Accreditation Public Comment System





This project is now closed for new comments.
DocumentSectionItemFirst NameLast NameGroup NameComment 
Doctoral StandardsI. Institutional and Program ContextA. Type of program StewartShankman For all sections below, I support the CUDCP response
Doctoral StandardsI. Institutional and Program ContextA. Type of program PaulKwon For all sections below, I support the CUDCP response
Doctoral StandardsI. Institutional and Program ContextA. Type of program SmithAimee For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program CheryllRotheryNCSPPI support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextA. Type of program AlexBurt The proposed name change is terrible. I am a clinical psychologist who is also a scientist. Moreover, I am a basic scientist, who studies etiology (not interventions). As such, I find this name change to be exclusionary. In addition, it makes the flagship degree in psychology (that of clinical psychology) sound like a sub-discipline. Just terrible.
Doctoral StandardsI. Institutional and Program ContextA. Type of program SuzanneMeeks A.1.a. What does "relevant evidence is practice-informed" mean? Much important and relevant scientific evidence is not "practice informed" in the making, although it may have practice applications. To what does "each" refer -- practice and empirical evidence? Unclear.
Doctoral StandardsI. Institutional and Program ContextA. Type of program MichaelHixson I think the change to the term "Health Service Psychology" is unfortunate. I thinking linking us to the health field is too limiting. Is it ultimately related to interest in prescription privileges, greater insurance reimbursement, MD envy?
Doctoral StandardsI. Institutional and Program ContextA. Type of program SteveShapiro For all sections below, I support the CUDCP response
Doctoral StandardsI. Institutional and Program ContextA. Type of program SteveSmith For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program MarkRoberts “For all sections below, I support the CUDCP response”.
Doctoral StandardsI. Institutional and Program ContextA. Type of program GraysonHolmbeck For all sections below, I support the CUDCP response
Doctoral StandardsI. Institutional and Program ContextA. Type of program CynthiaRohrbeck For all sections below, I support the CUDCP response
Doctoral StandardsI. Institutional and Program ContextA. Type of program SimpsonSteve A.1 Health Service Psychology. This name change not only fails to reflect the "broad and general nature" of clinical psychology training, it implies that programs are training students in a sub-discipline of medicine rather than preparing them for a career as independent professionals. While collaboration with health care professionals is essential, clinical psychology cannot be subsumed under medical practice. "Professional Psychology" provides an umbrella for a range of scientific endeavor and clinical practice that has always been the purview of clinical psychology. "Health Service Psychology" biases training, research, and practice toward a narrow range of activities in the "service" of health care paradigms largely uninformed by the science and best practices of clinical psychology. "Professional Psychology" does not limit those who wish to work within those paradigms; "Health Service Psychology" does limit those who wish to pursue work established in the discipline of psychology ... See Full Comment
Doctoral StandardsI. Institutional and Program ContextA. Type of program PaulRokke For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program RebeccaReady For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program JeffreyCiesla For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program HidekoSera For all sections, I support NCSPP's response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program margaretnettles I am not convinced that the change from Professional Psychology to Health Services Psychology is useful shift. Please explain why this change is felt to be necessary
Doctoral StandardsI. Institutional and Program ContextA. Type of program DeborahBeidelCUDCPCUDCP views the proposed term “Health Services Psychology” as the term used to identify the scope of areas eligible for accreditation as an improvement from the previous generic “professional psychology.” Health Service Psychology better defines the role of psychologists in providing health services to the public. There is some concern that this term does not properly educate the public about the research nature of what we do. Among all the disciplines that provide services to the public, only psychologists come from an educational philosophy that emphasizes the importance of training in research (for all graduates) as well as the provision of empirically-based assessment and intervention. CUDCP encourages consideration of the term Behavioral Health Psychology as it better captures both the science and practice integration of psychology. A second alternative is to insert a hyphen between health and service, as in health-service psychology, which then indicates that as a f... See Full Comment
Doctoral StandardsI. Institutional and Program ContextA. Type of program Mary AliceConroy I think Health Service Psychology is a poor title. First it sound too much like Clinical Health Psychology--a specific ABPP specialty And second, there are types of practice covered by these standards that are not really Health services (e.g., forensic evaluations, consultation to non-medical organizations such as probation departments).
Doctoral StandardsI. Institutional and Program ContextA. Type of program LauraPittman For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program DavidRiccio For all sections below, i support the CUDCP response to the proposal.
Doctoral StandardsI. Institutional and Program ContextA. Type of program MichelleSalyers For all sections below, I support the CUDCP reponse
Doctoral StandardsI. Institutional and Program ContextA. Type of program ChristinaGee For all sections below, I support the CUDCP response
Doctoral StandardsI. Institutional and Program ContextA. Type of program DavidHansen For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program KathleenPalm Reed I agree with the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program CellucciTonyAPTCThe Association of Psychology Training Clinics (APTC) Commentary on SOA for Health Service Doctoral Training Programs APTC represents the directors of academic training clinics. In addition, our members serve as coordinators of practicum training in many programs. We begin these comments with an acknowledgement of the valuable and challenging work that the CoA and its members have done in revising these standards and we particularly appreciate the thoughtful process undertaken of evolving accreditation to a national competency education model. We appreciate having a voice in this process through these requests for public comments. In reading the proposed SoA, we are particularly pleased that our expressed preference for a hybrid model of core and program specific competencies has been embraced in the proposed standards and that the core competencies seem to reflect broadly recognized professional competencies advanced in national documents and by various professional associations.... See Full Comment
Doctoral StandardsI. Institutional and Program ContextA. Type of program ChristineMaleckiCDSPP1. Health Service Psychology. During discussion at the CDSPP midwinter meeting, concerns were raised that the term “Health Service Provider” didn’t seem inclusive of school psychology and delivery of psychological services in schools. Although the definitions in the documents seem inclusive, it was voiced that the label could potentially marginalize school psychology with policy makers and professional—and possibly influence licensing agency inclusion of school psychology. Nonetheless, no other term was identified as “preferable”. [Possibly, Health Service Psychology or Behavioral Health Psychology] However, the term “health service provider” is consistent with our current roles and functions and breaks down barriers between mental health and education. We all should be aware that the term may be confusing to the public, as often people view health as “medical/physical”. Over time we can build an identity with the term, but we need to educate others. It will be positive when ... See Full Comment
Doctoral StandardsI. Institutional and Program ContextA. Type of program BethWildman For all sections below, I support the CUDCP response
Doctoral StandardsI. Institutional and Program ContextA. Type of program BethanyTeachman For all sections below, I support the CUDCP response
Doctoral StandardsI. Institutional and Program ContextA. Type of program CharlotteJohnston For all sections below, I support the CUDCP response
Doctoral StandardsI. Institutional and Program ContextA. Type of program ChristopherKearney For all sections below, I support the CUDCP response
Doctoral StandardsI. Institutional and Program ContextA. Type of program MarkLumley For all sections below, I support the CUDCP response
Doctoral StandardsI. Institutional and Program ContextA. Type of program EllenKoch For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program ReneeLajiness-O'Neill For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program AmberShifflettBoard of Educational Affairs (BEA)PsyD as proposed does not include the HSPEC Blueprint recommendation for all psychologists to produce research and not just learn to be a good consumer of research. Make clear the expectations for scholarly activity. Add: Make sure the definition of degrees is inclusive re: current degrees (EdD) and potential new degrees; e.g., there is a strong movement toward developing professional practice doctorates (PPD), especially in related health fields (OT, PT, Speech and Language, audiology, nursing, etc….) there may be new opportunities for psychology. For reference, the Carnegie Project on the Education Doctorate (CPED) initiative has worked to differentiate the distinctions between doctoral degrees that are designed to advance research vs advance practice. This may be a useful model to consider.
Doctoral StandardsI. Institutional and Program ContextA. Type of program DeborahBeidelCUDCPOverall, CUDCP believes that education of the public would be better served by a document that first listed the competencies that are required by anyone who graduates from an accredited program. In this way, the public (and potential graduates) would have a general understanding of the training areas included as part of the education of health-service psychology. CUDCP also believes that by first listing the overall expected competencies, there would be a better context by which to then explain the degree type. We maintain that degree types are important inasmuch as they are important to explain the myriad of questions and publics to which the SoA must respond. CUDCP strongly supports the effort to describe the two different degree types. CUDCP is concerned that the proposed Ph.D. description does not adequately describe the goals of a Ph.D. program. We hereby offer the following revision: Programs that confer the PhD place emphasis on ensuring that graduates can equally pr... See Full Comment
Doctoral StandardsI. Institutional and Program ContextA. Type of program MarshallDuke For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program MarshallDuke For all sections below, I support the CUDCP response
Doctoral StandardsI. Institutional and Program ContextA. Type of program MitchPrinstein For all sections below, I agree with the CUDCP response
Doctoral StandardsI. Institutional and Program ContextA. Type of program BrandonGibb For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program MichaelYoung For all sections below, I support the CUDCP response
Doctoral StandardsI. Institutional and Program ContextA. Type of program DavidMarcus For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program CardemilEsteban For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program SolidayElizabeth For all sections below, I support the CUDCP response
Doctoral StandardsI. Institutional and Program ContextA. Type of program PatriciaKerig For all sections here and below, I agree with the CUDCP comments.
Doctoral StandardsI. Institutional and Program ContextA. Type of program RisaBroudy For all sections below, I support the CUDCP response
Doctoral StandardsI. Institutional and Program ContextA. Type of program LauraBuchholz I think the section on degree type should be altered. A substantial amount of individuals with a PHD also gain training and expertise with delivering empirically-supported treatments, in addition to research.
Doctoral StandardsI. Institutional and Program ContextA. Type of program MatthewJerram For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program KathleenSikkema For all sections, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program Jackieon behalf of HornASPPB Board of DirectorsThe ASPPB Board of Directors would like to thank you for the opportunity to give input and comment on the new Standards of Accreditation in Health Service Psychology. Overall ASPPB finds that these proposed Standards represent a significant step forward towards defining quality training for psychologists who are health service providers, and we are very supportive of your efforts. We are pleased that you solicited input from the regulatory community throughout the process of creating these Standards, recognizing that licensure is one of the primary goals for many graduate students, interns and postdoctoral fellows. Additionally, it seems clearer and clearer that we are all focused on the same ultimate goals – offering top quality training to those psychology students who are interested in becoming health service providers, and thereby providing the public with ethical and high quality psychological services from an evidence-based perspective. We appreciate your spelling out that... See Full Comment
Doctoral StandardsI. Institutional and Program ContextA. Type of program Jackieon behalf of HornASPPB Board of Directors• (p. 1) EdD should be included in degree type. We understand that there are no EdD accredited programs currently, but many School Psychology and Counseling Psychology programs are housed within Schools or Departments of Education; • (p. 1) The current definition of the PhD is not accurate, is misleading, and we believe gives the public the impression that PhDs cannot implement good psychotherapy.
Doctoral StandardsI. Institutional and Program ContextA. Type of program DavidKahn I would like to comment on the concerns expressed by the Council of Directors of School Psychology Programs (CDSPP). One of the strengths of the revised standards is the use of the term “Health Service Provider,” a term that is inclusive of school psychology and all other specialty areas. It also is inclusive of all settings, including schools, and covers all aspects of one’s health: medical, physical, social, psychological, and educational. In addition, the term “Health Service Provider” acknowledges that, just as it is for all other health service providers, a doctoral degree and licensure as a psychologist is the standard for independent practice. I understand the unique challenges faced by the CDSPP. Regulations for school psychology training have been developed by the National Association of School Psychologists (NASP) and the Commission on Accreditation of the American Psychological Association. While I understand the desire of the CDSPP to meet the standards developed by b... See Full Comment
Doctoral StandardsI. Institutional and Program ContextA. Type of program SaulesKaren For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program LeeCooper For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program PaulaShear For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program MichaelStutts For this and all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program CochranBryan I agree with the comments articulated by CUDCP on all of the sections referenced below.
Doctoral StandardsI. Institutional and Program ContextA. Type of program AlineSayer For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program AlissaHuth-Bocks For all sections below, I support the CUDCP response
Doctoral StandardsI. Institutional and Program ContextA. Type of program GregProudfit For all sections below, I support the APCS response
Doctoral StandardsI. Institutional and Program ContextA. Type of program Klein-TasmanBonnie I agree with the CUDCP response
Doctoral StandardsI. Institutional and Program ContextA. Type of program MaureenLafferty In all of the sections below I support the ACCTA comments.
Doctoral StandardsI. Institutional and Program ContextA. Type of program JulieHubbard For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program NicoleKramer For all sections below, I support the CUDCP response
Doctoral StandardsI. Institutional and Program ContextA. Type of program StephanieWoodNCSPPThere are several key and important elements related to Section I to which NCSPP would like to offer comments. First, it is the perspective of NCSPP that the term “Health Service Psychology,” delineated in Section I.A.1 and employed as the overarching descriptor for accredited doctoral programs, is too restrictive. Although, NCSPP appreciates the aim of the term – which appears to be to ensure sensitivity to, and psychologist participation within, the changing health care environment – HSP does not reflect the fact that broad and general graduate training is intended to be broader than in “health” and “service,” and that graduates can take on various future roles, including those of academic program faculty, consultants, and researchers for which the “health service” label is not a good fit. It is a term that is not widely used and tends to be misinterpreted. Indeed, although APA has used the term, it is notable that at a recent meeting of CAPP (arguably the leaders of profession... See Full Comment
Doctoral StandardsI. Institutional and Program ContextA. Type of program SharonHorne I appreciate the effort that has gone into the development of the SoA and support the move to a profession-wide competency model. I endorse the SoA in general. I question the use of the term Health Service Psychology, although I understand this may benefit our graduates who are applying for licensure in states that often designate licensure as HSPs. However, health often appears to imply medical or intervention, and may unintentionally exclude professionals who are engaged in prevention, consultation, or are working in schools and college counseling centers. I prefer the more inclusive term applied psychologists. As a training director in a counseling psychology program in a city that regularly expects a minimum of 24 hours of practicum from doctoral students, it would be helpful to place some reasonable limits on these training experiences beyond Ca, Cb, and Cc. Expecting programs to provide data on graduates 10 years post-graduation seems challenging and The expectation that faculty ... See Full Comment
Doctoral StandardsI. Institutional and Program ContextA. Type of program LindaCraighead for all sections below, I support the CUDCP response
Doctoral StandardsI. Institutional and Program ContextA. Type of program EddyAmeenAPAGS (American Psychological Association of Graduate Students)APAGS believes that Section I, Domain A is adequate in its entirety. We support having a unified accreditation standard for Health Service Psychology (HSP) training, including clinical, counseling, and school psychology programs. This is appropriate to maintain uniformity in our field and prevent confusion among the public about the role of psychologists. Additionally, APAGS is in support of a uniform standardized competency-based assessment model for programs in all training models to achieve. However, it is reasonable for programs to set up their own program goals, objectives, and competencies in addition to the uniform set of profession based competencies.
Doctoral StandardsI. Institutional and Program ContextA. Type of program RobertPerl I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextA. Type of program PatriciaDixon I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextA. Type of program CharlesHoward I support the NCSPP statements in all areas. Thank you
Doctoral StandardsI. Institutional and Program ContextA. Type of program RandallWyatt I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextA. Type of program JimTheisen I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextA. Type of program DonnKaiser I support the NCSPP response to the document
Doctoral StandardsI. Institutional and Program ContextA. Type of program TIMOTHYCAVELLCUDCP/NCSPPFor all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program PeterArnett For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program BruceZahn I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextA. Type of program PrenskyEricNCSPPI support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextA. Type of program KathiBorden I believe Section I of the proposed standards creates a false dichotomy between PhD and PsyD programs that will be harmful to the profession of psychology. While it is tempting to create a division between PsyD and PhD standards, processes, and outcomes, I believe doing this in our accreditation standards will be detrimental to the profession of psychology. Because the PhD, typically a research degree in most fields, became the first practice degree in psychology, the field has not evolved with a clear delineation of careers based on PsyD vs. PhD. In fact, many PsyDs have academic careers, while even more PhDs are in clinical practice. Also, because of psychology education's history, most people currently in the field hold a PhD no matter what career path they have taken (as there was no alternative in the earliest days). I refer you to the Borden and McIlvried (2009) chapter in David Richard and Steven Huprich's text, Clinical Psychology: Assessment, Treatment, and Research, where... See Full Comment
Doctoral StandardsI. Institutional and Program ContextA. Type of program BatesKathie I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextA. Type of program ShawnCahill I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program MiltonFuentes I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextA. Type of program MiltonFuentes I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextA. Type of program JoanRead I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextA. Type of program Gregory A.Miller Any requirements or assumptions about the credentialing of practicum supervisors should be carefully considered. There’s potentially huge impact on faculty participation in clinical practica. It's not uncommon for university faculty to be partially exempt from licensing laws, meaning that they can teach clinical practica without being licensed. This is the case, for example, in California and Illinois (I'm skipping some details, which differ; I have chaired the licensing board in Illinois). If the new SoA rules would require (or could be interpreted to require) that all clinical supervisors be licensed, some programs could absorb that, and some would be shut down by it. Departments would react in a variety of ways, providing course reductions so that their clinical faculty could get licensed, withdrawing research-active faculty from clinical training (contrary to the clinical science model) and finding funds to hire outside supervisors, or closing their clinical programs. Many departme... See Full Comment
Doctoral StandardsI. Institutional and Program ContextA. Type of program StephanieWoodTim Cavell, Diana Concannon, Stephanie WoodThe context for this comment is an earlier group comment jointly posted by NCSPP and CUDCP. Unlike that comment, this is one is NOT a joint NCSPP/CUDCP comment. Instead, it is a comment made jointly by an individual member of the CUDCP Board (Dr. Tim Cavell), by the chair of NCSPP’s Accreditation Committee (Dr. Diana Concannon), and by an individual member of the NCSPP Executive Committee (Dr. Stephanie Wood). As a point of reference, we pasted below the earlier comment jointly posted by NCSPP and CUDCP: “CUDCP and NCSPP believe that a primary goal of the CoA’s Standards of Accreditation is to delineate the competencies required of graduates from accredited programs in health service psychology. Highlighting required competencies would better inform all educational stakeholders as well as the general public of the training areas required for producing competent health service psychologists. Given the importance of shared competencies, the SoA should place the section on competency... See Full Comment
Doctoral StandardsI. Institutional and Program ContextA. Type of program BinduMethikalam I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextA. Type of program CrystalCollier I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextA. Type of program HowellGary I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextA. Type of program BarbaraYutrzenka While I am not sure that Health Service Psychology is an improvement, I understand that the CoA is trying to be more specific about the areas that it is accrediting. That is, a clinical psychology program may have more than a service provision focus, but accreditation is focusing on that element of our training. With this comment in mind, for all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program DavidSbarraAcademy of Psychological Clinical ScienceAcademy of Psychological Clinical Science (APCS) APCS’s Response to the Commission on Accreditation’s (CoA) Request for Public Comment on the Standards of Accreditation in Health Service Psychology (SoA) Preamble We have organized our response to follow the basic organization of the proposed SoA. Prior to outlining our detailed responses, we wish to make a few general comments. First, as written, the SoA is exceptionally broad and lacks sufficient detail for a thorough analysis of its potential strengths and weaknesses. Consider, for example, the issue of profession-wide competencies: Although specific competencies are listed, the plan is to outline the elements—e.g., skills, knowledge, observable behaviors— that constitute each competency in a series of Implementing Regulations (IRs). If the broad SoA are approved, even after substantial modifications following this period of open commentary, the IRs can be implemented in a manner that undermines the entire process. Our first s... See Full Comment
Doctoral StandardsI. Institutional and Program ContextA. Type of program MicucciJoseph I support the NCSPP response for all sections
Doctoral StandardsI. Institutional and Program ContextA. Type of program MichaelLoewy I agree completely with NCSPP's statement on doctoral training and internship training standards.
Doctoral StandardsI. Institutional and Program ContextA. Type of program vincentalfonsoDivision 16 Executive Councila. Pg 1, in re Section A #3 Degree Type: Why limit degree types awarded? There are several other types of degrees (e.g., Professional Practice Doctorates; PPD) that are becoming more popular in health care programs. Further, what type of degree a university can offer is often a State issue and not a university or program issue / decision that simply reflects “emphasis of training priorities” and as such this is restrictive, unnecessary, and likely inaccurate. In addition, this interacts with the removal of training models. If a university is only allowed to offer a PsyD or EdD at the doctoral level, does that mean that they cannot offer scientist-practitioner training, merely because they are not PhD granting institutions?
Doctoral StandardsI. Institutional and Program ContextA. Type of program TIMOTHYCAVELLCUDCP/NCSPPJoint Comment from CUDCP/NCSPP CUDCP and NCSPP believe that a primary goal of the CoA’s Standards of Accreditation is to delineate the competencies required of graduates from accredited programs in health service psychology. Highlighting required competencies would better inform all educational stakeholders as well as the general public of the training areas required for producing competent health service psychologists. Given the importance of shared competencies, the SoA should place the section on competency-based education and evaluation before sections that distinguish how those competencies are represented/expressed by degree type. In this way, the SoA would offer context by which to understand degree type distinctions. Therefore, we recommend placing the section that distinguishes degree type after delineation of shared competencies. We recommend placing the section on degree type in a newly created Section II.B.c.
Doctoral StandardsI. Institutional and Program ContextA. Type of program DavidRaja I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextA. Type of program ScottBrowning I support the NCSPP response to all sections.
Doctoral StandardsI. Institutional and Program ContextA. Type of program HeatherLyonsLoyola University Maryland - PsyD in Clinical Psychology ProgramWe support the NCSPP response on all sections of each document.
Doctoral StandardsI. Institutional and Program ContextA. Type of program DianaConcannon I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextA. Type of program RitaCasey I dislike the using the term "Health Service Psychology" rather than the term "Professional Psychology". "Health Service" sounds far too medical and more explicitly practitioner in orientation that the prior terminology, and is too easily interpreted in ways that are inconsistent with the variety of areas cited as examples in Part 2. Practice Area. With respect to other aspects of these standards and the following sections, I agree with the CUDCP responses.
Doctoral StandardsI. Institutional and Program ContextA. Type of program DanielSegal For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program DanielSegal For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program JeffreyNevid For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program GoneJoseph For all sections below, I support the APCS response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program DonnaJohnson I support the NCSPP response in its entirety.
Doctoral StandardsI. Institutional and Program ContextA. Type of program Gregory A.Miller For all sections below, I support the APCS response, with additional comments on II.C.1.b. Supervision.
Doctoral StandardsI. Institutional and Program ContextA. Type of program NashBrenda I support the stance of NCSPP on all sections.
Doctoral StandardsI. Institutional and Program ContextA. Type of program GingerMoore For all sections below, I support the CUDCP response
Doctoral StandardsI. Institutional and Program ContextA. Type of program LindsayHam For all sections, I agree with the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program NicoleAllenOn Behalf of the Clinical/Community Psychology Docotoral Graduate ProgramFor all sections, we support the response to the Standards of Accreditation in Health Service Psychology (SoA) prepared by the Academy of Psychological Clinical Science (APCS).
Doctoral StandardsI. Institutional and Program ContextA. Type of program DavidSbarraAcademy of Psychological Clinical Science (APCS)Academy of Psychological Clinical Science (APCS) APCS’s Response to the Commission on Accreditation’s (CoA) Request for Public Comment on the Standards of Accreditation in Health Service Psychology (SoA) Preamble We have organized our response to follow the basic organization of the proposed SoA. Prior to outlining our detailed responses, we wish to make a few general comments. First, as written, the SoA is exceptionally broad and lacks sufficient detail for a thorough analysis of its potential strengths and weaknesses. Consider, for example, the issue of profession-wide competencies: Although specific competencies are listed, the plan is to outline the elements—e.g., skills, knowledge, observable behaviors— that constitute each competency in a series of Implementing Regulations (IRs). If the broad SoA are approved, even after substantial modifications following this period of open commentary, the IRs can be implemented in a manner that undermines the entire process. Our first s... See Full Comment
Doctoral StandardsI. Institutional and Program ContextA. Type of program LesleyLutes For all sections below, I support the CUDCP response
Doctoral StandardsI. Institutional and Program ContextA. Type of program HeatherSheets I support the NCSPP comments
Doctoral StandardsI. Institutional and Program ContextA. Type of program HeatherSheets I support the NCSPP comments
Doctoral StandardsI. Institutional and Program ContextA. Type of program HeatherSheets I support the NCSPP comments
Doctoral StandardsI. Institutional and Program ContextA. Type of program DavidSbarraAcademy of Psychological Clinical Science (APCS)Academy of Psychological Clinical Science (APCS) APCS’s Response to the Commission on Accreditation’s (CoA) Request for Public Comment on the Standards of Accreditation in Health Service Psychology (SoA) Preamble We have organized our response to follow the basic organization of the proposed SoA. Prior to outlining our detailed responses, we wish to make a few general comments. First, as written, the SoA is exceptionally broad and lacks sufficient detail for a thorough analysis of its potential strengths and weaknesses. Consider, for example, the issue of profession-wide competencies: Although specific competencies are listed, the plan is to outline the elements—e.g., skills, knowledge, observable behaviors— that constitute each competency in a series of Implementing Regulations (IRs). If the broad SoA are approved, even after substantial modifications following this period of open commentary, the IRs can be implemented in a manner that undermines the entire process. Our first s... See Full Comment
Doctoral StandardsI. Institutional and Program ContextA. Type of program MarkCarlson-Ghost As a PhD psychologist who has come to admire the clinical skills and preparation of graduates from PsyD programs, I support the recommendations of the NCSPP for all sections below.
Doctoral StandardsI. Institutional and Program ContextA. Type of program ScottFriedman I support the NCSPP response for all sections. I write this as a psychologist in practice who has close to thirty years of experience teaching and supervising psychology doctoral graduate students in clinical and counseling specializations. I am a part-time faculty member with the clinical program at Walden University. I have been very impressed with the quality of the faculty; and also have found that there are doctoral students whom I would have recruited to my practice if the program was APA accredited as required by the Georgia licensing board. Now that the program has been enhanced so that the majority of learning takes place through in person learning, I hope that APA will consider accepting the NCSPP recommended standards. I appreciate this opportunity to comment about this important accreditation issue. --Scott Friedman, Psy.D., ABPP
Doctoral StandardsI. Institutional and Program ContextA. Type of program TimothyBrown I support the NCSPP response for this section.
Doctoral StandardsI. Institutional and Program ContextA. Type of program ArnoldKevinCouncil of Specialties in Professional PsychologyThe Council of Specialties in Professional Psychology (CoS) wishes to thank the Commission on Accreditation (COA) for all its thoughtful and hard work on behalf of the education and training of professional psychologists who deliver health service psychological services. The Draft Standards for Accreditation reflect the highest level of professional effort, and CoS recognizes the vital role of COA in the on-going development of our profession. That being said, CoS has several specific recommendations, and additional general, comments regarding the Draft Standards for Accreditation (SAs). These recommendations and comments are made with all due respect to the high level of professionalism and hard work evidenced within the COA’s draft SAs. I.A.2—CoS recommends that Practice Area language identifies the specialty practice areas to be clinical, counseling, school, or a combination of those three areas, or a CRSPPP-recognized or ABPP-affiliated specialty practice area (not “developed... See Full Comment
Doctoral StandardsI. Institutional and Program ContextA. Type of program GilbertNewman I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextA. Type of program AlisaManulkin I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextA. Type of program HidekoSera For all sections, I support NCSPP's response.
Doctoral StandardsI. Institutional and Program ContextA. Type of program AnnemarieSlobig I agree with the NCSPP comments on all sections
Doctoral StandardsI. Institutional and Program ContextA. Type of program BrianChu For all sections below, I support the CUDCP response, with some additional comments in selected sections. Re. Degree type, I agree with CUDCP's expanded definition of PhD programs, but also agree with NCSPP's suggestion that degree type should be removed from this section and placed after a discussion of competencies. The degree type should only be informative in providing the context and relative emphasis in which the competencies get trained. There is a high degree of variation across both PhD and PsyD programs, and so up-front general definitions can be deceiving.
Doctoral StandardsI. Institutional and Program ContextA. Type of program School Psychology ProgramUniversity of ArizonaUniversity of Arizona School Psychology Program1.Health Service Psychology: From an APA-accredited School Psychology Program perspective, we question the change of Professional Psychology to Health Service Psychology. We are concerned that this title may be misleading to the public, especially if the program is not producing professionals who are actively providing medical health services. Instead, we suggest the consideration of “Applied Professional” or “Behavioral Health Service” Psychology as alternative names that are inherently more inclusive. 2.Practice area: We would like to see a minor change to clarify school psychology as distinct since the way it is currently written has the appearance that counseling and school are one in the same. Current: “areas of clinical psychology, counseling and school psychology” Recommended: “areas of clinical psychology, counseling psychology, school psychology, other developed practice areas, and combinations of these areas.” The change adds the word “psychology” after counseling, includ... See Full Comment
Doctoral StandardsI. Institutional and Program ContextA. Type of program ThomasKubiszynCRSPPPIA2. Consistent with our first general concern, the distinctions among CRSPPP, ABPP and CoS may be introduced here.
Doctoral StandardsI. Institutional and Program ContextA. Type of program ThomasKubiszynCRSPPPIA3a. the proposed language refers to “a substantial proportion of faculty” is vague and subject to interpretation. Does that mean 20%, 40%, 80%? Providing more specific guidance would be welcome.
Doctoral StandardsI. Institutional and Program ContextA. Type of program MarilynPowellWalden UniversityWe believe that the restrictive language in the current draft of the standards related to the new term of Health Service Psychology, specifically, that limiting blended or hybrid education by using the subjective word “substantial” in section 3 to describe the amount of online education that is unacceptable to meet the requirements of residency, contradicts APA’s own vision statement which states that we serve as “A principal leader and global partner promoting psychological knowledge and methods to facilitate the resolution of personal, societal and global challenges in diverse, multicultural and international contexts.” It limits the ability to accomplish 1.c. as stated in this section as well. Inclusion of such a subjective limitation fails to support the APA core values which includes a commitment to “social justice, diversity, and inclusion” and will continue to contribute to decreased diversity within doctoral psychology programs. For example, in three sections (Administr... See Full Comment
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesCellucciTonyAPTCThe Association of Psychology Training Clinics (APTC) Commentary on SOA for Health Service Doctoral Training Programs B. Administrative Structure and Financial Resources Graduate professional training is clearly a valued but demanding and costly activity for institutions. It is appropriate that the SoA reflect the need for funding and resources necessary for the program to achieve its goals and objectives that are sufficient as well as predictable and stable through the accreditation period. From our perspective, this particularly is a challenge during periods of economic downturn and budget retrenchment as institutions question small class sections and faculty commitment to supervision and research mentoring. We also concur that all programs should strive to create “supportive and encouraging learning environments appropriate for the training of diverse individuals and the provision of training opportunities for a broad spectrum of individuals,” as well as the importance of long t... See Full Comment
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesKathleenPalm Reed I agree with the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesLizO'Laughlin For all sections below, I agree with the CUDCP response
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesLauraBuchholz For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesJackieon behalf of HornASPPB Board of Directors• (p. 3) the support for preparing “graduates to navigate cultural and individual differences” in all they do is well put.
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesKennethSher With respect to other doctoral-level curriculum for health providers (e.g., medicine, osteopathy, dentistry), how many have "or the equivalent thereof" as part of their residency requirements. This type of language, even with the proviso currently included, is an invitation to programs to try to "game" the system. I fully realize that there have been advances in online education and other non-residential formats but it is unclear to what extent the ability to both be a part of effective role-modeling in day-to-day activities as well as to be evaluated on a day-to-day professional basis for professional comportment and the like can occur without sufficient immersion in an ambient learning community. In addition to objecting to the "equivalent thereof" for the one year of residency, I also believe that it is problematic to only require "one year" of residency; it seems cynical that we would give faculty the ability to award a Ph.D. or PsyD to a student they've only gotten to interact wit... See Full Comment
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesMaryPetersonGeorge Fox UniversityOur program supports the comment submitted by Azusa Pacific University, Biola University, Brigham Young University, Loma Linda University, and Wheaton College.
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesEddyAmeenAPAGS (American Psychological Association of Graduate Students)APAGS finds Section I, Domain B, Item 2 (Administrative Responsibilities) to be lacking. To address this item, we wish to reiterate comments which were submitted to the CoA during Phase II of the G&P revision process: 1. We emphasize that recruitment must be approached differently for unique under-represented groups and that diversity within the profession is something we strive for. Sites should not demonstrate that they have a one-size-fits-all approach to diversity recruitment; rather, they should demonstrate that they have specific strategies to tailor recruitment to individuals from various under-represented groups. 2. APAGS suggests that programs be required to describe their commitment to multiple factors of diversity, in publicly available recruitment materials. For example, we would like sites to provide potential students a description of what a diverse student body would look like according to their individual program’s conceptualization of diversity and program aims... See Full Comment
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesBruceZahn I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesPrenskyEricNCSPPI support the NCSPP response for all sections
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesBatesKathie I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesTaniaIsraelAPA Committee on LGBT ConcernsIt would be helpful to define “cultural and individual diversity” prior to using these terms and to remind readers each time of the breadth of what is meant by diversity. One way of doing this would be to define diversity in a footnote and reference it each time related terms are used. People may read only a particular section, so it’s important not to define it only in once place, and it may be cumbersome to define it repeatedly. Define "diverse," "diverse backgrounds," and "broad spectrum of individuals." Do these terms include sexual orientation and gender identity/expression? The final sentence of this section is very helpful guidance regarding program obligations and trainee expectations.
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesCrystalCollier I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesHowellGary I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesJenniferRipleyRegent University doctoral program in clinical psychologyWe want to emphasize our appreciation for CoA’s recognition that applying accreditation standards in constitutionally appropriate ways to faith based educational settings is an instantiation of respect for diversity rather than a diminution of it. Yet, we would concur with comments made by a number of the faith based programs regarding some potential problems with the language in the proposed SoA that may have the effect of reducing the protections affirmed by footnote 4 counter to the stated intent of CoA. Perhaps just a few revised sentences to something like the following would suffice: “Because of the United States’ rich diverse higher education landscape, training can take place in both secular and faith based settings. Thus programs with a religious affiliation or purpose may operate consistent with their religious affiliation and purpose under the prerogatives recognized by the U.S. constitution. Examples of these constitutional prerogatives include utilizing admissions and empl... See Full Comment
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesJeffVan DuzerSeattle Pacific UniversityWe understand the Commission on Accreditation intends to delete Footnote 4 in the Standards of Accreditation and include revised language from Footnote 4 in Doctoral Standard I.B.2, Doctoral Internship Standard I.C.2, and the Postdoctoral Residency Standard I.B.3. The Commission’s proposed language deletes, among other things, the last sentence of Footnote 4 (“This standard will be administered as if the U.S. Constitution governed its application.”) We urge the Commission to add the following sentence in place of that proposed deleted sentence: "This standard must be administered in a manner consistent with and without weakening the protections afforded to religious educational institutions under 42 U.S.C. Sec. 2000e-1(a) of the Civil Rights Act and the U.S. Constitution." We believe the Commission’s proposed new accreditation standards may weaken the rights of religious educational institutions to condition faculty and staff hiring on religious considerations under Title VII of... See Full Comment
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesJamesGordonAzusa Pacific University, Biola University, Brigham Young University, Loma Linda University, and Wheaton CollegeComment from Azusa Pacific University, Biola University, Brigham Young University, Loma Linda University, and Wheaton College. We applaud the Commission on Accreditation’s intent to respect the mission of religiously affiliated universities and to better embed Footnote 4 in the Standards of Accreditation. APA documents, including the proposed Standards of Accreditation, clearly indicate that psychologists respect human diversity. The proposed standards and other APA documents explicitly include religion among the aspects of human diversity to be respected by psychologists. It follows that the standards need to respect the missions of religiously affiliated universities. Moreover, the Higher Education Opportunity Act of 2008 provides, “No accrediting agency or association may be determined by the Secretary [of Education] to be a reliable authority as to the quality of education or training offered” unless that accrediting entity “consistently applies and enforces standards that r... See Full Comment
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesMichaelGalligan-StierleAssociation of Catholic Colleges & Universities Filed Electronically July 1st, 2014 American Psychological Association Office of Program Consultation and Accreditation 750 First Street, N.E. Washington, DC 20002-4242 Dear Sir or Madam: The Association of Catholic Colleges and Universities (“ACCU”) submits the following comments on the American Psychological Association’s proposed Standards of Accreditation in Health Service Psychology. Statement of Interest Founded in 1899, the ACCU is the collective voice of Catholic higher education in the United States. ACCU’s membership includes 197 accredited Catholic institutions of higher learning in the United States, comprising more than 90 percent of such institutions. Importantly for purposes of the present comments, at least 21 ACCU-member colleges and universities have programs accredited by the APA. ACCU’s mission includes strengthening the mission and character of Catholic higher education, and educating the general public on issues relating to Catholic educ... See Full Comment
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesHeatherSheets I support the NCSPP comments
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesAlisaManulkin I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesTimothyBrown I support the NCSPP response for this section.
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesSchool Psychology ProgramUniversity of ArizonaUniversity of Arizona School Psychology Program1.Administrative Structure: We believe the wording is consistent with previous guidelines. 2.Administrative Responsibilities: The expectations to ensure a diverse pool of graduates is essential. This subsection should allow for flexibility for how programs address this component given the unfortunate, yet legally mandated laws disallowing affirmative action.
Doctoral StandardsI. Institutional and Program ContextB. Institutional Setting & ResourcesWilliamRobinsonCouncil for Christian Colleges & UniversitiesJuly 7, 2014 APA Office of Program Consultation and Accreditation 750 First St., NE Washington, DC 20002 apaaccred@apa.org Sent by E-Mail and Posted in Online Comments Dear Members of the Commission on Accreditation: I write as Interim President of the Council for Christian Colleges & Universities on behalf of our 139 U.S. members and affiliates in response to the proposal by your Commission to embed Footnote 4 in the Standards of Accreditation. We applaud the decision of the APA to respect the mission of religious institutions by fully integrating Footnote 4 into the SOA, and fully support your Commission’s stated goal of “ensuring that religious institutions are afforded their rights under the Constitution.” The COA’s recognition that the mission of religious institutions must be respected is consistent with the APA’s stated goal for the programs it accredits to “indicate respect for an understanding of cultural and individual diversity,” as religious diversi... See Full Comment
Doctoral StandardsI. Institutional and Program ContextC. Program Context and ResourcesCellucciTonyAPTCThe Association of Psychology Training Clinics (APTC) Commentary on SOA for Health Service Doctoral Training Programs C. Program Context We agree with statements put forth regarding a) Program Leadership and b) Program Administration. C.1.c.i, ii, iii Length of Degree and Residency We support the SoA requirement that “The program has policies regarding program length and residency that permit faculty, training staff, supervisors, and administrators to execute their professional, ethical, and potentially legal obligations to promote student development, socialization and peer interaction, faculty role modelling and the development and assessment of student competencies. Residency provides students with mentoring and supervision regarding their development and socialization into the profession, as well as continuous monitoring and assessment of student development through live face-to-face, in-person interaction with faculty and students. These obligations cannot be met... See Full Comment
Doctoral StandardsI. Institutional and Program ContextC. Program Context and ResourcesKathleenPalm Reed I agree with the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextC. Program Context and ResourcesJackieon behalf of HornASPPB Board of Directors• (p. 4) ‘full-time residency’ - Continuing to allow “or the equivalent thereof” language may cause problems for applicants for licensure and for licensing boards. ASPPB has adopted language regarding residency that might be helpful as you consider this. The ASPPB Model Act states: The curriculum shall encompass … a minimum of one continuous academic year of full time residency at the educational institution granting the doctoral degree. Residency means physical presence, in person, at the educational institution in a manner that facilitates the full participation and integration of the individual in the educational and training experience and includes faculty student interaction; Models that use face-to-face contact for shorter durations throughout a year or models that use video teleconferencing or other electronic means to meet the residency requirement are not acceptable (ASPPB, 2010). The reason... See Full Comment
Doctoral StandardsI. Institutional and Program ContextC. Program Context and ResourcesJackieon behalf of HornASPPB Board of Directorsp. 5) ‘resources’ - We applaud the emphasis on acquisition of competencies throughout these Standards.
Doctoral StandardsI. Institutional and Program ContextC. Program Context and ResourcesLauraBuchholz Regarding the length of training, some degrees require students to complete an accredited training program in order to receive their degree. This may need to be reworded. Also, some states require students to be license-eligible in order to provide services. For instance, in Ohio, unlicensed providers cannot work with Medicare providers. This should be taken into consideration.
Doctoral StandardsI. Institutional and Program ContextC. Program Context and ResourcesEddyAmeenAPAGS (American Psychological Association of Graduate Students)Program Administration and Structure: APAGS would like CoA to address how they are defining “consistent with the program’s aims.” For example, is it important that the program’s leaders be in the same specialty as the program (i.e., counseling psychologists must be the leaders in a counseling psychology program) or is the program allowed to make a case for how their leaders are consistent with aims, regardless of specialization? APAGS believes the standard for length and residency requirements being met in person is adequate. In Phase 2, we noted that while we see telelearning as an important supplement for some content classes or special courses with limited expertise, the majority of instruction should be in person. Partnerships/Consortia: APAGS believes the standard by which programs may be in a partnership or consortium is adequate. We believe these sites can help promote interdisciplinary training, integration into primary care settings, and can aid programs in taking resp... See Full Comment
Doctoral StandardsI. Institutional and Program ContextC. Program Context and ResourcesRandallWyatt I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextC. Program Context and ResourcesStephanieWoodNCSPPNCSPP recommends three modifications: Section I.C.1 could be interpreted as prohibiting a psychologist trained in one substantive area of psychology from leading a program in another area (e.g., a counseling psychologist could not lead a clinical program, a Ph.D. could not lead a Psy.D. program). Eliminating the second sentence of Section I.C.1 is recommended to resolve this problem. It is also recommended that Section D.3 be modified slightly, from “The program makes the formal written policies and procedures available to all interested parties” to “The program makes the formal policies and procedures (in either a paper and/or electronic format) available to all interested parties.” This modification will support the Section’s relevance as communication methodology evolves. Finally, it is recommended that CoA adopt a process for supporting provisional accreditation – akin to that adopted for internship programs – to support the development of new programs that meet community needs... See Full Comment
Doctoral StandardsI. Institutional and Program ContextC. Program Context and ResourcesFearringtonMatt I'm confused about the statement regarding programs that are "substantially or completely online." The word "substantially" is ambiguous and can thus be interpreted differently by different people. Additionally, I'm not sure what evidence you have that online programs cannot adequately prepare students to work as professional psychologists. In fact, the research suggests that online or blended programs are equivalent or superior to traditional programs. If we are to consider ourselves scientists, then should we not let the data guide our decision-making?
Doctoral StandardsI. Institutional and Program ContextC. Program Context and ResourcesSmithMargaret I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextC. Program Context and ResourcesCrystalCollier I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextC. Program Context and ResourcesHowellGary I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextC. Program Context and ResourcesHeatherSheets I support the NCSPP comments
Doctoral StandardsI. Institutional and Program ContextC. Program Context and ResourcesAlisaManulkin I support the NCSPP response for this section.
Doctoral StandardsI. Institutional and Program ContextC. Program Context and ResourcesRaymondTrybus In general, I support the comments on NCSPP on this and all other sections throughout the document. In particular, I think it is essential to eliminate the word "substantially" in section C.1.c, because this constitutes an entirely unwarranted and non-evidence-based exclusion of programs that blend face-to-face and online approaches. Programs should not be excluded from consideration for accreditation simply on the basis of the instructional approaches used. Let programs be judged on their merits and their learning outcomes, and not be excluded automatically because they make mroe than trivial use of online learning methods. The research evidence on this point is very clear and has been replicated multiple times: students in online, and especially in blended, courses, achieve learning outcomes that are usually slightly better than those in traditional face-to-face classes, and at least on a par with such classes. In the face of this clear evidence, the proposed Standards would pla... See Full Comment
Doctoral StandardsI. Institutional and Program ContextC. Program Context and ResourcesMitchellHicks I support the NCSPP response for all sections
Doctoral StandardsI. Institutional and Program ContextC. Program Context and ResourcesTimothyBrown I support the NCSPP response for this section.
Doctoral StandardsI. Institutional and Program ContextC. Program Context and ResourcesNinaNabors I support the NCSPP and Walden University response on this section and request that the COA revise the draft, removing the language precluding blended (online/onground) programs from applying for accreditation. COA should rely on empirical evidence and solid operational definitions as required by our profession in crafting the requirements for accreditation. The preponderance of data supports blended and online education as a viable method of training.
Doctoral StandardsI. Institutional and Program ContextC. Program Context and ResourcesSchool Psychology ProgramUniversity of ArizonaUniversity of Arizona School Psychology Program1.Program Administration and Structure: We agree with the definition that the individual be trained in an area covered by HSP and that the leadership role may be shared by more than one individual. We agree with the proposed requirements for length of degree and residency requirements, as well as the remaining components of Part 1.c..
Doctoral StandardsI. Institutional and Program ContextC. Program Context and ResourcesMarilynPowellWalden UniversityWalden University respectfully suggests that the phrase “substantially online” be removed from the statement “These obligations cannot be met in programs that are substantially or completely online” in section c. Thus, the standard would read, in that part, “These obligations cannot be met in programs that are completely online.” Walden University has provided online and blended training in numerous fields, many with programmatic accreditation, for over 40 years. The evolution of hybrid or blended instruction –online and in-person education – is embraced by most fields and many programs in professional psychology mix the two methodologies. Walden University concurs with the proposed standard in that “completely” online programs cannot adequately train practicing psychologists. However, there is significant concern with including the phrase “substantially online” as it relates to the use of online technology because it is ambiguous and undefined. As this ambiguity will likely r... See Full Comment
Doctoral StandardsI. Institutional and Program ContextD. Program policies and proceduresMarykaBiaggioAPA Division 44Integrating diversity in the various parts of the proposed Standards seems to work well. I notice that diversity is referred to in different ways throughout the document. In IB2, reference is made to “the definition of cultural diversity.” But there is no mention of where the definition is. In ID1 it says the CoA “espouses a broad definition of cultural diversity and individual difference that includes, but is not limited to, age, disability, ethnicity, gender, gender identity, language, national origin, race, religion, culture, sexual orientation, and socioeconomic status.” I think this definition of “cultural diversity and individual difference” works well, and I would recommend that wherever the Standards mention diversity it should be so phrased. IIB1b.iv reads “Individual and cultural diversity,” which deviates from the term used above. IIIA1b mentions “students from a range of diverse backgrounds as outlined in the glossary.” Should this instead read “students repre... See Full Comment
Doctoral StandardsI. Institutional and Program ContextD. Program policies and proceduresKathleenPalm Reed I agree with the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextD. Program policies and proceduresLauraBuchholz For all sections below, I support the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextD. Program policies and proceduresJackieon behalf of HornASPPB Board of Directors• (p. 6) ‘student records’ – ASPPB would like you to develop the idea of this concept further. Licensing boards could potentially use that to evaluate programs when someone is seeking to be licensed but did not attend an APA-accredited program. It would be very helpful to the regulatory community for academic programs to retain portfolios for each student detailing how they met each of the required competencies. Within the proposed standards, it seems that each student may not have coursework that reflects each area deemed to be required profession wide competencies. Regulators rely on transcripts to assess if requirements have been met, and if the requirements are not met through coursework, and thus not reflected on transcripts, regulators will need other mechanisms to determine if requirements have been met.
Doctoral StandardsI. Institutional and Program ContextD. Program policies and proceduresEddyAmeenAPAGS (American Psychological Association of Graduate Students)Areas of Coverage: APAGS believes the language about cultural diversity seems out of place in this section. While it is an overarching value, this section could begin with the sentence, “The program has and adheres to…” The remaining portion about broadly defining cultural diversity is useful, but might be better placed under parts “a” and/or “g” of this section. Complaints/Grievances: APAGS believes the grievance section may benefit from specific language that requires an option to report a grievance anonymously. This benefits students who may fear unethical retaliation for filing complaints. As it stands, it makes unidentified complaints optional, limiting the likelihood that complaints will be filed and precluding the resolution of problems for current and future students. Therefore, we reiterate our comment from Phase 2: APAGS aspires to ensure student rights in the graduate school process. Consistent with this, we are in favor of creating an anonymous reporting system for stud... See Full Comment
Doctoral StandardsI. Institutional and Program ContextD. Program policies and proceduresBruceZahn I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextD. Program policies and proceduresTaniaIsraelAPA Committee on LGBT Concerns"gender identity/expression" would be preferable to "gender identity" in Areas of Coverage.
Doctoral StandardsI. Institutional and Program ContextD. Program policies and proceduresJoanRead I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextD. Program policies and proceduresCrystalCollier I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextD. Program policies and proceduresvincentalfonsoDivision 16 Executive Councilc. Pg 5, in section D #1 f Areas of Coverage: should this be professional development? Otherwise it appears that APA training is attempting to change personal beliefs (i.e., problems of conscientious objectors, religious faiths).
Doctoral StandardsI. Institutional and Program ContextD. Program policies and proceduresHeatherSheets I support the NCSPP comments
Doctoral StandardsI. Institutional and Program ContextD. Program policies and proceduresAlisaManulkin I support the NCSPP response for this section.
Doctoral StandardsI. Institutional and Program ContextD. Program policies and proceduresAlisaManulkin I support the NCSPP response for this section.
Doctoral StandardsI. Institutional and Program ContextD. Program policies and proceduresTimothyBrown I support the NCSPP response for this section.
Doctoral StandardsI. Institutional and Program ContextD. Program policies and proceduresThomasKubiszynCRSPPPID4a. The first sentence indicates that programs must maintain “permanent” records, but 1D4aii states that “Records must be maintained for all graduates until licensed or for a maximum of 10 years”. This contradiction should be reconciled.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentA. Aims of the ProgramCynthiaRohrbeck For all sections below, I support the CUDCP response
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentA. Aims of the ProgramCellucciTonyAPTC The Association of Psychology Training Clinics (APTC) Commentary on SOA for Health Service Doctoral Training Programs II. Curriculum, Outcomes, and Development A. Aims of Program B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession b. Profession-wide competencies: The broad competency categories listed in the draft SoA appropriately reflect the extensively-vetted categories developed by the profession. A substantial issue will be how the CoA instructs programs to operationalize these categories through more detailed specification of essential components and behavioral anchors. Presumably this will be the subject of a related IR. We recommend the use of the extensive work in this area already available on the APA website and in related publications. Training programs have distinct purposes and emphases today. We believe that CoA should consider requiring programs to detail additional, more specific c... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentA. Aims of the ProgramLauraBuchholz For all sections below, I support the CUDCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentA. Aims of the ProgramKlein-TasmanBonnie I agree with the CUDCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentA. Aims of the ProgramStephanieWoodNCSPPNCSPP would like to express its appreciation for the proposed adoption of universal competencies foundational to the training and practice of professional psychology. We applaud this addition, and endorse the specific competencies included in the draft Standards. Consistent with our comments related to Section I, NCSPP endorses the use of the term “professional psychology,” rather than “health service psychology” and recommends that the former replaces the latter in each instance. As also indicated under Section I, NCSPP strongly recommends placement of degree types in this Section (as opposed to Section I) to support the strength of adopting a universal competency-based accreditation approach, rather than potentially suggesting that there are greater differences between degree types – and the professional contexts in which graduates apply their education – than actually exists. Consequently, NCSPP strongly recommends placing any reference to degree types after delineation of... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentA. Aims of the ProgramEddyAmeenAPAGS (American Psychological Association of Graduate Students)APAGS supports the importance of programs explicitly stating their program aims to the public and future applicants. However, the phrase “including the career paths of its graduates” is unclear. Are programs expected to state the career paths that they intend for their students to pursue and/or the career paths their students actually pursue? Both pieces of information may be salient. Further, APAGS suggests that programs explicitly state their flexibility in terms of supporting students who ultimately choose “alternative” career paths other than those promoted and expected by their graduate institutions. It is reasonable to expect that some students will enter a program with interests or goals that change over the course of their graduate studies; these students should not be prohibited from exploring alternative career options or paths solely on the basis of adhering to the typical career paths intended by their current program.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentA. Aims of the ProgramBruceZahn I support the NCSPP response for all sections.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentA. Aims of the ProgramFrederickWechsler I support the NCSPP response for all sections.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentA. Aims of the ProgramAlisaManulkin I support the NCSPP response for this section.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentA. Aims of the ProgramTimothyBrown I support the NCSPP response for this section.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionMoyeJenniferAging Leadership TeamThank you for the opportunity to review the draft of the G&P. We, the aging leadership team, represented by The Society for Clinical Geropsychology, Psychologists in Long Term Care, The Council of professional Geropsychology Training Programs, and the APA Committee on Aging, do not feel the current draft goes far enough to insure that all practicing psychologists have adequate skills for work with older adults. The proportion of older adults in the United States is rapidly increasing. While 13% of the population is currently age 65 and older, by 2030 this figure will swell to 20% (Centers for Disease Control and Prevention and The Merck Company Foundation, 2007). Older adults are significant consumers of healthcare, responsible for 36% of all health related expenditures (Institute of Medicine, 2012). Even when care is being provided to children, adolescents, and younger adults, issues concerning older adults often arise as older adults may be caregivers (e.g., guardians to children)... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionGilbertNewman Noting in the proposed standards that there is no longer the usual list of courses as noted under Domain B. 3. (a), I assume that a similar course list will appear within the implementing regulations that will be developed in accordance with the new standards. I'd like to express my hope that the result of this process doesn't simply add more courses, but that there might be consideration of exchanging some for others. For example, History and Systems (since nearly each content course provides some historical context) might be replaced with a course on psychopharmacology. Or exchange another course with (or if the plan does simply add courses) I should hope that health psychology is included. Additionally, if there is a substantial change in the list of courses, consideration needs to be given to the length of time graduate programs will need to address the changes in faculty or faculty assignments.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionSaraQualls B.1.b.viii. Consultation/interprofessional/interdisciplinary I recommend this set of items be separated into 2: 1) Consultation is a distinct service that may be with colleagues in Psychology or in other disciplines or even in industries outside of healthcare (e.g., social services, housing) 2) Interprofessional/interdisciplinary -- other health professions are adopting rigorous standards related to interprofessional practice competencies and believe Psychology must align its standards likewise with the IPEC competencies. I suggest naming this Interprofessional Service Delivery.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionChristineMaleckiCDSPP1.Discipline-Specific Knowledge and Profession-Wide Competencies. The CDSPP Executive Committee fully supports a competency-based approach and appreciates the value of accreditation being linked to how well programs develop and document competency attainment. Further, we support the identified competencies. Concerns were raised that IRs be inclusive of practice in schools and unique competencies of school psychologists such as school law, the school context, and systems-level consultation be included in those IRs. Perhaps the IRs can allow for additional specific program or profession-specific competencies in addition to the profession-wide competencies. There was also a question regarding which professional values and attitudes we use. Is there a potential that someone else will define our professional values (1.b)? All of us have professional values that suit our programs well. For example, is reflective practice a universal “professional value”? There is concern that for some c... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionDeborahBeidelCUDCPCUDCP endorses the principle that not all training opportunities take place in the classroom. Students interested in achieving competency in assessment strategies such as EEG or fNIR may acquire needed education in a laboratory other than in the classroom. Thus CUDCP would encourage the last sentence of the above paragraph to be revised as follows.” Additional coursework and/or advanced training experiences in advanced topics are expected. Rather than the list above, we encourage the CoA to use the competencies already articulated by the Health Service Psychology Education Collaborative (HSPEC) and presented in that collaborative’s blueprint document. The HSPEC document represents the most thoroughly vetted and accepted competencies ever produced by the psychological community, indicating their widespread acceptance/agreement. If additional competences above those listed in the HSPEC blueprint are included, CUDCP raises the following concerns with the above list: a. The ter... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionLauraBuchholz I think the sections titled "communication and interpersonal skills" and "reflective practice" deserve more clarification.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionAmberShifflettBoard of Educational Affairs (BEA)-Add clarity to the term “discipline-specific” competencies that will replace “broad and general,” and whether it will be up to the field to decide these competencies with guidance from COGDOP. Specific questions: Who will determine the appropriate cut-off score? BEA suggests looking at “success” outcomes based on these cut scores after the GRE has been revised.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionJackieon behalf of HornASPPB Board of Directors• (p. 7) We think the changes in how to meet the “broad and general” requirements are excellent. We’ve suggested previously that another way to ensure this, in lieu of GRE subject tests, would be to require certain courses are taken by the end of the first year of graduate training.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionMary LouiseCashel I support the CUDCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionKennethSher The description of discipline-specific knowledge is so vague as to be virtually meaningless. I think CoA should step up to the plate to take a stance on "what every psychologist should know about the discipline of psychology." I realize this could come in one or more IRs but the bold outline should be here. Failure of CoA to provide this type of leadership leaves psychology in the pre-paradigmatic stage of science that undermines its credibility with the public and other scientific disciplines.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionStephanieWoodNCSPPIn relation to Section II.B.1.a.i: NCSPP recommends the following replacement paragraph: “Using student selection criteria that involve standardized assessments of a foundational knowledge base (e.g., GRE subject tests) expected at the graduate level. In this case, the program must describe how the curriculum enables students to demonstrate graduate-level discipline-specific knowledge.” The proposed edit reinforces the need to demonstrate competency at the graduate level, allows programs to “test” students after enrollment, and ensures that all students are held to equitable standards, (i.e., that those who test competent in a foundational area are not held to a higher standard – or subject to greater requirements – than those who do not). In relation to Section II.B.1.b, NCSPP suggests that the descriptor “most recent and rigorous” (in relation to the evidence base for the development and assessment of each of the competency categories) is both ambiguous and subjective. Instea... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionEddyAmeenAPAGS (American Psychological Association of Graduate Students)APAGS believes that the standard for students to enter graduate school with discipline-specific knowledge is an important one. Profession-wide competencies: APAGS is unable to provide comments on the specific requirements in each competency without corresponding IRs. In advance of those IRs, APAGS supports the movement toward profession-wide competencies as the goal of graduate training. In Phase 2, APAGS recommended implementation of the competencies outlined in the Blueprint. Most of those competencies appear, in some form, in the SoA. However, the “Leadership & Advocacy” competency appears absent. As we stated in Phase 2, we would like to see programs take responsibility for introducing students to the field and to the profession, instilling a sense of belonging, ownership, and responsibility in trainees for psychology’s relevance to science, practice, education, and public interest. Advocacy skills are important in the development of future generations of psychologists. We stro... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionShawnCahill I support the CUDCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionTaniaIsraelAPA Committee on LGBT ConcernsAgain, it would be helpful to have a footnoted definition of "Individual and cultural diversity."
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionRandallWyatt I support the NCSPP response for all sections.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionDavidSbarraAcademy of Psychological Clinical Science (APCS)II.B.1.a.i. Discipline-specific Selection Criteria. Based on our read of the SoA, the Discipline-specific knowledge (DSK) requirement can be met one of two ways—through “Broad and General” (presumably, as it exists in the current G&P with instruction domain areas, but, again, no specific details are provided under II.B.1.a.ii) or via selection criteria involving standardized examinations such as the GRE subject test. We are very enthusiastic about this proposal and support using standardized tests to demonstrate coverage of the DSK. At the same time, however, the SoA is unclear about how the student selection criteria can be implemented. We believe it would be beneficial for the training community stakeholders to have the ability to comment on the IRs related to how we can use student selection criteria to meet DSK. In our opinion, the fundamental goal of using selection criteria in this way should be to permit, foster, and promote a high degree of individualized training flexibility. ... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionDavidSbarraAcademy of Psychological Clinical Science (APCS)II.B.1.a.i. Discipline-specific Selection Criteria. Based on our read of the SoA, the Discipline-specific knowledge (DSK) requirement can be met one of two ways—through “Broad and General” (presumably, as it exists in the current G&P with instruction domain areas, but, again, no specific details are provided under II.B.1.a.ii) or via selection criteria involving standardized examinations such as the GRE subject test. We are very enthusiastic about this proposal and support using standardized tests to demonstrate coverage of the DSK. At the same time, however, the SoA is unclear about how the student selection criteria can be implemented. We believe it would be beneficial for the training community stakeholders to have the ability to comment on the IRs related to how we can use student selection criteria to meet DSK. In our opinion, the fundamental goal of using selection criteria in this way should be to permit, foster, and promote a high degree of individualized training flexibility. ... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionAlisaManulkin I support the NCSPP response for this section.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionTimothyBrown I support the NCSPP response for this section.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionBrianChu For II.B.1.a: I agree with CUDCP and APCS that HOW this gets implemented is most important. If this results in de facto additional requirements (e.g., mandatory psych GREs and "broad and general" courses), we will have increased our burden unnecessarily.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionSchool Psychology ProgramUniversity of ArizonaUniversity of Arizona School Psychology Program1.Discipline-Specific Knowledge: Although flexibility in courses required and the content contained within is notable, removing the description of what discipline-specific knowledge is expected may lead to wide variability of interpretation by Programs and Site Visitors. There certainly can and should be options for students who come in with that basic knowledge to “waive” or “test” out of the foundational courses and be permitted to take courses that address advanced topics in the same domains. However, this section was previously more detailed (and even further elaborated in the Implementing Regulation), which facilitated continuity. For instance, “biological aspects of behavior,” “human development,” etc.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionSchool Psychology ProgramUniversity of ArizonaUniversity of Arizona School Psychology Program2.Learning/Curriculum Elements Related to the Program’s Aims: The section on profession-wide competencies is much more developed (especially with the impending elaboration in the revised Implementing Regulations). We fully endorse such universal expectancies. However, some of the areas are more subjective and may vary considerably across evaluators and students. Further, it should be made very clear that a specific course may not achieve all of those areas and that the professional skill-oriented competencies should be infused across coursework and practica.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentB. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the ProfessionBrianChu II.B.1.b. I STRONGLY agree with CUDCP that the list of profession wide competencies follow the recommendations offered by the Health Service Psychology Education Collaborative (HSPEC) and presented in that collaborative’s blueprint.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsKlein-TasmanBonnie I agree with the CUDCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training Elementsroberteme There is no requirement that an essential component of supervision should be that the student is actually observed (in vivo, by taping, etc) functioning clinically by the supervisor for a minimal percentage of the time spent in a practicum or internship, e.g., 10% of the time. Supervision relying exclusively on student self-report is totally inadequate for knowing what the student is actually doing.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsGilbertNewman I have some concern about the inflexibility regarding "direct observation" under C.1.c. above. There are many situations where the evaluation of the student can not be based on such direct observation. Rather, the supervisor relies upon process notes and continuous discourse regarding the disposition of a clinical encounter. Do you mean that a faculty member of supervisor "observes the student in didactic, group supervision or through the student's performance in individual supervision? Or is direct observation strictly about observing the student as s/he interacts with a patient?
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsGilbertNewman Also regarding the direct observation issue, I'm wondering whether it would be possible to consider continuous patient evaluation of the therapist performance - patient satisfaction measures, surveys that help evaluate if the patient experiences the psychological service as useful and effective. Having a live observation of one session - where the student was on their best behavior, versus a series of measures taken throughout the course of treatment - which would you think is a more honest "observation" of the student's performance?
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsGilbertNewman Another issue regarding C.1.c. is that the cost of direct observation for each student in each practicum is very costly. Many of our programs have limited psychologist personnel and asking them to provide live supervision is too costly. The standards should not undermine our ability to serve our communities effectively. Why not rely upon the school to demonstrate that we have "directly observed the student sufficiently in the course of their practicum training" and that criteria for such observation are clearly outlined and followed. Why burden the poor agencies we are partnering with to deliver psychology into underserved communities?
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsSuzanneMeeks What is there in the category "professional values and attitudes" that is not contained in ethical & legal standards, interpersonal skills, reflective practice, and individual/cultural diversity? This seems like a vague and overlapping category, and therefore problematic.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsGregorySsmithClinical program - University of KentuckyC. 1. C saying practicum evaluation must be based in part on direct observation. We oppose this standard. We do not believe there is existing empirical evidence to support the superiority of supervision based on direct observation. We are strongly opposed to endorsing a change that was made in the absence of clear empirical evidence; doing so seems inconsistent with our science-based and evidence-based discipline. It is an open empirical question whether some direct observation significantly improves the supervision process. There are many reasons why that might not turn out to be true. One can watch tape briefly and misunderstand a session far more than if one listened to audio or heard a session recounted by the therapist. Some direct observation does not necessarily means a more full understanding of a given session or a given experience.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsKimLampson Please clarify who is to perform the "direct observation" for evaluation of the practicum (1c)- is that direct observation by the site supervisor or is it direct observation by a member of the program faculty.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsMary AliceConroy Standard C1(b) would seem to say that anyone providing clinical supervision would need to be a licensed doctoral level psychologist. I would very much applaud such a standard--how can faculty be role models and programs use licensure rate as distal evaluation data if supervising faculty are not licensed? However, a later standard--IVB4(c)--says that a minimum of one core faculty member must be licensed. So, that one faculty member must provide all of the clinical supervision? This seems very contradictory.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsGilbertNewman One more comment on C.1.c. - Our program is practicum heavy - 3-4 practica in the course of 3-4 years. Having to provide live or video-taped supervision for each practicum is a heavy burden compared to another doctoral program that only provides 1-2 practica experience. Psychoanalytic training programs have customarily rejected the idea of "direct observation". This standard could be seen as affront to this orientation of psychological practice.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsCellucciTonyAPTCThe Association of Psychology Training Clinics (APTC) Commentary on SOA for Health Service Doctoral Training Programs C. Practicum and Required Internship Elements 1. Practicum a. We strongly support the definition of practicum and the need for an individual level practicum plan. This standard defines the need to coordinate practicum with the program’s overall training goals and to ensure attainment of competency bases standards. We strongly support this standard. b. We believe that this section, regarding appropriately credentialed supervisors for practicum, is important and appropriate. We believe that programs should be required to provide a documented rationale when it uses a site that lacks an on-site licensed doctoral level psychologist who is responsible for the practicum (e.g., access to underserved or diverse populations). When there is no licensed doctoral level psychologist on site, we strongly recommend that the program supplement supervision by providing an integr... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsShannonFoster  c. As part of a program’s ongoing commitment to ensuring the quality of their graduates, each practicum evaluation must be based in part on direct observation (either live or electronically). Whereas I strongly support supervised experience under the guidance of appropriately credentialed individuals, I question the added value of regulating that this supervision be based on direct observation. Placing such a stipulation could greatly limit the number of practica placements available to students as not all clinical populations and/or settings are appropriate for this stipulation. For example, within a forensic setting it may not be feasible for a supervisor to directly observe sessions AND it may run counter to therapeutic and/or institutional guidelines to video these sessions. In addition, many sites may lack the A/V equipment necessary to implement this requirement and the cost of adhering to it may discourage some outstanding training sites from continuing to offer practica tra... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsKahnDavid The current draft of the new standards already has a number of appropriate requirements in place for practicum experiences. I would like to suggest the following revision. IV.C.1.b. should be revised to read "Practicum sites must provide supervision by an individual licensed as a psychologist at the doctoral level. The doctoral program must also provide ongoing supervision by a faculty member licensed as a psychologist at the doctoral level." This revision provides greater specificity for program faculty members. My experience as a student in an APA-accredited program suggests that faculty members need as much specificity as possible in the Standards relating to practicum experiences. This revision is also consistent with the most stringent requirements for licensure as a psychologist at the doctoral level. In addition, this revision will prevent other students at APA-accredited programs from experiencing what I did as a student. I completed my doctoral degree in school psychology at T... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsChristineGrant Thank you for the opportunity to comment on the proposed SoA. In the area C. Practicum and Required Internship Training Elements, an important requirement for doctoral programs is under 1c: "As part of a program’s ongoing commitment to ensuring the quality of their graduates, each practicum evaluation must be based in part on direct observation* (either live or electronically)." As the training director of an accredited internship, this requirement feels essential to us. We have had students from doctoral programs who were excellent students, and could speak well as far as how to DO psychotherapy -- but who were very different when actually sitting with a client. Reporting what happened in a counseling session can be vastly different than actually observing* the session. Also, trainees can obtain increasing competency in reflective practice when watching* their own sessions with clients. In their academic program, the trainees' performance could be good, and they may be apprec... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsChristineMaleckiCDSPP1. Practicum. C1b. …When the practicum site does not provide for doctoral-level licensed psychologists as supervisors, the doctoral program must provide ongoing supervision by appropriately licensed faculty. Our membership really appreciates this clarification. C1c – The direct observation requirement should have clarification in the IRs that direct observation can be done by a supervisor on-site in the field. Guidance and clarification on this will be appreciated in the IRs. 2. Required Internship. Our membership appreciates the opportunity to document the criteria for license-eligible internships when an internship is unaccredited. This fits in well with the use of our CDSPP Guidelines for Internship. The following is specified: i. the nature and appropriateness of the training activities; ii. frequency and quality of supervision; iii. credentials of the supervisors; iv. how the internship evaluates student performance; v. how interns demonstrate competency a... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsDeborahBeidelCUDCPWe agree with the requirement that practicum evaluations must be placed in part on direct observation, with the caveat that exceptions will need to occur for supervisors who are visually impaired. The term “in part” lacks clarity. We suggest that the term be operationally defined as “once per externship” or “once per semester” so that programs do not misinterpret the SoA’s intent.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsDeborahBeidelCUDCPCUDCP agreea with the requirement that practicum evaluations must be placed in part on direct observation, with the caveat that exceptions will need to occur for supervisors who are visually impaired. The term “in part” lacks clarity. We suggest that the term be operationally defined as “once per externship” or “once per semester” so that programs do not misinterpret the SoA’s intent.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsLauraBuchholz Is there a specific requirement for the number of hours necessary to complete the practicum and/or internship requirement? This should be clearly articulated. Also, my guess is the goal of this program is to enhance multidisciplinary care. If so, it might be helpful to require students to complete a specific number of practicum sites and/or rotations in different areas to increase the breadth of their training.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsJackieon behalf of HornASPPB Board of Directors• (p. 8) ‘practicum’ – An individualized focus of practicum experiences is good, and, by way of a portfolio, could aid licensing boards as they evaluate someone’s supervised professional experience (especially in those jurisdictions that don’t require the post-doc) for licensure;, ASPPB also fully supports, and very much appreciates, your efforts to ensure that programs rely on firsthand knowledge of students’ applied work through direct observation. Please keep this “eyes on” requirement. It might be helpful to be even more explicit about your expectations here, e.g., direct observation (either live in-person, or electronic video based observation.) This requirement very much helps our jurisdictions rely on accreditation as the standard for judging adequacy of practicum experiences.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsMary LouiseCashel I support the CUDCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsJackieon behalf of HornASPPB Board of Directors• (p. 9) ASPPB supports maintaining the requirement that an internship is a required component of the doctoral degree. ASPPB encourages CoA to require that graduate programs send their students to APA-accredited internships, and if one of their students does not attend an accredited internship, the program must explain why. Since currently there are not enough internship placements for all graduates coming from APA-accredited doctoral programs, we would recommend that CoA state that, as of some later date (2017 or 2018), this requirement would take effect. Additionally, as in Canada, we recommend that if the student attends an unaccredited internship, the program should be responsible for ensuring and reporting how that unaccredited internship meets all of the requirements that accredited internships must meet. We support maintaining records of student/trainee evaluations. Licensing boards can use these evaluations, or their inclusion in a portfolio, for licensing purposes.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsEddyAmeenAPAGS (American Psychological Association of Graduate Students)APAGS believes the standard that practica must include supervised experience working with diverse individuals with a variety of presenting concerns is adequate. The need for individual level training plans speaks to differentiated training that takes each student’s development into account. However, in Phase 2, APAGS noted a concern with the lack of regulations limiting the amount of practicum hours and recommended setting a standard minimum number of hours to apply for internship, as well as a 20 hour/week maximum for practicum students. Upon an extensive discussion in Phase 3, APAGS has refined our earlier response. We present the entirety of our discussion and our rationale here, framed in our duty to protect students from unhealthy work habits/expectations that may ultimately detract from other important academic endeavors and competencies and reduce quality of care delivery. Our conversation centered on five themes. First, APAGS agreed that students do not perform their best... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsShawnCahill I support the CUDCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsTaniaIsraelAPA Committee on LGBT ConcernsC. 1. "diverse range of individuals" would be preferable to "diverse individuals," as it is not the individual who is diverse.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsDavidSbarraAcademy of Psychological Clinical ScienceAcademy of Psychological Clinical Science (APCS) APCS’s Response to the Commission on Accreditation’s (CoA) Request for Public Comment on the Standards of Accreditation in Health Service Psychology (SoA) II.C.1.b. Supervision. In this section, we assume “appropriately credentialed” means a licensed clinical psychologist. What does it mean for a doctoral program to “provide ongoing supervision by appropriately licensed faculty”? We believe this issue deserves careful consideration. Many of our programs have excellent clinical placement sites that are staffed by other licensed behavioral health professionals that can provide excellent supervision. What does the internal supervision need to look like if our students were to work at one of these sites? We believe the SoA should be more flexible in this regard and permit students to work at sites that have a licensed behavioral health supervisor (e.g., licensed social worker, psychiatrist, or marriage and family therapist) who provide... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsRandallWyatt I support the NCSPP response for all sections.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsvincentalfonsoDivision 16 Executive Councild. Pg 8, in redirect observation of practicum experiences needs to be clarified. Can the observation be completed by the field supervisory school psychologist and reported to the program? It would be difficult to ask for faculty to make observations at a practicum setting where they are not cleared by the school’s Board of Directors for practice. HIPPA, FERPA and IEP regulations are all a concern here.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsvincentalfonsoDivision 16 Executive Councile. Pg 9, in section D #2 Required Internship: i. First a point of clarification. School psychology internships are highly regulated by the US Department of Education as well as the State Board of Education. That is, although most internships are not in the APPIC / APA system it is only because a different regulatory agency has a priority in schools. ii. Additionally, in the APPIC / APA system 2012 data show <2% of internships are in a school setting and only 1/3 of sites accept school psychology applicants. The field is in flux as we develop more APPIC / APA sites. 1. Note, the Division and CDSPP have committed substantial funds toward helping APA approved programs advance APPIC / APA internship developments in schools. There is an active grant program. Also, CDSPP in connection with CCTC has moved to increase the number of school APPIC/APA internships. This is an active commitment where several workshops and presentations regarding consortium development have taken place. ** A g... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsBruceZahn I support the NCSPP response for all sections.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsStephanieWoodNCSPPIn relation to Section II.C.1, NCSPP suggests that the term “training plan” is subject to misinterpretation. To this end, NCSPP recommends deleting the following from paragraph II.C.1: “that it provides a training plan applied and documented at the individual level, appropriate to the student’s current skills and ability that ensures that…” Instead, NCSPP recommends the following sentence: “The doctoral program needs to demonstrate that the student has attained the requisite level of competency by the time of application to internship.” In relation to Section II.C.1.c, it is recommended that the sentence be changed to read: “As part of a program’s ongoing commitment to ensuring the quality of their graduates, at least one practicum evaluation must be based in part on direct observation (either live or electronically).” NCSPP suggests that replacing “each” with “at least one” recognizes the importance of direct observation while allowing the use of sites which, for theoretical (e.g.... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsDavidSbarraAcademy of Psychological Clinical Science (APCS)II.C.1.b. Supervision. In this section, we assume “appropriately credentialed” means a licensed clinical psychologist. What does it mean for a doctoral program to “provide ongoing supervision by appropriately licensed faculty”? We believe this issue deserves careful consideration. Many of our programs have excellent clinical placement sites that are staffed by other licensed behavioral health professionals that can provide excellent supervision. What does the internal supervision need to look like if our students were to work at one of these sites? We believe the SoA should be more flexible in this regard and permit students to work at sites that have a licensed behavioral health supervisor (e.g., licensed social worker, psychiatrist, or marriage and family therapist) who provides the direct supervision. In this case, we could stipulate some minimum amount of time needed to be supervised by a licensed clinical psychologist. This section, then, could be re-written as follows: The large... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsAlisaManulkin I support the NCSPP response for this section.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsTimothyBrown I support the NCSPP response for this section.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsM.G.HardimanBoard of Professional Affairs (BPA)/Committee for the Advancement of Professional Practice (CAPP)JOINT BPA – CAPP COMMENTS ON PROPOSED STANDARDS OF ACCREDITATION “This statement represents the position of the Board of Professional Affairs and the Committee for the Advancement of Professional Practice regarding the APA policy on requiring APA accredited internships as a requirement for licensure for psychologists as it relates to the current CoA public comment request. We strongly encourage that CoA phase in a requirement that doctoral programs have students trained in an accredited internship. The internship is the capstone and most intensive clinical training experience in the doctoral program, and we believe that a recognized peer reviewed quality assurance mechanism for this training is essential for psychology's credibility as a health profession. Moreover, those psychologists currently entering the workforce without having had an APA accredited internship may be disadvantaged in career pursuits -- a disadvantage they may not have fully realized when enrolling in a docto... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsSchool Psychology ProgramUniversity of ArizonaUniversity of Arizona School Psychology Program1. Practicum: It may be clearer to state Pre-internship field experiences rather than practicum. Programs and sites vary in what they consider such “practica.” Field experiences would be inclusive of practicum, externships, and other health service psychology practice activities that may be embedded in a didactic course and not referred to as practicum. b. We agree with the statement that supervision must be provided by appropriately credentialed individuals. Further, we appreciate the flexibility for practica that do not provide a doctoral-level licensed psychologist, University supervision may be used to supplement. A further clarification should be made that there are times that the University supervisor may serve as a primary supervisor when an appropriately credentialed supervisor is not available, yet the setting provides opportunity for access to appropriate clients, services, and field experiences. c. We understand the requirement to have each practicum evaluation based in ... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsSchool Psychology ProgramUniversity of ArizonaUniversity of Arizona School Psychology Program2. Required Internship: b. Unaccredited internships: While it is commendable to ensure the quality of the internship, this section needs further clarification either in the SoA or IRs. As it is proposed, it is left entirely up to the programs to determine what “quality” is. Should standards just be based on state licensure requirements then? In order to provide Programs with clear expectations as to what the CoA would consider quality, it may be helpful to list minimum expectations for what would be considered appropriate, minimum expectations for supervision, etc. The following questions remain: 1) Who determines what “quality” is (the Program? Site visitors? CoA?); 2) Would it be considered “quality and adequate” if the internship follows Council of Directors of School Psychology Programs’ guidelines for internships, does the internship have to be consistent with the requirements for an internship to be APA accredited, or should standards be based on state certification/licensure ... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsBrianChu In the section on practica, I agree with CUDCP and APCS that regulations be mindful of the changing health care environment in which some of the best supervisors of psychological practice may be non-psychologists (e.g., social workers, psychiatrists, etc.).
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentC. Practicum and Required Training ElementsThomasKubiszynCRSPPPIIC2a. Because APA policy will require completion of APA accredited programs in 2018 and APA accredited internships in 2020, this requirement should be included in this section.
Doctoral StandardsIII. StudentsA. Selection processes and criteriaCynthiaRohrbeck For all sections below, I support the CUDCP response
Doctoral StandardsIII. StudentsA. Selection processes and criteriaLauraBuchholz For all sections below, I support the CUDCP response.
Doctoral StandardsIII. StudentsA. Selection processes and criteriaAmberShifflettBoard of Educational Affairs (BEA)-BEA appreciates the emphasis on preparing trainees to serve a diverse clientele (secondary to a change from the previous Footnote 4 as an element of the core standards for doctoral, internship, and postdoctoral programs). This change reflects the efforts of the BEA Working Group on Trainee Conflicts Serving a Diverse Clientele.
Doctoral StandardsIII. StudentsA. Selection processes and criteriaEddyAmeenAPAGS (American Psychological Association of Graduate Students)APAGS supports this standard in principle, as students need the support of peers for a fully enriched graduate school experience. However, we are currently unclear on the operational definition of the word “meaningful” and how its interpretation will directly impact students. We applaud the CoA for their focus on including students from diverse backgrounds. In particular, APAGS appreciates requiring programs to deliberately and consistently reflect on their diversity efforts and to continually improve. APAGS supports the move towards competency-based assessment for admission to doctoral programs in theory. Without a currently well-established and validated model of competency-based assessment for admission, APAGS has concerns about how the development and implementation of this system could adversely impact students. As one example, students who initially chose other career paths (e.g., social work) could be prevented from entering the field of psychology later in life if a comp... See Full Comment
Doctoral StandardsIII. StudentsA. Selection processes and criteriaDavidSbarraAcademy of Psychological Clinical Science Academy of Psychological Clinical Science (APCS) APCS’s Response to the Commission on Accreditation’s (CoA) Request for Public Comment on the Standards of Accreditation in Health Service Psychology (SoA) III.A.1.b.i. Implementing diversity. The final portion of the second sentence in this section (“… these alone are not sufficient”) is vague. With respect to student diversity, statements about what constitutes sufficient and insufficient recruitment should be clearly stated. III.A.1.b.ii. Evaluating diversity implementation. The SoA states, “The program should demonstrate that it examines the effectiveness of its efforts to attract diverse students and document any steps needed to revise/enhance its strategies.” What does this mean? Empirical assessment? How will this work in practice and how will programs be able to successfully meet this standard? (Also see section III.C.2. for the same issue.)
Doctoral StandardsIII. StudentsA. Selection processes and criteriaJoanRead I support the NCSPP response for all sections.
Doctoral StandardsIII. StudentsA. Selection processes and criteriaBruceZahn I support the NCSPP response for all sections.
Doctoral StandardsIII. StudentsA. Selection processes and criteriaTaniaIsraelAPA Committee on LGBT ConcernsA.b.i. Is "diversity" based on the definition in section D.1.? If so, it might be helpful to note that or refer to a footnote.
Doctoral StandardsIII. StudentsA. Selection processes and criteriaJenniferRipleyRegent University doctoral program in clinical psychologyThere is an assumption that diversity will always need to be increased when maintenance may be the goal over time for some programs. The face of diversity could shift over time as American society changes but we as a profession should reflect society in all its variety. It seems a better language is increase or maintain for programs with good Diversity of their student body.
Doctoral StandardsIII. StudentsA. Selection processes and criteriaStephanieWoodNCSPPNCSPP suggests two minor changes to this Section, which we believe will support clarity: a. In relation to Section A.1.c., we recommend changing the word “competency” to “readiness” to more appropriately capture expectations for incoming students. b. We recommend replacing A.1.c.i with the following: “If the program has criteria for selection that involve demonstration of past knowledge (e.g., GRE Psychology subject test, undergraduate or graduate GPA), the program should describe how they are used in student selection/admission decisions.” We recommend deleting A.1.c.ii as it is better articulated in the prior section.
Doctoral StandardsIII. StudentsA. Selection processes and criteriaSusanKeane I support the CUDCP response
Doctoral StandardsIII. StudentsA. Selection processes and criteriaDavidSbarraAcademy of Psychological Clinical Science (APCS)III.A.1.b.i. Implementing diversity. The final portion of the second sentence in this section (“… these alone are not sufficient”) is vague. With respect to student diversity, statements about what constitutes sufficient and insufficient recruitment should be clearly stated. III.A.1.b.ii. Evaluating diversity implementation. The SoA states, “The program should demonstrate that it examines the effectiveness of its efforts to attract diverse students and document any steps needed to revise/enhance its strategies.” What does this mean? Empirical assessment? How will this work in practice and how will programs be able to successfully meet this standard? (Also see section III.C.2. for the same issue.) V.A.2.c.i. Assessment of Discipline-specific Knowledge (DSK). This section suggests DSK knowledge can be assessed at entry into the program. How will this work and what will be acceptable? For example, can a program use a GRE Subject Test practice exam? If, say, a program defines having me... See Full Comment
Doctoral StandardsIII. StudentsA. Selection processes and criteriaHeatherSheets I support the NCSPP comments
Doctoral StandardsIII. StudentsA. Selection processes and criteriaAlisaManulkin I support the NCSPP response for this section.
Doctoral StandardsIII. StudentsA. Selection processes and criteriaTimothyBrown I support the NCSPP response for this section.
Doctoral StandardsIII. StudentsB. Supportive learning environment LauraBuchholz For all sections below, I support the CUDCP response.
Doctoral StandardsIII. StudentsB. Supportive learning environment RandallWyatt I support the NCSPP response for all sections.
Doctoral StandardsIII. StudentsB. Supportive learning environment EddyAmeenAPAGS (American Psychological Association of Graduate Students)As we indicated in Phase 2: APAGS is very concerned about the quality of mentoring that students receive in doctoral programs. A sizable number of doctoral recipients have had challenges with advisors and faculty, and the quality of mentoring varies significantly both between and within programs. Elaboration on this comment from Phase 2 can be found in lines 750 to 775 of our Phase 2 comments to CoA at http://tinyurl.com/apagscoap2. For this standard, APAGS has some concerns regarding the definition of faculty members beings “accessible” that could limit students’ access to high quality mentorship and training. If a program has too few faculty to adequately address the needs of admitted students, it is unlikely that a supportive learning environment could be attained. Additionally, “accessible” may be interpreted as “present” and does not adequately state that guidance, mentoring, and supervision are being provided. We advise CoA to establish criteria for minimum contact between studen... See Full Comment
Doctoral StandardsIII. StudentsB. Supportive learning environment BruceZahn I support the NCSPP response for all sections.
Doctoral StandardsIII. StudentsB. Supportive learning environment HeatherSheets I support the NCSPP comments
Doctoral StandardsIII. StudentsB. Supportive learning environment HeatherSheets I support the NCSPP comments
Doctoral StandardsIII. StudentsB. Supportive learning environment AlisaManulkin I support the NCSPP response for this section.
Doctoral StandardsIII. StudentsB. Supportive learning environment TimothyBrown I support the NCSPP response for this section.
Doctoral StandardsIII. StudentsC. Plans to maximize student success CellucciTonyAPTCThe Association of Psychology Training Clinics (APTC) Commentary on SOA for Health Service Doctoral Training Programs C. Plans to Maximize Student Success 3. We strongly support the need for timely feedback to students regarding their performance. We believe that programs should be required to have written policies and procedures for identifying students in need of remediation, and for the remediation process itself, including the remediation plans used, and that programs should demonstrate how and when this process is used, and its outcome.
Doctoral StandardsIII. StudentsC. Plans to maximize student success Jackieon behalf of HornASPPB Board of Directors• (p. 13) ‘feedback and remediation’ – ASPPB recognizes that it would not necessarily be appropriate that licensing boards have access to these records; however we would like to see, as part of portfolios, documentation that each year of training has been successfully completed and that the competencies expected at those levels have been assessed and met for each trainee/student. We will be glad to work with CoA to develop mechanisms that graduate programs can use to retain this information in formats that licensing boards can and will use.
Doctoral StandardsIII. StudentsC. Plans to maximize student success RandallWyatt I support the NCSPP response for all sections below.
Doctoral StandardsIII. StudentsC. Plans to maximize student success StephanieWoodNCSPPNCSPP recommends replacing C.1 with the following: “The program provides advising to facilitate timely completion of the program and to maximize student success.”
Doctoral StandardsIII. StudentsC. Plans to maximize student success BruceZahn I support the NCSPP response for all sections.
Doctoral StandardsIII. StudentsC. Plans to maximize student success HeatherSheets I support the NCSPP comments
Doctoral StandardsIII. StudentsC. Plans to maximize student success AlisaManulkin I support the NCSPP response for this section.
Doctoral StandardsIII. StudentsC. Plans to maximize student success TimothyBrown I support the NCSPP response for this section.
Doctoral StandardsSection IV: FacultyA. Program Leadership, Administration, and ManagementCynthiaRohrbeck For all sections below, I support the CUDCP response
Doctoral StandardsSection IV: FacultyA. Program Leadership, Administration, and ManagementLauraBuchholz For all sections below, I support the CUDCP response.
Doctoral StandardsSection IV: FacultyA. Program Leadership, Administration, and ManagementFrederickWechsler I support the NCSPP response for all sections.
Doctoral StandardsSection IV: FacultyA. Program Leadership, Administration, and ManagementEddyAmeenAPAGS (American Psychological Association of Graduate Students)APAGS believes this standard is adequate.
Doctoral StandardsSection IV: FacultyA. Program Leadership, Administration, and ManagementJoanRead I support the NCSPP response for all sections.
Doctoral StandardsSection IV: FacultyA. Program Leadership, Administration, and ManagementBruceZahn I support the NCSPP response for all sections.
Doctoral StandardsSection IV: FacultyA. Program Leadership, Administration, and ManagementAlisaManulkin I support the NCSPP response for this section.
Doctoral StandardsSection IV: FacultyA. Program Leadership, Administration, and ManagementTimothyBrown I support the NCSPP response for this section.
Doctoral StandardsSection IV: FacultyB. Faculty Qualifications and Role ModelingSuzanneMeeks A.1. This seems to duplicate stipulation in I.C.
Doctoral StandardsSection IV: FacultyB. Faculty Qualifications and Role ModelingSuzanneMeeks Why is B.2.e. included? The stipulation is that 50% of faculty time is available to the program. Why do accreditors need to worry about the other 50%?
Doctoral StandardsSection IV: FacultyB. Faculty Qualifications and Role ModelingCellucciTonyAPTCThe Association of Psychology Training Clinics (APTC) Commentary on SOA for Health Service Doctoral Training Programs IV. Faculty section 4 Faculty sufficiency c. Only requiring a minimum of one core faculty member to be licensed seems to be an extremely low standard and would create difficulty finding qualified supervisors among the core faculty. In fact, programs should be encouraged to have a reasonable percentage of core faculty involved in practicum training. We believe that supervision by program faculty is very important to promote integration of practicum training with the program’s training goals. Requiring just one core faculty member to be licensed works against this goal, and we believe that a higher number/percentage is essential.
Doctoral StandardsSection IV: FacultyB. Faculty Qualifications and Role ModelingDeborahBeidelCUDCPFrom the SoA text: "b. Core faculty must be composed of individuals whose primary professional employment (50% or more) is at the institution in which the program is housed, and to whom the institution has demonstrated a multiyear commitment. At least 50% of core faculty professional time must be devoted to program-related activities." CUCDP finds the statement above to be confusing. If a faculty member whose primary professional employment is 50% at the institution, does this mean that 100% of that time must be devoted to program-related activities?
Doctoral StandardsSection IV: FacultyB. Faculty Qualifications and Role ModelingChristineMaleckiCDSPP5. Cultural and Individual Diversity of Faculty Members. We would appreciate diversity being defined broadly – including ethnicity, gender, sexual orientation, bilingual or multilingual, etc.
Doctoral StandardsSection IV: FacultyB. Faculty Qualifications and Role ModelingAmberShifflettBoard of Educational Affairs (BEA)-BEA supports the expectation of direct observation of students as part of evaluation process. -BEA supports the explicit expectation for 50% of core faculty to be employed at the training institution. -Only one core faculty member needs to be licensed – While it is useful to address the issue of faculty licensure in doctoral programs, BEA is concerned that the current proposal to require licensure for only one core faculty member is too low. Doctoral programs benefit greatly from the provision of supervision by core faculty members in that there is increased integration of clinical and research/academic training. Although BEA recognizes that state laws vary, many do require licensure for faculty who supervise trainees. We encourage CoA to consider requiring that the majority of core faculty be licensed if this is a requirement to supervise trainees in the program’s jurisdiction. BEA also recommends that CoA provide clarification about this expectation especially as it relate... See Full Comment
Doctoral StandardsSection IV: FacultyB. Faculty Qualifications and Role ModelingLauraBuchholz I think a statement should be added regarding faculty responsibilities. For instance, some faculty solely focus on research and obtaining grants in their respective areas which is not reflected above.
Doctoral StandardsSection IV: FacultyB. Faculty Qualifications and Role ModelingJackieon behalf of HornASPPB Board of Directors• (p. 16) ‘faculty sufficiency’ – ASPPB strongly recommends that all faculty who provide coursework, training, or supervision related to the provision of health care services be fully licensed by their jurisdictions. Many, if not most, jurisdictions require individuals to be licensed if they are supervising the provision of health care services; faculty serve as role models, so should demonstrate the appropriate and highest level of professional achievement possible for students under their tutelage/supervision.
Doctoral StandardsSection IV: FacultyB. Faculty Qualifications and Role ModelingEddyAmeenAPAGS (American Psychological Association of Graduate Students)APAGS believes that, overall, this section on Faculty Qualifications and Role Modeling addresses many of the concerns expressed during earlier comment periods. We believe the variety of ways in which core faculty can contribute is a strength of the document and reflective of the numerous roles psychologists may hold within their careers (e.g., B.2.d). Core faculty: APAGS suggests clarification on parts b and e. On part b, APAGS is unclear on the operational definition of “sufficient in number” as the workload distributed among faculty could greatly influence the quality of training available. We defer to CoA to either provide rationale for this terminology or provide some guidance to this matter in the IRs, including how to operationalize “sufficient” and what might be considered “optimal.” On part d, APAGS would like clarification on the term “substantial competence.” Will programs be responsible for creating systems that subjectively or objectively determine faculty competence? ... See Full Comment
Doctoral StandardsSection IV: FacultyB. Faculty Qualifications and Role ModelingShawnCahill I support the CUDCP response
Doctoral StandardsSection IV: FacultyB. Faculty Qualifications and Role ModelingTaniaIsraelAPA Committee on LGBT ConcernsB.5.a. Does "differing backgrounds" include sexual orientation and gender identity/expression? Again, a footnote definition might help to clarify the intent.
Doctoral StandardsSection IV: FacultyB. Faculty Qualifications and Role ModelingStephanieWoodNCSPPIn general, NCSPP endorses Section IV of the proposed Standards as drafted with two additions: a. Under Section IV.B.2, it is recommended that the Standards incorporate the language from IR C-18, which more clearly delineates the time allocation and activities of core faculty. Specifically, it is recommended that this Section be changed to reflect the following: At least 50% of core faculty professional time must be devoted to program-related activities. That means, for example, that a faculty person who is 50% at the institution would need to have 100% of that time spent as a core faculty. (The day per week institutions often allow for professional development activities such as research, consultation, or practice is not intended to be added to or subtracted from this calculation. That is, a 100% core faculty person in an institution with a consultation policy should be thought of as a 100% person, not 125% or 80%, regardless of the activities done on that day.) A full time 9-mont... See Full Comment
Doctoral StandardsSection IV: FacultyB. Faculty Qualifications and Role ModelingBruceZahn I support the NCSPP response for all sections.
Doctoral StandardsSection IV: FacultyB. Faculty Qualifications and Role ModelingRandallWyatt I support the NCSPP response for all sections.
Doctoral StandardsSection IV: FacultyB. Faculty Qualifications and Role ModelingHeatherSheets I support the NCSPP comments
Doctoral StandardsSection IV: FacultyB. Faculty Qualifications and Role ModelingHeatherSheets I support the NCSPP comments
Doctoral StandardsSection IV: FacultyB. Faculty Qualifications and Role ModelingMarkYarhouseRegent University Doctoral Program in Clinical PsychologyWe want to emphasize our appreciation for CoA’s recognition that applying accreditation standards in constitutionally appropriate ways to faith based educational settings is an instantiation of respect for diversity rather than a diminution of it. Yet, we would concur with comments made by a number of the faith based programs regarding some potential problems with the language in the proposed SoA that may have the effect of reducing the protections affirmed by footnote 4 counter to the stated intent of CoA. Perhaps just a few revised sentences to something like the following would suffice: “Because of the United States’ rich diverse higher education landscape, training can take place in both secular and faith based settings. Thus programs with a religious affiliation or purpose may operate consistent with their religious affiliation and purpose under the prerogatives recognized by the U.S. constitution. Examples of these constitutional prerogatives include utilizing admissions and empl... See Full Comment
Doctoral StandardsSection IV: FacultyB. Faculty Qualifications and Role ModelingAlisaManulkin I support the NCSPP response for this section.
Doctoral StandardsSection IV: FacultyB. Faculty Qualifications and Role ModelingTimothyBrown I support the NCSPP response for this section.
Doctoral StandardsSection IV: FacultyB. Faculty Qualifications and Role ModelingBrianChu Agree with all organizations that using percentage time to define core faculty are difficult to interpret (given varying organizational structures) and today's myriad arrangements that can help a program enhance its training goals.
Doctoral StandardsSection IV: FacultyB. Faculty Qualifications and Role ModelingThomasKubiszynCRSPPPIVB3. The first sentence identifies three types of non-core faculty: associated, contributing and adjunct. Yet only associated and adjunct faculty are differentiated. How are programs to differentiate contributing from associated and adjunct faculty. CRSPPP suggest that the contributing category be eliminated.
Doctoral StandardsSection V: Communication Practices A. Public Disclosure APA Division44APA Division 44Comment from APA Division 44: We applaud the CoA’s new approach to integrating diversity throughout the proposed Standards of Accreditation. Whereas Footnote 4 language has understandably been retained and moved to the narrative, new text has been added that more clearly elaborates expectations for nondiscrimination, requires documentation of actions to recruit and retain diverse students and faculty, and expects transparency in policies affecting enrollment and employment. We are especially supportive of some new language: In B2, “Regardless of a program’s setting, the program may not constrain academic freedom or otherwise alter the requirements of these standards. Finally, compelling pedagogical interests require that each program prepare graduates to navigate cultural and individual differences in research and practice, including those that may produce value conflicts or other tensions arising from the intersection of different areas of diversity.” We also support the definit... See Full Comment
Doctoral StandardsSection V: Communication Practices A. Public Disclosure CynthiaRohrbeck For all sections below, I support the CUDCP response
Doctoral StandardsSection V: Communication Practices A. Public Disclosure LauraBuchholz For all sections below, I support the CUDCP response.
Doctoral StandardsSection V: Communication Practices A. Public Disclosure FrederickWechsler I support the NCSPP response for all sections.
Doctoral StandardsSection V: Communication Practices A. Public Disclosure EddyAmeenAPAGS (American Psychological Association of Graduate Students)APAGS believes that the information listed in Section V, Domain A, Item 2c (description of program) is inadequate. In addition to the information currently required, APAGS suggests that doctoral programs must provide accurate and timely information pertaining to students’ career placement (employment indicators), internship match rates (percent matched to an accredited internship on the first try), as well as licensure rates for the program. This information is critical for students to be able to make informed decisions about their academic training and careers. For the protection of diverse students, we ask that CoA require the establishment and public availability of policies related to maternity and paternity leave, family medical leave, disability leave, same sex and domestic partner benefits, caregiver policies, and other related policies. We understand that CoA may be limited in regulating individual employment policies, but at the very least, there is great potential in req... See Full Comment
Doctoral StandardsSection V: Communication Practices A. Public Disclosure LaurenMizockMotherhood Subcommittee Division 35June 20, 2014 Dear Members of the Commission on Accreditation, Maternity and paternity leave policy disclosure requirements are needed for doctoral, internship, and postdoctoral sites accredited by APA. This need has come to the attention of our Motherhood Subcommittee of Division 35, the Society for the Psychology of Women, based on reports from members, colleagues, and participants at APA conference presentations. Former and current trainees have indicated problems at their training sites related to inadequate maternity leave, pressure from supervisors to take a shorter leave, and fear of disclosure of pregnancy to supervisors and faculty. Some reported graduate school probation or dismissal from an internship site due to the length of their maternity leaves. Others reported unnecessary stress and frustration when they had to negotiate their maternity leaves given that clear guidelines were not in place at their training sites. A number of APA accredited training sites do ... See Full Comment
Doctoral StandardsSection V: Communication Practices A. Public Disclosure DavidSbarraAcademy of Psychological Clinical ScienceAcademy of Psychological Clinical Science (APCS) APCS’s Response to the Commission on Accreditation’s (CoA) Request for Public Comment on the Standards of Accreditation in Health Service Psychology (SoA) V.A.2.c.i. Assessment of Discipline-specific Knowledge (DSK). This section suggests DSK knowledge can be assessed at entry into the program. How will this work and what will be acceptable? For example, can a program use a GRE Subject Test practice exam? If, say, a program defines having met the DSK as > 90% on a GRE subject test practice exam, will this be sufficient for meeting the DSK requirements? The training community needs more details about how the selection-based DSK requirements will work in practice. Again, if students meet some pre-specified level for having demonstrated adequate DSK upon program entry, do they have to take classes in all four of the G&P breadth areas? If yes, can these be specialized seminars rather than survey courses?
Doctoral StandardsSection V: Communication Practices A. Public Disclosure BruceZahn I support the NCSPP response for all sections.
Doctoral StandardsSection V: Communication Practices A. Public Disclosure StephanieWoodNCSPPConsistent with feedback given under Section III, NCSPP recommends that the GRE not be referred to as a “competency-based” test (as it is currently described in Section A.2.c.i). NCSPP also recommends deleting Section A.2.c.i and Section A.2.c.ii. Although NCSPP endorses program articulation of the way in which its admission standards support student success to the accrediting body, it does not think this should be included in the information required for publication to students.
Doctoral StandardsSection V: Communication Practices A. Public Disclosure ArnoldKevinCouncil of Specialties in Professional PsychologyV.A.1 and V.A.2—CoS recommends that COA reference the APA “taxonomy” guidelines (http://www.apa.org/ed/graduate/specialize/taxonomy.pdf) and require that each program no longer use any descriptions of levels of specialty coverage other than the four identified in the “taxonomy” guidelines: Major Area of Study, Emphasis, Experience, or Exposure; and that COA require documentation of the use of any such term by a comparison of the programs specialty coverage to a given specialty’s articulation of the “taxonomy” levels of coverage at the doctoral level.
Doctoral StandardsSection V: Communication Practices A. Public Disclosure AlisaManulkin I support the NCSPP response for this section.
Doctoral StandardsSection V: Communication Practices A. Public Disclosure TimothyBrown I support the NCSPP response for this section.
Doctoral StandardsSection V: Communication Practices B. Communication and Relationship with the Accrediting BodyLauraBuchholz APA accreditation also requires that programs publish information regarding the acceptance and attrition rates of students admitted into their programs. This should be included here.
Doctoral StandardsSection V: Communication Practices B. Communication and Relationship with the Accrediting BodyEddyAmeenAPAGS (American Psychological Association of Graduate Students)APAGS believes this standard is adequate.
Doctoral StandardsSection V: Communication Practices B. Communication and Relationship with the Accrediting BodyBruceZahn I support the NCSPP response for all sections.
Doctoral StandardsSection V: Communication Practices B. Communication and Relationship with the Accrediting BodyHeatherSheets I support the NCSPP comments
Doctoral StandardsSection V: Communication Practices B. Communication and Relationship with the Accrediting BodyTimothyBrown I support the NCSPP response for this section.
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextSherriTurner These comments are for all sections. I was initially concerned that the SoA was going to be too prescriptive, but instead I find this document to be very clear and reasonable. I believe some of the ambiguity from the current document has been dealt with in a way that is still respectful of program faculty's decisions concerning program direction.
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextToddDuBose Greeting to all, and thank you for the invitation for public comments. My comments are based on a foundational concern of how to provide competencies to diverse populations while remaining ambiguous about what counts as “evidence,” “outcome,” “health,” and “psychology.” Given that reliability necessitates a proper match between what is measured and how it is measured, addressing meaningful concerns for human beings requires a human science approach to therapeutic care. Hence, evidence should be broadened beyond its typical natural science, experimental methodological understanding of statistical significance. Existential significance, lived experience, and the radical empiricism noted by William James as anything one experiences is more primary as data than secondary statistical analysis of such primary data. If we are truly interested in respecting the diversity of each individual served, then lived experience of those individuals should be included if not take primacy in defining... See Full Comment
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextJennyCornishAPPICThe Association of Psychology Postdoctoral and Internship Programs (APPIC) represents 756 internship and 162 postdoctoral programs. The APPIC Board greatly appreciates the opportunity to comment on the proposed Standards of Accreditation (SoA) in Health Service Psychology for Doctoral Programs. Overall, we are particularly grateful for the clear writing and the attempts to reduce redundancy in the proposed SoAs, and feel that they represent a very helpful outline for the field. Our feedback pertains an area for further clarification that may be best provided in the Implementing Regulations. In reviewing the SoAs, we appreciate the emphasis on APA accreditation as the profession’s standard in all levels of Health Service Psychology training. We endorse providing doctoral programs with an mechanism that recognizes programs which are working toward achieving accreditation, similar to the Accredited, on Contingency status that was implemented in 2012 for internship and postdo... See Full Comment
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextJennyCornishAPPICThe Association of Psychology Postdoctoral and Internship Programs (APPIC) represents 756 internship and 162 postdoctoral programs. The APPIC Board greatly appreciates the opportunity to comment on the proposed Standards of Accreditation (SoA) in Health Service Psychology for Doctoral Programs. Overall, we are particularly grateful for the clear writing and the attempts to reduce redundancy in the proposed SoAs, and feel that they represent a very helpful outline for the field. Our feedback pertains an area for further clarification that may be best provided in the Implementing Regulations. In reviewing the SoAs, we appreciate the emphasis on APA accreditation as the profession’s standard in all levels of Health Service Psychology training. We endorse providing doctoral programs with an mechanism that recognizes programs which are working toward achieving accreditation, similar to the Accredited, on Contingency status that was implemented in 2012 for internship and postdo... See Full Comment
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextmarykabiaggioAPA Division 44We applaud the CoA’s new approach to integrating diversity throughout the proposed Standards of Accreditation. Whereas Footnote 4 language has understandably been retained and moved to the narrative, new text has been added that more clearly elaborates expectations for nondiscrimination, requires documentation of actions to recruit and retain diverse students and faculty, and expects transparency in policies affecting enrollment and employment. We are especially supportive of some new language: In B2, “Regardless of a program’s setting, the program may not constrain academic freedom or otherwise alter the requirements of these standards. Finally, compelling pedagogical interests require that each program prepare graduates to navigate cultural and individual differences in research and practice, including those that may produce value conflicts or other tensions arising from the intersection of different areas of diversity.” We also support the definition of diversity in D1: “The Comm... See Full Comment
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextmarykabiaggioAPA Division 44Comment from APA Division 44: We applaud the CoA’s new approach to integrating diversity throughout the proposed Standards of Accreditation. Whereas Footnote 4 language has understandably been retained and moved to the narrative, new text has been added that more clearly elaborates expectations for nondiscrimination, requires documentation of actions to recruit and retain diverse students and faculty, and expects transparency in policies affecting enrollment and employment. We are especially supportive of some new language: In B2, “Regardless of a program’s setting, the program may not constrain academic freedom or otherwise alter the requirements of these standards. Finally, compelling pedagogical interests require that each program prepare graduates to navigate cultural and individual differences in research and practice, including those that may produce value conflicts or other tensions arising from the intersection of different areas of diversity.” We also support the definit... See Full Comment
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextMartitaLopez I agree with the CUDCP response.
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextMaryJansenDivision 18 - subcommittee on Serious Mental Illness1. We understand that there will not be a list of courses that precludes room should for training in specialized areas of interest, and we applaud this. Each training program should be able to provide some specialized training in areas of interest and expertise to students and faculty mentors – this is often why students choose certain doctoral and internship programs. 2. Regarding profession wide competencies We hope that public comment will be allowed when the definitions for each of the competencies are released. With the implementation of the ACA, health care will increasingly become more oriented toward a primary care model and more population based. Future Psychologists will need to be able to identify a wider range of disorders, work with a more diverse array of clients, and know when, and to whom, to refer. The specific interest of the group submitting these comments is serious behavioral health disorders, most particularly serious mental illnesses. In order for Psy... See Full Comment
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextTimothyTumlin Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextAmberShifflettBoard of Educational Affairs (BEA)GENERAL COMMENTS ON SOA: -BEA appreciates the HSP emphasis since it is consistent with the work of the interorganizational Health Service Psychology Education Collaborative, which consisted of representatives from CCTC, COGDOP and APA. BEA does encourage more concise use of the language of the HSP competencies recently endorsed by the APA Council of Representatives. These competencies, built on work over the years of multiple groups, have been the most widely vetted profession wide competencies developed in American psychology. It was an iterative process in which specific language and wording was very carefully negotiated among communities of interest. The current SoA language reflects a disconnect from the published competencies articulating expectations for health service psychologists. -BEA appreciates the flexibility built into the new SoA. -BEA appreciates that CoA is making current expectations concrete and mandatory, such as communication between doctoral program and... See Full Comment
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextLernerMatthew Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextSherrylGoodman I support the SSCP response regarding the proposed definition for evidence-based practice and evidence-based assessment.
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextPatriciaDixon I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextFrankGruba-McCallister I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextLavitaNadkarni I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextKenFogel I support the NCSPP response for all sections
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextCrystalCollier I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextNeJameJulieFlorida School of Professional PsychologyI support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextRandallWyatt I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextFrederickWechsler "I support the NCSPP response for all sections."
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextFrederickWechsler I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextNealon-WoodsMichele I support NCSPP's response for all sections.
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextvincentalfonsoDivision 16 Executive CouncilDivision 16 Response Standards of Accreditation in Health Service Psychology: Doctoral In general, is well written and consistent with current practices in doctoral level school psychology. We like the idea of undergraduate classes counting for broad and general knowledge so that more in-depth teaching can occur in these areas; the GRE subject test could be a possibility although that is not what the test was designed for – how that would work needs to be clarified. Division 16 supports the document with the following feedback. 1. Strengths: a. Allows for appropriately credentialed faculty to supervise practicum students. b. Makes it clear that psychologists can bill, helps with parity, breaks down barriers between mental health and education. 2. Challenges: a. Being able to articulate the similarities and differences between APA standards and State Board of Education (SBE) standards within training programs. Specifically, the school setting, by definition, prioritizes e... See Full Comment
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextFranBrown I support the NCSPP response for all sections
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextHeatherSheets I support the NCSPP comments
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextHeatherSheets I support the NCSPP comments
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextLeahHorvath I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextChristinaBrown I support the NCSPP response for all sections.
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextAlisaManulkin I support the NCSPP response for this section.
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextGeraldNissley As a licensed psychologist and member of the APA, I am further deeply concerned by the decided bias against blended and online programs in the SoA rules of the APA. I attended an university that utilized primarily online modalities, and I was able to secure an APA-accredited internship. Based on all typically forms of assessment (GRE, internship competitiveness, licensure oral exam, etc.), I was trained effectively for the practice of psychology. The ban on primarily online and blended programs doesn't appear to fit with the research that's actually available demonstrating that such forms of learning can be just as effective when performed appropriately. It seems as though it would be better to assess the outcomes of such programs when considering accreditation than it is to summarily write them off. Not only does it not make sense from an empirical standpoint, it also doesn't fit from a public policy standpoint. We need more behavioral healthcare providers, and we need m... See Full Comment
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextSorenHeitzAntioch University SeattleAntioch University Seattle appreciates the opportunity to comment on the proposed Standards of Accreditation. We support the inclusion of language in Sections I, II, III and IV of the proposed Standards of Accreditation for doctoral programs recognizing the emerging importance for programs to engage in concrete action to recruit and retain diverse student and faculty populations and remove policies which are burdensome or irrelevant for student success. Limiting electronic sharing of resources or faculty between campuses, not extending accredited status to recent graduates of newly accredited programs and the absence of any mechanism for a tiered or provisional access to accreditation, creates program requirements which may function as significant and disproportionate burdens for some programs and, ultimately, students in those programs. We agree that some core competencies for professional psychologists cannot be developed in online environments. The proposed proscriptive langu... See Full Comment
Doctoral StandardsI. Institutional and Program ContextGeneral comment on Institutional and Program ContextThomasKubiszynCRSPPPCRSPPP appreciated the time, effort and expertise that CoA has invested in developing the Standards of Accreditation (SoA) to replace the Guidelines and Principles (G & P). CRSPPP believes that, overall, the SoA substantively improves upon the G & P and should provide doctoral, internship and postdoctoral programs with more clear and consistent guidance regarding the standards that must be met to achieve and sustain APA accreditation. More specifically, CRSPPP welcomes the expansion of the consideration given to applicant programs that was extended to internship and postdoctoral programs in 2012. Yet, CRSPP also noted two general areas that either remain ambiguous or may be problematic with regard to the identification and recognition of specialties and proficiencies in Health Service Psychology, especially at the postdoctoral level. We also offer several specific comments after the general concerns are described. First, to support the intent of the SoA to clarify and coordin... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentAmberShifflettBoard of Educational Affairs (BEA)-BEA encourages CoA to take a longer-term view of how these changes will be implemented over time. BEA is in strong support of CoA's work to encourage ASPPB/licensing boards to trust accreditation and rather than develop specific curriculum expectations.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentAlexanderWilliams Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentKathleenPalm Reed I agree with the CUDCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentBufferdSara Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentKathrynHumphreys Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentBenjaminEmmert-Aronson Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentKennethSher I strongly support the SSCP response/proposal to put primary emphasis on the scientific evidence base with clinical experience and client preferences representing important but secondary roles.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentShariSteinman Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentHeathSchechinger Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentChristinaWilliams Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentJedidiahSiev Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentRosannaBreaux Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response. Thank you for your time.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentAnnaRudo-Hutt Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentBradleyWhite I support the SSCP response regarding the proposed definitions for evidence-based practice and evidence-based assessment.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentRobinToblin Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentAaronLyon Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentAmandaBryan Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentCynthiaRohrbeck Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentBrennaMaddox Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentLindsayBodell Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentJamesWood Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and Developmentdanielklein Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentKristyAllen Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentDavidTolin Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentBethanyTeachmanSociety for a Science of Clinical Psychology (APA Division 12, Section 3)The Society for a Science of Clinical Psychology (SSCP) would like to suggest edits to the proposed wording for two of the definitions related to Evidence Based Practice. Current wording: Evidence based Intervention: Demonstrates appropriate knowledge skills and attitudes in the selection, implementation, and evaluation of interventions that are based on the best scientific research evidence; respectful of clients’ values/preferences; and relevant expert guidance. Evidence-based Assessment: Demonstrates appropriate knowledge, skills, and attitudes in the selection, administration, and interpretation of assessments consistent with the best scientific research evidence and relevant expert guidance. Proposed edits: Evidence based Intervention: Demonstrates appropriate knowledge, skills, and attitudes in the selection, implementation, and evaluation of interventions that are based primarily on the best scientific research evidence with appropriate adaptations to take int... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentEugeneBotanov Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentSpencerDawson Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentAlexisMay It is very important that empirically sound evidence is the primary tool used to select assessment tools and to determine which treatments to present to clients as treatment options. Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentThomasSuter Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentKristinWeinzierl Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentMartitaLopez Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentMartitaLopez Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentKelseyHagan Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentWilliamBenson Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentGaudianoBrandon Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentSarahTarbox Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response and suggested edits.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentLeonardSimms Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentRebeccaReady Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentPatriciaDixon I support the NCSPP response for all sections.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentLeonardoBobadilla Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentLawtonErin Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentMichaelMoore Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentChrisSpencer Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentFrankGruba-McCallister I support the NCSPP response for all sections.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentThomasOlino Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentKenFogel I support the NCSPP response for all sections
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentStephanieLarew Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentAmieSchry Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentCrystalCollier I support the NCSPP response for all sections.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and Developmentdanielklein I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and Developmentdanielklein I support the Academy of Psychological Clinical Science response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentRandallWyatt I support the NCSPP response for all sections.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentNealon-WoodsMichele I support NCSPP's response for all sections.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentDylanGee Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentFranBrown I support the NCSPP response for all sections
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentLeahHorvath I support the NCSPP response for all sections.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentChristinaBrown I support the NCSPP response for all sections.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentDavidRosmarin Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the response of the Society for a Science of Clinical Psychology (SSCP).
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentAlisaManulkin I support the NCSPP response for this section.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentGeneral comment on Curriculum, Outcomes, and DevelopmentSorenHeitzAntioch University SeattleAntioch University Seattle appreciates the opportunity to comment on the proposed Standards of Accreditation. We support the inclusion of language in Sections I, II, III and IV of the proposed Standards of Accreditation for doctoral programs recognizing the emerging importance for programs to engage in concrete action to recruit and retain diverse student and faculty populations and remove policies which are burdensome or irrelevant for student success. Limiting electronic sharing of resources or faculty between campuses, not extending accredited status to recent graduates of newly accredited programs and the absence of any mechanism for a tiered or provisional access to accreditation, creates program requirements which may function as significant and disproportionate burdens for some programs and, ultimately, students in those programs. We agree that some core competencies for professional psychologists cannot be developed in online environments. The proposed proscriptive langu... See Full Comment
Doctoral StandardsIII. StudentsGeneral comment on StudentsAbbieGoldbergClinical program, Clark UFor all sections below, I support the CUDCP response.
Doctoral StandardsIII. StudentsGeneral comment on StudentsKathleenPalm Reed I agree with the CUDCP response.
Doctoral StandardsIII. StudentsGeneral comment on StudentsLeahHorvath I support the NCSPP response for all sections.
Doctoral StandardsIII. StudentsGeneral comment on StudentsvincentalfonsoDivision 16 Executive Councilb. Pg 5, in Section C #3 Services to support students with academic, financial, health, and personal issues: This section is too broad. It appears that programs would be responsible for student health care or personal support at any length. This is simply not possible from the university perspective. Some qualifying statement needs to be added here, otherwise the financial burden / responsibility is too great. We suggest that programs should be required to indicate those services that are available to students in these areas, and to provide referrals in cases of more extensive needs.
Doctoral StandardsIII. StudentsGeneral comment on StudentsPatriciaDixon I support the NCSPP response for all sections.
Doctoral StandardsIII. StudentsGeneral comment on StudentsEddyAmeenAPAGS (American Psychological Association of Graduate Students)APAGS is largely impressed with and supportive of the section on students. Overall, we are particularly appreciative of the emphasis on program accountability and diversity throughout the standards. However, our comments here reflect what information is currently provided as we at times found it difficult to comment fully without the availability of the IRs.
Doctoral StandardsIII. StudentsGeneral comment on StudentsFrankGruba-McCallister I support the NCSPP response for all sections.
Doctoral StandardsIII. StudentsGeneral comment on StudentsKenFogel I support the NCSPP response for all sections
Doctoral StandardsIII. StudentsGeneral comment on StudentsCrystalCollier I support the NCSPP response for all sections.
Doctoral StandardsIII. StudentsGeneral comment on StudentsNealon-WoodsMichele I support NCSPP's response for all sections.
Doctoral StandardsIII. StudentsGeneral comment on StudentsFranBrown I support the NCSPP response for all sections
Doctoral StandardsIII. StudentsGeneral comment on StudentsHeatherSheets I support the NCSPP comments
Doctoral StandardsIII. StudentsGeneral comment on StudentsChristinaBrown I support the NCSPP response for all sections.
Doctoral StandardsIII. StudentsGeneral comment on StudentsAlisaManulkin I support the NCSPP response for this section.
Doctoral StandardsIII. StudentsGeneral comment on StudentsSorenHeitzAntioch University SeattleAntioch University Seattle appreciates the opportunity to comment on the proposed Standards of Accreditation. We support the inclusion of language in Sections I, II, III and IV of the proposed Standards of Accreditation for doctoral programs recognizing the emerging importance for programs to engage in concrete action to recruit and retain diverse student and faculty populations and remove policies which are burdensome or irrelevant for student success. Limiting electronic sharing of resources or faculty between campuses, not extending accredited status to recent graduates of newly accredited programs and the absence of any mechanism for a tiered or provisional access to accreditation, creates program requirements which may function as significant and disproportionate burdens for some programs and, ultimately, students in those programs. We agree that some core competencies for professional psychologists cannot be developed in online environments. The proposed proscriptive langu... See Full Comment
Doctoral StandardsSection IV: FacultyGeneral comment on FacultyMargoJackson Not only for this section, but also for all sections, the integration throughout of values on individual and cultural diversity is apparent and appreciated!
Doctoral StandardsSection IV: FacultyGeneral comment on FacultyKahnDavid The draft of the new standards, as currently written, has some important faculty qualifications already listed. There are two additional qualifications that should be considered. First, it should be required that all core faculty members are licensed psychologists at the doctoral level. Second, it should be required that all core faculty members are regularly engaged in professional work as health service providers. I completed my doctoral degree in school psychology at Texas A&M University. The program at Texas A&M is an APA-accredited program. I met with the director of training before applying to the program, and he assured me that the training I would receive would fulfill the requirements for licensure as a psychologist. After graduation, I applied for licensure as a psychologist in Arkansas and Michigan. My application for licensure was initially denied, and I had to complete a number of additional steps in order to become licensed, steps that I should not have been required to c... See Full Comment
Doctoral StandardsSection IV: FacultyGeneral comment on FacultyKathleenPalm Reed I agree with the CUDCP response.
Doctoral StandardsSection IV: FacultyGeneral comment on FacultyLeahHorvath I support the NCSPP response for all sections.
Doctoral StandardsSection IV: FacultyGeneral comment on FacultyFrankGruba-McCallister I support the NCSPP response for all sections.
Doctoral StandardsSection IV: FacultyGeneral comment on FacultyPatriciaDixon I support the NCSPP response for all sections.
Doctoral StandardsSection IV: FacultyGeneral comment on FacultyKenFogel I support the NCSPP response for all sections
Doctoral StandardsSection IV: FacultyGeneral comment on FacultyCrystalCollier I support the NCSPP response for all sections.
Doctoral StandardsSection IV: FacultyGeneral comment on FacultyFranBrown I support the NCSPP response for all sections
Doctoral StandardsSection IV: FacultyGeneral comment on FacultyNealon-WoodsMichele I support NCSPP's response for all sections.
Doctoral StandardsSection IV: FacultyGeneral comment on FacultyChristinaBrown I support the NCSPP response for all sections.
Doctoral StandardsSection IV: FacultyGeneral comment on FacultyAlisaManulkin I support the NCSPP response for this section.
Doctoral StandardsSection IV: FacultyGeneral comment on FacultyBeauvaisJohnVAPTC - Executive CouncilIn the Doctoral Program SoA, more than one core faculty member and those teaching clinical skills are not required to be licensed. It is believed that, at a minimum, a set of faculty need to be appropriately credentialed and licensed in their jurisdiction to teach core competencies.
Doctoral StandardsSection IV: FacultyGeneral comment on FacultySorenHeitzAntioch University SeattleAntioch University Seattle appreciates the opportunity to comment on the proposed Standards of Accreditation. We support the inclusion of language in Sections I, II, III and IV of the proposed Standards of Accreditation for doctoral programs recognizing the emerging importance for programs to engage in concrete action to recruit and retain diverse student and faculty populations and remove policies which are burdensome or irrelevant for student success. Limiting electronic sharing of resources or faculty between campuses, not extending accredited status to recent graduates of newly accredited programs and the absence of any mechanism for a tiered or provisional access to accreditation, creates program requirements which may function as significant and disproportionate burdens for some programs and, ultimately, students in those programs. We agree that some core competencies for professional psychologists cannot be developed in online environments. The proposed proscriptive langu... See Full Comment
Doctoral StandardsSection V: Communication Practices General comment on Communication PracticesKathleenPalm Reed I agree with the CUDCP response.
Doctoral StandardsSection V: Communication Practices General comment on Communication PracticesLeahHorvath I support the NCSPP response for all sections.
Doctoral StandardsSection V: Communication Practices General comment on Communication PracticesNealon-WoodsMichele I support NCSPP's response for all sections.
Doctoral StandardsSection V: Communication Practices General comment on Communication PracticesFrankGruba-McCallister I support the NCSPP response for all sections.
Doctoral StandardsSection V: Communication Practices General comment on Communication PracticesPatriciaDixon I support the NCSPP response for all sections.
Doctoral StandardsSection V: Communication Practices General comment on Communication PracticesCrystalCollier I support the NCSPP response for all sections.
Doctoral StandardsSection V: Communication Practices General comment on Communication PracticesKenFogel I support the NCSPP response for all sections
Doctoral StandardsSection V: Communication Practices General comment on Communication PracticesFranBrown I support the NCSPP response for all sections
Doctoral StandardsSection V: Communication Practices General comment on Communication PracticesHeatherSheets I support the NCSPP comments
Doctoral StandardsSection V: Communication Practices General comment on Communication PracticesChristinaBrown I support the NCSPP response for all sections.
Doctoral StandardsSection V: Communication Practices General comment on Communication PracticesAlisaManulkin I support the NCSPP response for this section.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramMary AliceConroy I am concerned about the practicality of evaluating graduates on the mandated profession-wide competencies after 2 years. First, it seems to assume that all of them are utilizing all of those competencies in whatever current employment they hold. Second, I am not sure who you would do this from a distance. Simply ask them? That seems awfully weak. Survey their current supervisors? That would no doubt require permission and most supervisors would hesitate to say they employ incompetent people.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramAlanGross 1. ii Tracking graduates' activities 5 and 10 years (which would actually be 6 and 11 as a result of the internship) post graduation seems somewhat unreasonable. The contract when accepting students is to prepare them to be psychologists. Accreditation requirements currently demand considerable data demonstrating requisite professional competencies. Programs have no control over their graduates' subsequent life choices. People change professions for many reasons (e.g., attorneys). It is not clear to me how the decision to leave the profession reflects on the quality of training provided by a graduate program. More importantly, how does having this information information inform graduate training policy.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramCellucciTonyAPTCThe Association of Psychology Training Clinics (APTC) Commentary on SOA for Health Service Doctoral Training Programs D. Program Policies and Procedures 1.d We would strongly recommend that programs create clear standards for evaluating students on their applied training, since this tends to be more challenging than academic course evaluations. We understand that this may be in the IR’s, but want to mention here to ensure inclusion.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramDeborahBeidelCUDCPCUDCP is concerned that 10 years may be too extensive a period of time for tracking of program graduates. For many students, career changes may occur that have nothing to do with the quality of the training program. Serious illnesses may force a graduate to give up or change careers, parents may decide to give up a career to raise children. There needs to be some consideration of graduates who are no longer in the profession, where the reasons are clearly unrelated to training. Although licensure is obviously a final outcome of the training sequence, simply calculating the number of students who are licensed could provide misleading data about program quality. Therefore in addition to the total number of program graduates who are licensed, CUDCP believes that an equally important metric is the number of students who sat for the licensing exam and passed.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramChristineMaleckiCDSPP3. Documenting and Achieving Outcomes Demonstrating Program’s Effectiveness. Our membership appreciates that the CoA recognizes the different aims and potential for successful practice. It would be nice if it were acknowledged that licensure rates may differ state to state given very different post-doc and exam requirements.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramMary LouiseCashel I support the CUDCP response.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramLauraBuchholz Regarding licensure, some psychologists do not go on to obtain their license. For instance, experimental psychologists do not provide clinical interventions, and thus, are not licensed. Also, some clinical psychologists do not go on to obtain licensure. This should be reflected in the standards above.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramAlexandraRoth Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramJackieon behalf of HornASPPB Board of Directorsp. 11) ‘documenting and achieving outcomes…’ – The wording in this section seems to be somewhat contradictory. If “all accredited doctoral programs are expected to prepare students for entry-level practice as health service psychologists”, then why wouldn’t CoA expect all of the graduates to be licensed if they are working? Where a program’s goals are to train people for academic or research careers, we believe it is important for CoA to define what the appropriate outcome measures would be.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramPaulIngram Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramEddyAmeenAPAGS (American Psychological Association of Graduate Students)APAGS believes that, in addition to outlining the minimum levels of achievement for competency, excellence should have an objectively defined baseline. There is an important distinction between competent and excellent skillsets that may speak to a graduate’s job placement, retention, and so forth, and that distinction should be on the record for programs. A benchmark for excellence provides an opportunity for students to continue growth and learning after reaching competency while also promoting psychology’s core commitment to lifelong learning. APAGS supports the use of multiple methods of evaluation. APAGS believes that specific outcome data should be referenced, including time to completion, career placement (including type of career and relevance to training), accredited internship match rate on first try, and licensure rates. APAGS believes that licensure rates are an important outcome for program evaluation, especially when the explicit goal is that all students are prepar... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramEddyAmeenAPAGS (American Psychological Association of Graduate Students)APAGS believes that, in addition to outlining the minimum levels of achievement for competency, excellence should have an objectively defined baseline. There is an important distinction between competent and excellent skillsets that may speak to a graduate’s job placement, retention, and so forth, and that distinction should be on the record for programs. A benchmark for excellence provides an opportunity for students to continue growth and learning after reaching competency while also promoting psychology’s core commitment to lifelong learning. APAGS supports the use of multiple methods of evaluation. APAGS believes that specific outcome data should be referenced, including time to completion, career placement (including type of career and relevance to training), accredited internship match rate on first try, and licensure rates. APAGS believes that licensure rates are an important outcome for program evaluation, especially when the explicit goal is that all students are prepar... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramDouglasMennin Regarding the proposed definitions for evidence-based practice and evidence-based assessment, I support the SSCP response
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramShawnCahill I support the CUDCP response
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramDavidSbarraAcademy of Psychological Clinical ScienceAcademy of Psychological Clinical Science (APCS) APCS’s Response to the Commission on Accreditation’s (CoA) Request for Public Comment on the Standards of Accreditation in Health Service Psychology (SoA) II.D.1.a.ii. Students’ Competencies. This section of the document on “outcome data” is exceptionally vague and has the potential to become incredibly burdensome. As indicated above, many of the PWCs are vague from the outset. In this section, what do “best practices” mean? Will there be a set of guidelines that outline the best practices? II.D.1.b.i. Program graduate preparation in PWC. This proposed change will be exceptionally burdensome on programs, and we recommend it be removed entirely from the SoA. Our concern here is based primarily on the vague wording of the PWCs and the absence of the associated IRs. The training community has no way to evaluate what will be required, and it is also not clear what programs will be required to assess from their graduates. II.D... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramRandallWyatt I support the NCSPP response for all sections.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramBruceZahn I support the NCSPP response for all sections.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramStephanieWoodNCSPPIn relation to Section II.D.1.a.i: NCSPP recommends deleting the last sentence of this paragraph (i.e., “The level of achievement expected should reflect the current standards of the profession.”) as this is ambiguous and subjective. In relation to Section II.D.1.a.ii: NCSPP recommends deleting “including at least some form of direct observation” at the conclusion of this paragraph, as inclusion erroneously implies that direct observation is perhaps more reliable and valid than other forms of competency evaluation. In relation to the distal outcome measures referenced in Section II.D.1.b.ii, NCSPP concurs that programs must be required to engage in a documented, concerted effort to collect data on graduates. However, NCSPP suggests that the recommended time intervals (5 and 10 years) are too protracted, and will necessarily limit the ability of a program to comply with this requirement with limited evidence of the usefulness/meaning of student status a decade post-graduation. Dat... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramStephanieWoodNCSPPIn relation to Section II.D.1.a.i: NCSPP recommends deleting the last sentence of this paragraph (i.e., “The level of achievement expected should reflect the current standards of the profession.”) as this is ambiguous and subjective. In relation to Section II.D.a.ii: NCSPP recommends deleting “including at least some form of direct observation” at the conclusion of this paragraph, as inclusion erroneously implies that direct observation is perhaps more reliable and valid than other forms of competency evaluation. In relation to the distal outcome measures referenced in Section II.D.b.ii, NCSPP concurs that programs must be required to engage in a documented, concerted effort to collect data on graduates. However, NCSPP suggests that the recommended time intervals (5 and 10 years) are too protracted, and will necessarily limit the ability of a program to comply with this requirement with limited evidence of the usefulness/meaning of student status a decade post-graduation. Data at... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramDavidSbarraAcademy of Psychological Clinical Science (APCS)II.D.1.a.ii. Students’ Competencies. This section of the document on “outcome data” is exceptionally vague and has the potential to become incredibly burdensome. As indicated above, many of the PWCs are vague from the outset. In this section, what do “best practices” mean? Will there be a set of guidelines that outline the best practices? II.D.1.b.i. Program graduate preparation in PWC. This proposed change will be exceptionally burdensome on programs, and we recommend it be removed entirely from the SoA. Our concern here is based primarily on the vague wording of the PWCs and the absence of the associated IRs. The training community has no way to evaluate what will be required, and it is also not clear what programs will be required to assess from their graduates. II.D.1.b.ii. 5-10 year outcome data on graduates. These criteria should be specified in detail so that the training community can get a sense of the “scholarly/research contributions” that would demonstrate having suf... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramAlisaManulkin I support the NCSPP response for this section.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramTimothyBrown I support the NCSPP response for this section.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramSchool Psychology ProgramUniversity of ArizonaUniversity of Arizona School Psychology Program1. Evaluation of students’ competencies: a. We agree with the need to provide multiple methods of assessment to determine if competencies are met by graduates. b.i. It is unclear how programs can show two years after graduation that the Program prepared students for profession-wide and program-specific competencies. Would these be self-reports of graduates or would it be expected to get job performance evaluations? If this requirement refers to job placement and licensure rates, then such distal data might be possible. To support school psychology programs, credential as a school psychologist should be viewed as a positive outcome, if the Program sets that as a distal data point. ii. We find the idea of providing ten years post-graduation data unnecessary and, furthermore, do not believe it should be the program’s responsibility. Even for graduates who could be tracked up to ten years post-graduation, it is unclear how Programs should be held accountable for whether former stu... See Full Comment
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramBrianChu I agree with CUDCP, APCS, and NCSPP that the guidelines for outcomes need to be more specified and that 10 year outcomes are overly burdensome, unlikely to provide relevant data for training outcomes, and will lead many programs to non-compliance.
Doctoral StandardsII. Curriculum, Outcomes, and DevelopmentD. Evaluation of Students and ProgramThomasKubiszynCRSPPPIID1bii. Because the extent to which program graduates are licensed and active in scholarship can vary across both programs and graduates, collection of distal data is important to program evaluation. Yet, collecting those data can be very burdensome and problematic for programs, especially as graduates have become increasingly mobile in recent years. Graduates may not respond to data requests, especially if they are annual and/or cumbersome, and even tracking the states that graduates may reside within may not be possible, much less their scholarly productivity and “those who are still licensed.” CRSPPP recommends that the feasibility of this requirement be studied further before inclusion in the SoA.
Internship StandardsI. Institutional and Program ContextA. Type of programAmberShifflettBoard of Educational Affairs (BEA)Item “c” is confusing: “The program may admit interns from any accredited doctoral program (single-entity internship) or from a specific accredited doctoral program (exclusively affiliated internship).” Feedback: Single entity concept is confusing terminology.
Internship StandardsI. Institutional and Program ContextA. Type of programA. GladeEllingson I agree with and wish to strongly support the comments submitted throughout by the Association of Counseling Center Training Agencies (ACCTA).
Internship StandardsI. Institutional and Program ContextA. Type of programAlliAndersonACCTAI strongly support the ACCTA statement regarding the SoA for Internship Standards.
Internship StandardsI. Institutional and Program ContextA. Type of programAmberShifflettBoard of Educational Affairs (BEA)- In the proposed internship standards, “school” needs to be added to the current listing of acceptable training locations: "Location. This is the setting at which internship education and training in health service psychology takes place (e.g., hospital, counseling center, or VA). Programs can be single-site or multiple-site."
Internship StandardsI. Institutional and Program ContextA. Type of programTODDFINNERTY It is interesting to note that CMS (Centers for Medicare and Medicaid Services)) recently concluded in the Federal Register that there is no evidence supporting a difference between an accredited and unaccredited program. This was in response to the National Register attempting to get CMS to require psychologists to have had an accredited program in order to be eligible for Medicare reimbursement in Community Mental Health Centers. See CMS's response to comments from the National Register-- see pg. 64609 of the Federal Register/ vol. 78. no. 209, 10/29/13. CMS said "However, we do not have any data indicating that clinical psychologists graduating from non- accredited programs reduces the level of quality care provided to clients served. Without formal evidence, modifying the psychologist personnel requirement in the CoPs would create a discrepancy between the conditions of participation and the payment policy requirements at Sec. 410.71(d)." This is equally the case for accredite... See Full Comment
Internship StandardsI. Institutional and Program ContextA. Type of programRobertPerl I support the NCSPP response for all sections.
Internship StandardsI. Institutional and Program ContextA. Type of programEddyAmeenAPAGS (American Psychological Association of Graduate Students)APAGS believes this standard is adequate.
Internship StandardsI. Institutional and Program ContextA. Type of programDianaConcannon I support the NCSPP response for all sections.
Internship StandardsI. Institutional and Program ContextA. Type of programStephanieWoodNCSPPConsistent with the perspective expressed in relation to the proposed standards for accreditation of doctoral programs, NCSPP maintains that the term “Health Service Psychology,” referenced in Section I.A.1 and employed as the overarching descriptor for accredited internship programs, is too restrictive. Although, NCSPP appreciates the aim of the term – which appears to be to ensure sensitivity to, and psychologist participation within, the changing health care environment – HSP does not reflect the fact that broad and general doctoral internship training is intended to be broader than in “health” and “service,” and that graduates can take on various future roles, including those of academic program faculty, consultants, and researchers for which the “health service” label is not a good fit. It is a term that is not widely used and tends to be misinterpreted. Indeed, although APA has used the term, it is notable that at a recent meeting of CAPP (arguably the leaders of professional ... See Full Comment
Internship StandardsI. Institutional and Program ContextA. Type of programGilbertNewman I support the NCSPP response for all sections.
Internship StandardsI. Institutional and Program ContextA. Type of programAlisaManulkin I support the NCSPP response for this section.
Internship StandardsI. Institutional and Program ContextA. Type of programTimothyBrown I support the NCSPP response for this section.
Internship StandardsI. Institutional and Program ContextA. Type of programM.G.HardimanBoard of Professional Affairs (BPA)/Committee for the Advancement of Professional Practice (CAPP)JOINT BPA – CAPP COMMENTS ON PROPOSED STANDARDS OF ACCREDITATION (Note, Also posted under Doctoral Standards, Section II, C Practicum and Required Training Elements) “This statement represents the position of the Board of Professional Affairs and the Committee for the Advancement of Professional Practice regarding the APA policy on requiring APA accredited internships as a requirement for licensure for psychologists as it relates to the current CoA public comment request. We strongly encourage that CoA phase in a requirement that doctoral programs have students trained in an accredited internship. The internship is the capstone and most intensive clinical training experience in the doctoral program, and we believe that a recognized peer reviewed quality assurance mechanism for this training is essential for psychology's credibility as a health profession. Moreover, those psychologists currently entering the workforce without having had an APA accredited internship may be disadvan... See Full Comment