Settings (AVS / AESH / Shadow Teacher) is regulated under Category 13 (Domain 3).
• Operational Consequence: Informal practice as a school shadow teacher (AVS) or independent family mediator is no longer permitted. Anyone practicing either role professionally (whether salaried or independent) must hold the corresponding ICHHAD accreditation.

2Summary Comparison Matrix of Applicable Legal Regimes