Accreditation Public Comment System





This project is now closed for new comments.
DocumentSectionItemFirst NameLast NameGroup NameComment 
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsArpanaInmanCCPTPCCPTP supports the Intent to Apply IR for Doctoral Programs
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsRonPilato I endorse NCSPP's response.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsCrystalCollier I support NCSPP's recommendations.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsLeeCooper I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsLaurenNichols I support NCSPP's recommendations.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsNabilEl-GhorouryAPAGSAPAGS is pleased to comment on the Implementing Regulations for the Commission on Accreditation. This is an important step in moving forward with the new Standards of Accreditation. In general, APAGS is supportive of the recommended changes to the Implementing Regulations. The “Intent to Apply” and “Accredited, on Contingency” Implementing Regulations promote transparency to students and appropriate methods to evaluate control in terms of training. The proposed timelines for achieving full accreditation appear reasonable and feasible for programs. Following these timelines, students entering a doctoral program at the “Intent to Apply” stage could conceivably graduate from an accredited program, should their program choose to ultimately apply for accreditation. This change will likely have a positive effect on the lives of many students.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsSherrylGoodman I fully support the responses submitted by CUDCP and APCS.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsLanceSwenson I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsStewartShankman I endorse the comments made by CUDCP and APCS.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsDylanGee I agree with the response from APCS.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsTonyCellucciAPTCIntent to Apply IR for Doctoral Programs. APTC is in strong support of these new statuses. Under “Process to apply,” the first sentence reads in part: “To apply for this status, programs are asked to submit documentation in accordance with the SS instructions…” We presume this means self-study but would recommend spelling it out.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsThomasOltmannson behalf of the Academy of Psychological Clinical Science (APCS)The APCS Executive Committee believes that this IR is reasonable. It has no added comments.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsAlaynaPark I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsAlaynaPark I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsAlaynaPark I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsBarryDauphinDivision 39 Board of Directors and Education & Training CommitteeAlthough we appreciate the efficiency of section-by-section comments, that does not readily allow for comments addressed to the document as a whole. We suggest this option be included in future public comment phases. To that end, the document understandably emphasizes the significance of scientific practice or practice based upon science by repeating this throughout the document. We believe that the document should likewise emphasize ethics in practice or practice based upon ethical principles throughout the document, rather than isolating ethics to a single section. Also APA has a Policy Statement on Evidence Based Practices in Psychology, which should be referenced in this document.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsGuanKaren I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsDanielleKeenan-Miller I endorse the comments made by APCS.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsLeahHorvath I support the NCSPP comments and recommendations in all areas.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsAliciaDel Prado I endorse the NCSPP response for all sections.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsAliciadel Prado I endorse the NCSPP response for all sections.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsStephenDeMersASPPBASPPB is very appreciative of the time, effort and collaboration that CoA has exhibited throughout the current revision process. We believe that it is in everyone’s interest, and especially the consumers interest, for all major psychology professional associations and organizations to work together to advance high standards for the field. The Implementing Regulations are a means to further define and clarify concepts in the Standards of Accreditation, and thus deserve careful review and thoughtful deliberation. We know that you have already considered our point of view while developing these regulations and hope that our comments below will assist you in your final deliberations. Intent to Apply for Doctoral Programs and Accredited on Contingency ASPPB supports adding the intent to apply status and the accredited on contingency status for doctoral programs as it did for internship programs. The time frames suggested for how long a program can be in both statuses seem appropriate... See Full Comment
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsRobertBarrett I support the comment made by NCSPP
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsRajaDavid I endorse the NCSPP response for this section.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsAlisaManulkin I endorse the NCSPP response
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsAngusLynne  Humanistic psychotherapy research 1990–2015: From methodological innovation to evidence-supported treatment outcomes and beyond LYNNE ANGUS, JEANNE CHERRY WATSON, ROBERT ELLIOTT, KIRK SCHNEIDER,& LADISLAV TIMULAK5 Psychotherapy Research, 2014 http://dx.doi.org/10.1080/10503307.2014.989290 Despite a significant decline in research funding sources and HP clinical training centres, particularly in North America, HP researchers have managed to complete an increasing number of randomized controlled trials to assess the efficacy of HP approaches – in particular emotion-focused therapy in comparison to client-centred and cognitive behaviour therapy – to address a range of clinical disorders - Depression, Complex Trauma and Emotional-injuries in couples (Greenberg & Watson 1998; Goldman, Greenberg & Angus 2006; Watson et al 2003) over the past twenty years. Importantly, the key empirical question of ‘does HP work?’, recent meta-analytic analyses, summarizing findings fr... See Full Comment
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsTorreyWilson I strongly support the NCSPP recommendations.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsTorreyWilson I strongly support the NCSPP recommendations.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsTorreyWilson I strongly support the NCSPP recommendations.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsTorreyWilson I strongly support the NCSPP recommendations.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsTorreyWilson I strongly support the NCSPP recommendations.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsTorreyWilson I strongly support the NCSPP Recommendations/Comments.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsHeatherSheets "I endorse the NCSPP response for all sections."
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsHeatherSheets "I endorse the NCSPP response for all sections."
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsTimothyBrown I endorse the NCSPP response for this section.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsWallaceDixonCouncil of Graduate Departments of Psychology (COGDOP) COGDOP would like the IR language to clarify whether, and in how much detail, programs can expect to receive feedback when submitting an Intent to Apply. The language also does not specify whether this status is required of programs before they apply for contingent accreditation status. Omission of this language implies that one is not required before the other, but COGDOP requests the CoA to make this point crystal clear to its publics.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsBradRoperSociety for Clinical Neuropsychology (Div. 40), representing 4,330 membersThe Society for Clinical Neuropsychology welcomes the opportunity to comment on the draft implementing regulations. Intent to apply status needs to be clearly defined to insure that prospective students can understand it. It is unclear what the consequences are to a program that fails to obtain accreditation within the three years of intent to apply status. The implementing regulation seems to serve the interests of programs but not necessarily those of students. If a program is in this status, how are students, prospective students, and the public kept aware of the program’s status and its progress toward obtaining accreditation? Could students in the program be led to expect accreditation only to find that the program was ill-prepared and did not obtain it? Since intent to apply status potentially comes very cheaply for programs, there should be more information available to the public regarding a program’s status. For example, it would be helpful for the public to be updated on wher... See Full Comment
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsChristineMaleckiCouncil of Directors of School Psychology Programs Executive CommitteeThe Council of Directors of School Psychology Programs Executive Committee finds this IR helpful and relatively clear. It is recommended that more specific details could be provided that make timelines even more clear. For example, does a program’s status change to “Under Review” from Intent to Apply once application is submitted? Does the Intent to Apply status apply only prior to application or is that the status given up until an alternative status (i.e., accredited) is established? Three years is given, but it would be helpful if it were clearly stated that they must have submitted an application within three years or what marker would meet that requirement. Under Process to Apply spell out “SS” instructions for clarity.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsGeoritaFriersonRowan University Clinical Psychology Ph.D. ProgramWe agree with the comments from CUDCP and APAGS.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsStantonAnnette I endorse the APCS comments.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsJeffreyGoodie I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsMeganO'Banion I support NCSPP's recommendations.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsElizabethMagro I fully support NCSPP's recommendations.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsAmyWilliams I endorse ACCTA's comments
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsBrianDOnofrio I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsDeborahBeidelCouncil for University Directors of Clinical Psychology (CUDCP)CUDCP agrees with the language of this IR.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsMarkLumley I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsHidekoSeraNCSPPIntent to Apply IR for Doctoral Programs NCSPP appreciates the addition of this category, and has no recommended changes to the IR as proposed.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsMartitaLopez I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsMichellePaul I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsRobertPerl I endorse the NCSPP response for all sections.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsKathleenSikkema I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsBrandonGibb I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsCarlaSharp I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsCornishJennyAssociation of Psychology Postdoctoral and Internship Centers (APPIC)APPIC supports the Intent to Apply IR for Doctoral Programs. In addition to providing helpful information for the public, this status will provide developing doctoral programs the opportunity to demonstrate they have a specific plan to move forward for quality training. APPIC will use this information to assess whether a program should be considered eligible to allow these students to participate in the APPIC match. Beginning in 2017 the APPIC internship match will be restricted to students from APA or CPA accredited doctoral programs in health service programs.
Implementing Regulations for Public Comment Phase IIntent to Apply IR for Doctoral ProgramsIntent to Apply IR for Doctoral ProgramsBeckyReady I agree with the CUDCP response
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsDeborahBeidelCouncil for University Directors of Clinical Psychology (CUDCP)CUDP agrees with the language of this IR with the following exception: CUDCP supports the need for clear evidence of curriculum and practicum evaluations. We believe however, that there must also be clear and sufficient evidence of the research training component that is integral to training for the Ph.D. degree. We believe that the “evidence necessary for accreditation on contingency must be expanded to include evidence of research training, such as research evaluations (by research mentors) and completed Master’s theses available for review.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsJulieNeJame I agree with the statements presented.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsDavidMarcus I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsCrystalCollier I support the NCSPP response.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsRonPilato I endorse NCSPP's response.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsMartitaLopez I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsArpanaInmanCCPTPCCPTP supports the Doctoral Programs accreditation on contingency IR
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsLeeCooper I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsBrandonGibb I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsLaurenNichols I support NCSPP's recommendations.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsNabilEl-GhorouryAPAGS(read with comment on Intent to Apply) As well, the “Accredited, on Contingency” Implementing Regulations emphasizes keeping students and the public informed of changes in the timelines of “Accredited, on Contingency” programs that could adversely impact accreditation status. This is a positive change that allows students to act as informed consumers when selecting a doctoral program. We feel the “Intent to Apply” Implementing Regulations should also include a statement about keeping students and the public informed about changes that could adversely affect a program’s chances at attaining accreditation.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsSherrylGoodman I fully support the responses submitted by CUDCP and APCS.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsLanceSwenson I agree with the CUDCP response
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsStewartShankman I endorse the comments made by CUDCP and APCS.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsCindyYee-Bradbury I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsGuanKaren I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsHannahWilliamson I endorse the APCS comments on this IR.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsMichelleFenesy I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsThomasOltmannson behalf of the Academy of Psychological Clinical Science (APCS)This IR is also reasonable, and APCS supports the following addition (see CUDCP recommendations). For programs that emphasize research training and active participation in psychological science, the program should also be required to submit data to indicate that students are making adequate progress in that domain.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsAlaynaPark I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsKristenJezior I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsBrianDOnofrio I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsLaurenHarris I endorse comments made by APCS
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsDanielleKeenan-Miller I endorse the comments made by APCS.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsAliciadel Prado I endorse the NCSPP response for all sections.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral Programsdenisechavira I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsAliciadel Prado I endorse the NCSPP response for all sections.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsRobertBarrett I support the comments made by NCSPP
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsRajaDavid I endorse the NCSPP response for this section.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsMichelleMontagno I support NCSPP's response.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsAlisaManulkin I endorse the NCSPP response
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsAliciadel Prado I endorse the NCSPP response for all sections.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsAliciadel Prado I endorse the NCSPP response for all sections.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsDianeBlau I support this IR.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsMartinezDavid I fully support the "accredited, on contingency." This will help a lot of students who are in new & good quality programs.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsTorreyWilson I strongly support the NCSPP recommendations/comments.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsHeatherSheets "I endorse the NCSPP response for all sections."
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsGeoritaFriersonRowan University Clinical Psychology Ph.D. ProgramWe agree with the comments from CUDCP and APAGS.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsAndrewChristensen I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsWallaceDixonCouncil of Graduate Departments of Psychology (COGDOP) COGDOP supports the creation of this status, especially as programs gear up for full accreditation status. COGDOP also strongly endorses that programs need not have a full complement of faculty at the time of self-study submission, so long as they describe “plans for ensuring faculty sufficiency as the program grows to include students at all levels of matriculation…” However, COGDOP is concerned about how program syllabi will be reviewed. Because the current IR language requires that syllabi for all courses be submitted with the self-study, but doesn't require that all potential faculty be in residence, COGDOP requests that this IR be revised to specify that affected syllabi can identify faculty as TBD. It will be important to make this clear so as to ease potential program anxiety. Otherwise, there is considerable risk of excessive “Defer for Information” determinations simply on the basis of programs not having the full complement of faculty on staff, which the IR explicitly al... See Full Comment
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsDellaniraGarcia I support NCSPP's response.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsBradRoperSociety for Clinical Neuropsychology (Div. 40), representing 4,330 membersLacking outcome data, are there any upper or lower bounds on a program’s cohort size? Is there required reporting of cohort size?
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsBrentFerm I support the NSCPP's recommendations
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsAnnetteStanton I agree with the APCS comment.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsConstanceHammen I support the APCS position.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsChristineMaleckiCouncil of Directors of School Psychology Programs Executive CommitteeThe Council of Directors of School Psychology Programs (CDSPP) Executive Committee finds this IR to be clearly articulated, with one clarification requested. A “component” referenced is “the program’s plans and policies to meet the requirements of the SoA.” Is this accomplished through a narrative discussion of policies and procedures, or does the SoA intend for programs to submit official documents, such as program handbooks?
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsTimothyBrown I endorse the NCSPP reponse for this section of the revised IR.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsMargaretBauer I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsJeffreyGoodie I agree with the CUDCP response
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsMeganO'Banion I support NCSPP's recommendations.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsElizabethMagro I fully support NCSPP's recommendations.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsAmyWilliams I endorse ACCTA's comments
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsCindyYee-Bradbury I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsLindsayStaples I endorse comments made by APCS
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsMarkLumley I agree with the CUDCP response
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsHidekoSeraNCSPPNCSPP appreciates the addition of this category, and has no recommended changes to the IR as proposed.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsMichellePaul I agree with the CUDCP response
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsKathleenSikkema I agree with the CUDCP response
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsCarlaSharp I agree with the CUDCP response
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsCornishJennyAssociation of Psychology Postdoctoral and Internship Centers (APPIC)APPIC supports the Accredited, on Contingency IR for Doctoral Programs. In addition to providing helpful information for the public, this status will provide doctoral programs an opportunity to be site visited before students have completed the program. Contingency status will allow doctoral programs to demonstrate they have a quality program regarding proximal outcomes and will then need to provide distal outcome assessment to help move from contingency to full accreditation. Beginning in 2017 the APPIC internship match will be restricted to students from APA or CPA accredited doctoral programs in health service programs.
Implementing Regulations for Public Comment Phase I"Accredited, on Contingency" IR for Doctoral Programs"Accredited, on Contingency" IR for Doctoral ProgramsBeckyReady I agree with the CUDCP response
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRDeborahBeidelCouncil for University Directors of Clinical Psychology (CUDCP)CUDCP agrees with the language of the IR with the following exception: With respect to the definition of Health Service Provider, we do not believe that the phrase “have current knowledge of accredited training programs in health service psychology” We suggest that all site visitors have to be actively engaged in training of health service psychologists – as a practicum, externship or internship supervisor, for example.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRHidekoSeraNCSPPNCSPP concurs with the proposed language related to Health Service Psychology site visitors, and has no recommended changes. In relation to the Generalist Site Visitors, NCSPP has two significant concerns: (1) The lack of provision for generalists who are primarily engaged in independent practice (as is permitted for HSPs) and (2) The exclusion of faculty from educational programs that are delivered “substantially online.” The former reflects concern that the restriction will unnecessarily constrict this site visitor pool (which arguably already lacks sufficient numbers) and will preclude inclusion of this group’s important insights and perspectives. The latter concern is two-fold: The term “substantially” is ambiguous and, therefore, can be arbitrarily interpreted. Additionally, the exclusion of those who deliver online education unnecessarily precludes the engagement of those with a special expertise in this area, and who can assist in the assessment of the online delivery o... See Full Comment
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRDavidMarcus I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRCrystalCollier I support NCSPP's response.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRMeganO'Banion I support NCSPP's recommendations.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRPauline "Polly"Lytle Typo identified: " Are involved as faculty or training staff in an APA accredited training program, or have an association with an APA accredited training program within the past five year," Should be "five years"
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRMartitaLopez I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRLeeCooper I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRJeffreyGoodie I agree with the CUDCP response
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRNabilEl-GhorouryAPAGSIn terms of the Site Visitor Nomination Implementing Regulations, we feel the eligibility of health service psychology site visitors should not be restricted to individuals from and/or affiliated with an APA-accredited program, but should be inclusive of individuals from and/or affiliated with CPA accredited programs as well (i.e., Canadian Psychological Association). The training standards of APA and CPA accredited programs are considered equivalent by both organization under the First Street Accord (see website: www.apa.org/ed/accreditation/first-street-accord.aspx) and it is unclear to us why the text of this Implementing Regulation does not read “APA or CPA.”
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRSherrylGoodman I fully support the responses submitted by CUDCP and APCS.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRLanceSwenson I agree with the CUDCP response
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRStewartShankman I endorse the comments made by CUDCP and APCS.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRCindyYee-Bradbury I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRLindaCraighead I support the CUDCP and APCS responses
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRGuanKaren I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRBeckyReady I support the APCS comment.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRHannahWilliamson I endorse the APCS comments on this IR.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRKristenJezior I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRLindsayStaples I endorse comments made by APCS
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRMichelleFenesy I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRThomasOltmannson behalf of the Academy of Psychological Clinical Science (APCS)APCS Executive Committee comments: For review of Ph.D. programs, description of the health service psychology site visitor’s background characteristics should mention specifically the person’s recent (past 5 years) knowledge of, and participation in, scientific research related to clinical problems (assessment, treatment, or psychopathology). It is not sufficient to say that the person is “knowledgeable about scientific issues.” APCS also questions whether the role of the generalist site visitor might be reconceptualized as a “specialist consultant” so that only the two health service psychologist team members would need to be at the site visit. It is unclear that there is substantial information gathered in person that addresses issues the generalist is best suited to address (course syllabi and the acquisition of discipline-specific knowledge). Limiting the generalist to provision of a paper review would seem to be adequate. Moreover, unless there is convincing evidence that (1)... See Full Comment
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRAlaynaPark I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRBrianDOnofrio I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRLaurenHarris I endorse comments made by APCS
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRLorettaBraxtonVAPTCVAPTC supports the Site Visitor Nomination IR. Given the shortage of site visitors, perhaps it would be beneficial to more actively encourage nominations through different language usage (e.g., the CoA “encourages”, rather than “invites” nominations or self-nominations…).
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRDanielleKeenan-Miller I endorse the comments made by APCS.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRTrybusRaymond I endorse the comments of NCSPP on this section and all other sections of the proposed IRs. The exclusion of generalists who are especially knowledgeable about online education is particularly regressive and out of step with the realities of the present and future of higher education.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRRobertBarrett I support the comments made by NCSPP
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRdenisechavira I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRDavidSacks I agree with the NCSPP comment on this IR.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRStephenDeMersASPPBD.3-1. Site Visitor Nomination Proposed Draft We would like to strongly suggest that part of the qualifications of all health service psychology site visitors should be licensure. Likewise, we would also like to suggest that one of the criteria be licensure for generalist site visitors who are engaged in applied psychology (e.g. Consultation. I/O) where licensure is available and allowable by law.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRYakushkoOksana - Recent longitudinal data on programs, accredited by the American Psychological Association, show that the doctoral training is becoming “less intellectually diverse” and offers an ever “narrowing” training, leading to “monocultural” approaches, currently represented by the Cognitive-Behavioral (CBT) methods (see Levy & Anderson, 2013 for data and review). New “standards” of accreditation appear to propose to further contribute to this creation of the “monoculture.” Multiple scholars have highlighted that this narrowing of psychotherapy orientations has significant and negative impact on the field (e.g., Heatherington et al., 2012) and contradicts available scientific data that shows that many of the approaches alternative to CBT, are as or more effective (Abbass et al., 2006; Leichsenring & Rabung, 2008; Levy et al., 2013; Shedler, 2010; Wampold et al., 2011; Weisz et al., 2009). This narrowing could not have occurred if it were not explicitly and implicitly supported by the Guidelin... See Full Comment
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRStephanieWood I support NCSPP's recommendations.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRRajaDavid I endorse the NCSPP response for this section.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRAlisaManulkin I endorse the NCSPP response
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRAliciadel Prado I endorse the NCSPP response for all sections.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRAliciadel Prado I endorse the NCSPP response for all sections.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRTorreyWilson I strongly support the NCSPP recommendations.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRHeatherSheets "I endorse the NCSPP response for all sections."
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRAndrewChristensen I endorse comments made by APCS
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRBradRoperSociety for Clinical Neuropsychology (Div. 40), representing 4,330 members“Minimum of 5 years of professional experience”: does that include postdoctoral training experience? If it is post-degree, clarifying that would be helpful.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRAnnetteStanton I endorse the APCS comments.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRConstanceHammen I support the APCS position.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRConstanceHammen I support the APCS position.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRChristineMaleckiCouncil of Directors of School Psychology Programs Executive CommitteeIn terms of point 2 under the requirements for Generalist Site Visitors, the Council of Directors of School Psychology Programs (CDSPP) Executive Committee suggests the requirement that the Generalist be a faculty member in doctoral-level psychology education. As written, the other site visitors must be not only be doctoral -level graduate educators, but also from APA accredited programs. It should be a parallel requirement that Generalists be from doctoral level programs.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRTimothyBrown I support the NCSSP response to this section of the revised IR.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRThomasKubiszynCRSPPPCRSPPP appreciates CoA’s development of the proposed IRs. CRSPPP believes that the proposed IRs provide important specificity and guidance that doctoral, internship and postdoctoral programs need to enhance professional health service psychology training. That guidance should also prove helpful in enabling more focused preparation for the adoption of the SoA in 2016. CRSPPP also recognizes that the proposed IRs, like any attempt to address complex, evolving and important professional training issues, will invariably prove controversial, include unintended consequences, and defy universal approval. Nevertheless, CRSPPP believes that the proposed IRs, once public comments have been considered, will benefit the public and the profession.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRWallaceDixonCouncil of Graduate Departments of Psychology (COGDOP) Regarding Paragraph 1: COGDOP views HSP site visitors and generalist site visitors as not mutually exclusive. Many HSP site visitors, technically defined, may retread or practice as basic scientists, and completely discontinue any formal affiliation with HSP. A site visitor with formal clinical training who longer practices or trains students in practice skills may be well positioned to evaluate science-practice integration and translational aspects of doctoral education, yet as presently defined in the IR, such a person would not qualify for either category of site visitor. That would both reduce the pool of site visitors and remove a valuable source of expertise. COGDOP requests that the clause, “which does not necessarily preclude someone from also being trained in HSP” be appended in the parenthetical note following “generalist site visitors.” COGDOP believes that some of the language about the HSP person is troublesome, specifically the statement that, “if primarily engag... See Full Comment
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRMargaretBauer I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRMargaretBauer I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRMargaretBauer I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRThomasBradbury I endorse the APCS statement.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRKathleenSikkema I agree with the CUDCP response
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRC. PatriciaHanley I strongly support the comments submitted by the Association of Counseling Center Training Agencies (ACCTA).
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRArpanaInmanCCPTPCCPTP supports the site visitor nomination process
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRBrandonGibb I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRAlliAnderson I endorse ACCTA’s response.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRRadhikaKrishnamurthy I endorse NCSPP's response.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRMarkLumley I agree with the CUDCP response
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRKennethAdams This nomination rubric for Health service psychology site visitors seems overly broad; it would be harder to specify who is not covered by these criteria than who is covered. Although I doubt that independent service delivery practitioners will be storming APA to take two days out of their practice often (although some especially dedicated people will, in all probability). I think that the Health service provider site visitors need to have skin in the game in real time. Accreditation has become that corporate. This needs tightening; and there is no shortage of needed site visitors created thereby. Detail" In the 12th line of text, "year" should be "years" Respectfully submitted.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRWilliamStrein Minor clarification point: It would be important to make it clear as to whether eligibility under each of the two categories requires that the individual meets ALL of the bulleted points, or qualifies by meeting ONE (or fewer) of them, i.e., the list is read as "and" vs. "or". I am presuming "and"; one must meet ALL of the criteria. I am concerned about the criteria that a HSP site visitor must be a graduate of an APA-accredited program. Although I personally meet this criterion, it is clear to me that many leaders in HSP or those who may have very substantive experience to bring to being a site visitor may have completed their doctoral degree prior to the time that their doctoral program received APA accreditation. This criterion, if rigidly applied, would rule out such a person permanently. The second criterion, which, as presently worded, may require the CoA to make a professional judgment about the nominee's credentials,assures that the individual is knowledgeable about the SOA ... See Full Comment
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRMichellePaul I agree with the CUDCP response
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRCatherineCostiganClinical Psychology Graduate Program, University of VictoriaThe text specifies that Health Service Psychologist Site Visitors must come from APA accredited programs and be affiliated with an APA program. We suggest that the text "or CPA" follow APA on these implementing regulations. The First Street Accord, formalized in 2012, recognizes the equivalence of APA and CPA accredited training (http://www.apa.org/ed/accreditation/first-street-accord.aspx). Thus, graduates of CPA-accredited doctoral programs are competent to serve as site visitors for APA accreditation. There are many U.S. citizens in CPA-accredited doctoral programs, and many of these students return to the U.S. for their professional careers. The addition of "or CPA" to the text will add many competent health service psychologists to the pool of site visitors and provide these individuals the opportunity to give back to the community of psychology training programs.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRCornishJennyAssociation of Psychology Postdoctoral and Internship Centers (APPIC)APPIC generally supports the proposed revisions to the Site Visitor Nomination IR. However, we have some concerns with how “current knowledge of accredited training programs in health service psychology” would be determined for psychologists primarily engaged in private practice. For instance, some of our consortium internship programs have had difficulties when independent practices are included as training sites, and we question whether site visitors from such settings would be truly qualified to serve the CoA. It would be important that site visitors have some experience in education and training and to have at least be affiliated with an accredited program at one time.
Implementing Regulations for Public Comment Phase ISite Visitor Nomination IRSite Visitor Nomination IRBeckyReady I agree with the CUDCP response
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRDavidMarcus I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRDavidMarcus I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRMeganO'Banion I support NCSPP's recommendations.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRMartitaLopez I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRCrystalCollier I support NCSPP's response.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRLeeCooper I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRJeffreyGoodie I agree with the CUDCP response
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRLanceSwenson I agree with the CUDCP response
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRStewartShankman I endorse the comments made by CUDCP and APCS.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRHannahWilliamson I endorse the APCS comments on this IR.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRCindyYee-Bradbury I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRTonyCellucciAPTCAPTC reviewed the site visitor nomination and selection criteria and procedures which seem reasonable and appropriate; the new selection procedure should make the process more efficient. It is also appropriate that CoA have a greater role in their selection and this will also reduce the burden on programs to find site visitors. We would point out that Clinic Directors are an excellent position to serve as health service psychology site visitors in that they are familiar with training programs and standards and also are engaged in ongoing supervision and service delivery.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRLindaCraighead I support the CUDCP and APCS responses
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRGuanKaren I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRBeckyReady I support the APCS comment.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRLindsayStaples I endorse comments made by APCS
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRMichelleFenesy I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRKimberlyHays I would hope that a Chair be able to decline a site visit opportunity even if they are generally available at a specific time or review cycle. It sounds as though you could be assigned to anything if you are free during a specific cycle and that may not be workable for some, unless I am misreading this.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRThomasOltmannson behalf of the Academy of Psychological Clinical Science (APCS)Comments from the APCS Executive Committee: When a clinical science program is being reviewed, APCS feels strongly that both HSP members of the site visit team must be faculty members from other programs that have specifically adopted the clinical science training model. It is fine to have the Commission appoint the Chair of the team, but the success of this process will depend on the ability and willingness of the Commission to match carefully appropriate site visitors with clinical science programs.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRAlaynaPark I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRBrianDOnofrio I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRLaurenHarris I endorse comments made by APCS
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRKristenJezior I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRMaureenO'Hara In view of the importance of the role of the site visitors schools need to be assured that the team have the necessary experience in both pedagogical diversity (how the programs are delivered and this is assessed for quality of outcomes, and 2, the content and methodological diversity that is represented by the wide variety of psychology programs currently available and likely to be in the future. I suggest some language be inserted for item 4 that reflects the need to have at least one site visitor who is familiar with mission specific program elements such as cultural and religious diversity or focus on a wider range of qualitative science methods.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRRobertBarrett I support the comments made by NCSPP
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRDanielleKeenan-Miller I endorse the comments made by APCS.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRAnnaLau I endorse the comments of APCS
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRdenisechavira I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRStephenDeMersASPPBASPPB supports the requirement that CoA select the Chair of the site visitor team for doctoral programs. We feel this requirement adds to consumer protection. We also support the requirement that one of the site visitors be involved in education and one be involved in practice. We also strongly suggest that one of the criteria be licensure for both of these categories if the education or practice that they are involved in is related to health service provision or general applied services. ASPPB endorses the concept that those who supervise any health service provision or general applied services should themselves be licensed.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRLorettaBraxtonVAPTCThe VAPTC supports the proposed changes in the Site Visit Selection IR and appreciates the Commission’s efforts. A number of concerns are addressed if the Commission appoints the Chair of the site visit team and the program selects the second team member. These changes will have a positive impact by reducing programs’ burden in scheduling a full team, allowing programs to focus on identifying a second team member knowledgeable about the specific program type, and increasing the likelihood of unbiased peer review. We also welcome that team members will be notified in advance that their names will be included on a list as potential site visitors. This IR represents a much needed improvement.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRRajaDavid I endorse the NCSPP response for this section.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRAlisaManulkin I endorse the NCSPP response
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRAliciadel Prado I endorse the NCSPP response for all sections.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRTorreyWilson I strongly support the NCSPP recommendations.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRTorreyWilson I strongly support the NCSPP recommendations.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRHeatherSheets "I endorse the NCSPP response for all sections."
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRHeatherSheets "I endorse the NCSPP response for all sections."
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRAndrewChristensen I endorse comments made by APCS
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRAnnetteStanton I endorse the APCS comments.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRChristineMaleckiCouncil of Directors of School Psychology Programs Executive CommitteeAs written, it does not appear to the Council Of Directors Of School Psychology Programs (CDSPP) Executive Committee that the selected Chair will be asked by the CoA if potential bias/conflict exists prior to appointment to lead a site visit. At what point in the process would a Chair communicate to the CoA that he/she believes a potential bias/conflict is present? The Program is responsible for notifying the CoA if perceived bias/conflict is present. Will examples of bias/conflict accompany this IR? Who determines if an actual conflict exists? A CoA staff-member? The CoA itself?
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRTimothyBrown I support the NCSPP response to this section of the revised IR.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRThomasKubiszynCRSPPPCRSPPP appreciates CoA’s development of the proposed IRs. CRSPPP believes that the proposed IRs provide important specificity and guidance that doctoral, internship and postdoctoral programs need to enhance professional health service psychology training. That guidance should also prove helpful in enabling more focused preparation for the adoption of the SoA in 2016. CRSPPP also recognizes that the proposed IRs, like any attempt to address complex, evolving and important professional training issues, will invariably prove controversial, include unintended consequences, and defy universal approval. Nevertheless, CRSPPP believes that the proposed IRs, once public comments have been considered, will benefit the public and the profession.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRThomasBradbury I endorse the APCS statement.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRWallaceDixonCouncil of Graduate Departments of Psychology (COGDOP) COGDOP notes that the IR is not explicit as to how CoA staff will translate a program’s goals and objectives into a decision process for selecting a site-visit chair and assembling a slate of potential additional members. If, for example, a program specifies 15 training goals, what proportion of these will be matched as CoA selects a chair that accords with the “training aims” of the program? In Item 1 under the subheading, “Composition of site visit teams,” does the CoA include supervision and consultation as “psychological services?” Faculty who provide clinical supervision have the same skill, professional, legal, and ethical responsibilities and liabilities as a direct service provider. Furthermore, failing to do so would restrict the reviewer pool because many faculty in accredited programs do not engage in the delivery of other forms of psychological services despite the fact that they maintain licensure and provide professional supervision or consultation. This may be men... See Full Comment
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRJulieCorkery I endorse ACCTA's response.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRChristinaCarroll-Pavia I endorse ACCTA’s response.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRKathleenSikkema I agree with the CUDCP response
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRC. PatriciaHanley I strongly support the comments submitted by the Association of Counseling Center Training Agencies (ACCTA).
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRLindaScott I am agreement with ACCTA's recommendations.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRArpanaInmanCCPTPCCPTP supports the site visitor selection process
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRAmyWilliams I endorse ACCTA's comments
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRDeborahBeidelCouncil for University Directors of Clinical Psychology (CUDCP)CUDCP also believes that CoA should appoint the generalist as well as the Chair, leaving the program to select its “second” team member from a list of 5 appropriate visitors provided by the CoA.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRBrandonGibb I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRAlliAnderson I endorse ACCTA’s response.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRMarkLumley I agree with the CUDCP response
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRWilliamStrein Excellent - and long overdue! Benchmarked against accreditation or program approval by other accrediting bodies recognized by the Dept. of Ed. or CHEA, it is indefensible, on its surface, that psychology programs get to select their own site visitors. If anything, this IR is not bold enough. The Commission should, ideally, select all of the site visitors, absent, of course, legitimate evidence of conflict of interest or bias. However, given our history and our previous failed attempts to move forward this change, the proposed IR is likely as good a one can hope for at this point.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRKarenLese-FowlerAssociation of Counseling Center Training Agencies (ACCTA)The Association of Counseling Center Training Agencies, an organization of 178 doctoral internships the vast majority of whom are either accredited or seeking accreditation, believes that the proposed changes to the site visitor selection will likely facilitate unbiased peer review. We appreciate the Commission’s efforts in selecting a Chair and list of potential site visitors with availability during the review cycle. As a practical matter, given that scheduling a site visit requires balancing many schedules including those of institutional heads, we encourage the selection of appointed chairs and potential second (or third) members with as wide a range of availability within the relevant review cycle as possible.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRHidekoSeraNCSPPNCSPP has no recommended changes to the IR as proposed.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRMichellePaul I agree with the CUDCP response
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRHeatherNoble I endorse ACCTA’s response.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRDeborahBeidelCouncil for University Directors of Clinical Psychology (CUDCP)CUDCP is concerned that the site visitor selection does not pay specific attention to the research dimension of PhD training. There is no guarantee that one of the site visitors will be actively involved in clinical research (broadly construed to be research in the areas of psychopathology, assessment or treatment). We believe that the “practice perspective” site visitor must be broadly construed to include clinical research. There are many individuals who are actively engaged in clinical research and who supervise their students in the provision of doctoral services, even if they themselves do not specifically provide clinical services. We offer the following revision for the final two sentences for #1. under the subheading Composition of the site visit teams: (addition in bold, deletion in strikeout) “The designated educator will be a psychologist who regularly engages within his/her professional role in teaching, and, training, and research, in psychology. The designate... See Full Comment
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRCornishJennyAssociation of Psychology Postdoctoral and Internship Centers (APPIC)APPIC supports the Site Visitor Selection IR. This is an important change to the profession. Site Visitors should not be selected based on friendship. The proposal to allow APA to select the chair of the site visit team and then allow the program to choose from names submitted by APA seems fair and reasonable. This will also relieve some of the burden that has been placed on a site to find someone free and willing to travel to their site. APA should choose the site visit chair and then the program can focus on finding the remaining site visitor(s) from the list provided by APA. This approach is more consistent with other accrediting bodies.
Implementing Regulations for Public Comment Phase ISite Visitor Selection IRSite Visitor Selection IRBeckyReady I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRBrandonGibb I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRHidekoSeraNCSPPNCSPP would like to reiterate concerns raised during the public comment period related to the Standards on Accreditation, and strongly recommend that the Standard II.B.3.d be changed as follows: “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., analytic) or contextual (e.g., forensic) reasons, would not allow such observation. The use of “at least one” also prevents a disparity that potentially disadvantages programs that require more practica. Additionally, this revision ensures measurement of competency via direct observation without eliminating valuable sites from engagement in practicum training. NCSPP likewise recommends that Section II.D.1.a.iv and Standard II.D.... See Full Comment
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRAnnemarieSlobig I endorse NCSPP's comments.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRMeganO'Banion I appreciate this addition while also supporting the specific comments and suggestions submitted by NCSPP, APPIC and CUDCP. I would also strongly encourage CoA to review the IR and modify the language to ensure inclusivity rather than inadvertent discrimination.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRMartitaLopez I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRCrystalCollier I support NCSPP's response.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRPauline "Polly"Lytle I think this proposal is an excellent addition. However, as a doctoral faculty member who does practicum site visits annually, I recognize that it may take some time and education for the directors of training to get full cooperation and compliance from all practicum sites. We already have some sites that are not comfortable with audiorecordings!
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRLeeCooper I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRArpanaInmanCCPTPCCPTP had several concerns re: this IR. Is there any evidence that suggests that “visual” (live, streaming or video recording) direct observation is more beneficial or superior to audio recording alone. Moreover, several of our practicum sites do not allow video recording (domestic violence agencies, Indian Health, etc.) There is also difficulty ensuring live observations (given the many limitations/restriction of off-campus sites). There is also concerned about this requirement in terms of working with clients who are hesitant to be recorded. Often clients are far less reticent to submit to audio recording. Related to this, for programs that use external sites (outside of a training clinic) and provide supervision to students at those external sites, it seems near impossible to comply both with the requirement of video or live supervision and the requirement to follow laws and standards regarding confidentiality and security. Is there really a level of security that is high enough for... See Full Comment
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRLaurenNichols I support NCSPP's recommendations.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRDavidMarcus I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRJeffreyGoodie I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRSherrylGoodman I fully support the responses submitted by CUDCP and APCS.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRLanceSwenson I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRHannahWilliamson I endorse the APCS comments on this IR.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRTonyCellucciAPTCTraining Clinics routinely provide direct observation in the training and evaluation of professional competencies. APTC strongly supports adding this requirement for all practica sites although we recognize many sites currently do not use direct observation. This may encourage those which do more training and ongoing professional development to add necessary infrastructure. It may also encourage more research on the advantages/superiority of video over audio for supervisee observation.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRJamesLichtenberg I realize that there may be sometimes significant issues with IMPLEMENTING the "direct observation" with some sites, but I think the integrity of our graduate training programs requires direct observation on at least a periodic basis throughout students' graduate training. Although I am addressing specifically DOCTORAL program trainig, I believe that this is true also for internships and post-docs. Relying on student clinicians' narratives of what went on in their therapy with clients (their own actions, the clients' responses) just can't cut it. For all the advancements in technology that could so help in training and supervision--from early "wire recorder," to reel-to-reel and cassette recorders, to digital video recorders, and the recording systems that have been developed for these purposes, it is disheartening to think that the profession would sanction as a good quality program, one in which faculty/supervisors may have no directed observational knowledge of just what their tra... See Full Comment
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRGuanKaren I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRBeckyReady I support the APCS comment.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRCindyYee-Bradbury I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRLindsayStaples I endorse comments made by APCS
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRMichelleFenesy I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRSalinaRenninger This IR fails to identify who needs to do the direct observation. Will it be sufficient for the site to provide direct observation (and complete an evaluation) or will the doctoral program also need to provide direct observation and evaluation? It may be challenging for doctoral programs to do this if: 1) the site does not allow recordings to be made; or 2) the site does not allow recordings to be taken off site. These two situations are not uncommon. It would be a shame if sites had to be removed because of this IR. Additionally, the IR indicates that recordings must comply with appropriate regulations, laws, and professional standards with regard to confidentiality and security. This is extremely challenging to do as the technological landscape is ever-changing. It would very helpful if "standard practices and recommendations" were provided on how best to stay in compliance with the regulations. Tech support within institutions of higher education are not well equipped to d... See Full Comment
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRAlaynaPark I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRThomasOltmannson behalf of the Academy of Psychological Clinical Science (APCS)Comments from the APCS Executive Committee: APCS applauds in principle the emphasis on direct observation, which is likely to improve the level of supervision. High-quality supervision is particularly important in the first two years of practicum and might even need to be specified at a particular level. Clinical science programs generally provide high levels of direct observation and would not have a problem with this requirement. At the same time, APCS has concerns about this IR. First, requiring each separate placement to have direct observation might inadvertently force programs to drop unique or novel training sites where such observation is not possible (e.g., a home visiting intervention or hospital setting). Second, the IR states that “audio recording alone is not sufficient to meet the requirements of direct observation.” For some and perhaps even many programs, external training sites are located in community mental health centers. Although these sites can and do provid... See Full Comment
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRBrianDOnofrio I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRLaurenHarris I endorse comments made by APCS
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRKristenJezior I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRDanielleKeenan-Miller I endorse the comments made by APCS. I am particularly concerned about the impact that strict requirements for live or video observation in each practicum would have on the opportunity for our students to train with high-need and vulnerable populations where recordings may not be financially feasible, allowable by IRB, or tolerable to clients. However, I would support the requirement that all students obtain supervision that has live or recorded observation at some point or points in their training and that these methods of supervision be used when feasible.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRAnnaLau I endorse the comments of APCS
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRAliciadel Prado I endorse the NCSPP response for all sections.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRdenisechavira I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRRobertBarrett I support the comments made by NCSPP.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRElizabethDalton I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRStephenDeMersASPPBASPPB supports the requirement that there be direct observation of a trainee’s work for each practicum and each internship rotation. The definition of direct observation (live, streaming, video recording) seems clear to us. You have also proposed that programs must verify that this observation occurs. It would be helpful to licensing boards if there could be a standardized manner in which this verification takes place and we would be glad to collaborate with you on this.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRYakushkoOksana This proposed regulation must be examined in light of what types of sites and students it privileges. Specifically, sites that serve traditionally underserved communities, sites that do not have funds for two-way mirrors or electronic recording (and in many cases, where such recordings would be contraindicated for the well being of clients from diverse communities), would be excluded and thus, students will be asked to maintain their training in sites that serve privileged and monocultural communities. Lastly, this IR is most likely to result in further narrowing of practicum and internship training sites rather than inviting programs to expand their work in multiple settings and diverse communities, resulting in further diminished number of training spots.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRStephanieWood I support NCSPP's recommendations.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRLorettaBraxtonVAPTCVAPTC supports the direct observation IR. However, we request that two issues be clarified. First, in what training rotations would adherence to this IR not be expected? For example, how would direct observation be expected or defined when a fellow is completing either a research or program development elective? Second, given that live observation is defined visually (e.g., videotaped, streamed, in-room), we would request that an exception or accommodation for visually impaired supervisors be clearly described (e.g., in these cases audiotaping would suffice and/or a secondary supervisor could complete the direct observation in collaboration with the visually impaired supervisor).
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRRajaDavid I endorse the NCSPP response for this section.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRAlisaManulkin I endorse the NCSPP response
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRLaurenBerkovits I endorse comments made by APCS on this IR.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRHeatherSheets "I endorse the NCSPP response for all sections."
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRTimothyBrown I endorse the NCSPP response to this section of the revised IR. I particularly share the concern expressed in a number of comments that the revision as proposed would limit our practicum students' access to training in settings in which they could work with underserved populations.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRAndrewChristensen I endorse comments made by APCS
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRRodGoodyear The CoA is to be commended for proposing the requirement that the clinical work of students, interns, and postdoctoral residents be directly oberved. This constitutes best practice in terms both of ensuring quality of care and for providing the clear and specific feedback that is so essential to fostering supervisee’s development. It also is consistent with APA’s supervision guidelines (see January’s American Psychologist).
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRAnnetteStanton I endorse the APCS comments.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRConstanceHammen I support the APCS position.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRChristineMaleckiCouncil of Directors of School Psychology Programs Executive CommitteeThe Council Of Directors Of School Psychology Programs (CDSPP) Executive Committee cannot identify within the IR the role of the professional who may conduct the direct observations. If direct observations can be conducted by, for example, a faculty-member or a field-based supervisor, stating this would add further clarity to the IR.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRThomasKubiszynCRSPPPCRSPPP appreciates CoA’s development of the proposed IRs. CRSPPP believes that the proposed IRs provide important specificity and guidance that doctoral, internship and postdoctoral programs need to enhance professional health service psychology training. That guidance should also prove helpful in enabling more focused preparation for the adoption of the SoA in 2016. CRSPPP also recognizes that the proposed IRs, like any attempt to address complex, evolving and important professional training issues, will invariably prove controversial, include unintended consequences, and defy universal approval. Nevertheless, CRSPPP believes that the proposed IRs, once public comments have been considered, will benefit the public and the profession.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRMargaretBauer I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRMargaretBauer I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRThomasBradbury I support the APCS statement.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRWallaceDixonCouncil of Graduate Departments of Psychology (COGDOP) COGDOP believes that the meaning of the term “direct observation” is not defined. Is live, onsite, through-the-glass observation the only venue that counts as direct observation? Would live but physically remote observation via video+audio or via audio-only count? Would watching a videotape or listening to an audiotape count? All of these are clearly a type of observation, distinct from relying a trainee’s report about a session. Yet even a typical supervision session is a type of “direct observation” (of the trainee). The term “direct” needs explanation. This is particularly important as the field grapples with telehealth and delivery of services in rural communities. COGDOP believes that the requirement should be flexible, in part because some types of training in service delivery occur in nontraditional settings where “direct observation” in a very narrow sense would be disruptive or infeasible. COGDOP questions the appropriateness of the term “accurate,” because as used in th... See Full Comment
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRKarenLese-FowlerAssociation of Counseling Center Training Agencies (ACCTA)Standard II.D.1.a.v. ? Given that “best practices in intern competencies evaluation” is a broad term that may be easily misunderstood, ACCTA urges the CoA to offer more clarity as to how they are defining their expectations in this area.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRC. PatriciaHanley I strongly support the comments submitted by the Association of Counseling Center Training Agencies (ACCTA).
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRChristinaCarroll-Pavia I endorse ACCTA’s response.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRRadhikaKrishnamurthy I support NCSPP's recommendations.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRKathleenSikkema I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRJulieCorkery I support the inclusion of audio recording as a means of direct observation.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRRonPilato I endorse NCSPP's response on all proposed IRs.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRAmyWilliams I support ACCTA's comments
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRCornishJennyAssociation of Psychology Postdoctoral and Internship Centers (APPIC)APPIC supports the Direct Observation IR but proposes that accommodations be made for visually impaired supervisors to allow a different faculty member to observe and report to a DCT or TD with a visual impairment that does not allow direct observation.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRCarlaSharp I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRDeborahBeidelCouncil for University Directors of Clinical Psychology (CUDCP)CUDCP agrees with the language of this IR but notes that there still is no exception made in the case where a supervisor may be visually impaired.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRAlliAnderson I endorse ACCTA’s response.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRMarkLumley I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRGeneCarroccia Regarding the statement under the Internship section within Definitions and Guidelines for the Direct Observation IR, it would be helpful to clarify how many live observations will be required for each internship evaluation period. A sentence in this section says "Each of these written evaluations must be based in part on an instance of direct observation." Does this mean that there is a minimum of only one direct observation per each written internship evaluation period? Additionally, under the Internships section, standard II.D1.a.v. states "the data should reflect assessment that is consistent with best practices in intern competencies evaluation." It may be helpful to explain more about what is expected with "best practices" for intern competencies evaluation. Perhaps this could be further discussed or addressed in the Definitions and Guidelines section.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRJonathanKrejci The requirement that direct observation include live or video recording is onerous for programs that do not have the often expensive equipment required to do this effectively. Lacking that equipment, it is also intrusive for clients, especially in the context of individual therapy. I recommend that audio recordings be sufficient to comply with this requirement.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRanafaraci I would like to know if the "direct observation" supervision will count towards the required hours of supervision? Currently the hours of internship supervision are defined either as individual or group. Additionally, some internship programs involve other licensed mental health professionals who work directly with the students/interns in clinical meetings, staffings, etc. Could their "direct observation" count towards the fulfillment of this requirement? This new requirement would entail additional supervisor time; therefore the involvement of other mental health professionals in the evaluation of trainees might play a vital role in this process.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRLindaScott I am in support of ACCTA s recommendations.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRMyrna (Micki)Friedlander I'm in agreement with previous comments about the potential burden on practicum supervisors in the field needing to observe students live or by video. Most agencies/hospitals do not have video recording capabilities. If live observation could be limited to sitting in on one session with an individual client, that might be possible although intrusive for the client. It seems that ongoing audio recording of sessions (with review in the context of supervision) could be sufficient.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRKarenLese-FowlerAssociation of Counseling Center Training Agencies (ACCTA)Standard II.D.1.a.iv. ? ACCTA agrees that observation of a trainee’s actual performance is the ideal method of supervisory oversight. Even so, it may be more difficult to achieve direct observation of some competency areas. For example, in some settings consultation may take place on a one time basis and/or on the telephone, making it more difficult to arrange for recording or direct observation.) Given the need to balance appropriate oversight with budgetary and technological limitations at some training sites, ACCTA suggests that the requirement for direct observation should include audio recording technology as a method of direct observation as well.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRMichellePaul I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRMichellePaul I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRMichellePaul I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRBrooksMorse I support ACCTA comments
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRStewartShankman I endorse the comments made by CUDCP and APCS.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRYangJanet I think the inclusion of some direct review of the interns' work is an excellent addition. However, the requirement that this review be live, streaming or by video would be overly burdensome for many internships, including one like ours in a community mental health center. If the use of audio recordings were sufficient for this criteria, that would be very doable.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRVarelaJorge Let me begin by thanking CoA for all their efforts on behalf of our profession. Developing all these guidelines cannot be an easy task. I would like to comment regarding the Direct Observation IR (p. 10). I am a DCT and am heavily involved and invested in clinical supervision. My read of the proposed IR is that supervision requires direct observation (e.g., in person, through a one-way glass, video recording). The problem I see with this IR is that it seems to preclude someone who is visually or hearing impaired from providing supervision. I do not believe it is CoA's or APA's intent to exclude our colleagues who cannot "observe" in the manner described from providing supervision. IN our program, for example, we have an OUTSTANDING psychologist faculty member whose supervision is of great value to our doctoral students. I would strongly encourage CoA to review the IR and change the language so as to ensure we are not inadvertently discriminating against a subgroup of our co... See Full Comment
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRHeatherNoble I endorse ACCTA’s response.
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRLotteSmith-Hansen I have a comment on the requirement for direct observation as it relates to practicum training. My comment is inspired by a meeting I was in this morning with the Training Committee of the Massachusetts Psychological Association where we discussed the IRs as they relate to practicum training (though I speak only for myself here). I strongly support the requirement for direct observation of students, and agree with the IR language related to observation. As a supervisor, I know how important it is to have direct access to students' work. Still, I hope that CoA will not specify further details in the IRs, for two reasons. First, many practicum sites are already overburdened with requirements. In Massachusetts, doctoral students may now use hours from advanced practicum toward licensure as a psychologist, if the practicum experience meets certain criteria, so practicum sites are feeling burdened by the new requirements for supervision, didactics, etc., and by the requirem... See Full Comment
Implementing Regulations for Public Comment Phase IDirect Observation IRDirect Observation IRBeckyReady I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRStewartShankman It is a great change that this IR has a more enhanced and more detailed description of Research Methods, Quantitative Methods, and Psychometrics. I think this will ensure a more appropriate (read higher) threshold that programs must adhere to for these critical areas of training.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRDeborahBeidelCouncil for University Directors of Clinical Psychology (CUDCP)CUDCP agrees with the language for the first category of discipline-specific knowledge. We applaud the enhanced and detailed description of Research Methods, Quantitative Methods, and Psychometrics than what was previously listed in the previous IRs. We believed that this will provide a more appropriate threshold for this critical areas of training. CUDCP believes that the language for the second category of discipline specific knowledge is too broad (see language below), leading to multiple interpretation and confusion by programs regarding the “acceptability” of particular training activities, e.g., “can one course provide advanced integrative knowledge for two areas?” We note that the definition of: “Advanced Integrative Knowledge of Discipline-Specific Content Areas, includes in-depth graduate-level understanding and competence that entails integration of multiple basic discipline-specific content areas (vis., affective, biological, cognitive, social, and developmental aspe... See Full Comment
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRRadhikaKrishnamurthy I strongly support NCSPP's recommendation to maintain a single standard for graduate-level knowledge acquisition across programs.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRBrandonGibb I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRHidekoSeraNCSPPNCSPP appreciates CoA’s detailed description of expectations for discipline-specific knowledge. However, NCSPP also suggests that some of the language related to the demonstration of discipline-specific knowledge is ambiguous, and potentially places a higher burden on students who demonstrate a foundational knowledge base, for whom the program must build upon this foundation knowledge and require “additional coursework in advanced topics.” Although NCSPP appreciates allowing programs to exercise discretion in determining the appropriate means of supporting core competency development, we suggest that the delineation as proposed is unnecessary and potentially uneven. Instead, NCSPP proposes eliminating subsections i and ii of this section and modestly amending section (a) to read as follows: a)…represents the requisite knowledge of psychology an individual must have to attain the profession-wide competencies. The Program must describe how its curriculum enables students to demons... See Full Comment
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRMeganO'Banion I support NCSPP's response.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRBethanyTeachman I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRHidekoSeraNCSPPNCSPP applauds CoA for supporting a competency-based approach to education and training, and appreciates the detailed and developmentally-sensitive operational definitions offered for each content area. NCSPP is concerned, however, that several sections as currently written can be narrowly interpreted and/or misinterpreted, and result in an unintended disadvantage to certain programs, particularly Psy.D. programs. To avoid such a circumstance, NCSPP recommends the following modifications to the proposed text: Under In-depth graduate-level understanding and competence: NCSPP recommends modifying the sentence: “The CoA will look for certain pieces of evidence in evaluating graduate level, including students’ exposure to a curriculum plan that utilizes primary source materials (including original empirical work that represents the current state of the area” to read “The CoA will look for evidence in evaluating graduate level, including students’ exposure to a curriculum plan t... See Full Comment
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRMichellePaul I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRMartitaLopez I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRCrystalCollier I support NCSPP's response.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRLeeCooper I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRArpanaInmanCCPTPWhile there may be some value in allowing the use of undergraduate courses/knowledge it is unclear as to how the quality of the course can be assessed. A suggestion here is for SoA to come up with guidelines for how to assess this knowledge. On the other hand, an added concern is if programs move to allow this as a way to demonstrate achievement of competence they may not offer a course option (because courses typically must have a certain enrollment for university administrators to be willing to list them or for individuals to get credit for teaching them). If programs adopt this and a particular state does not make the change in recognizing the selective admission approach then will it restrict licensure of graduates? This is really a question of whether ASPPB can document that all the states will "get on board" with this. RE: the use of GRE’s: Is it possible that use of test scores will decrease the diversity of enrollment of students? Do we know for sure that the GRE subject test ... See Full Comment
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRLaurenNichols I support NCSPP's recommendations.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRDavidMarcus I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRKathleenSikkema I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRLanceSwenson I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRNabilEl-GhorouryAPAGSFor Discipline-Specific Knowledge, we value the flexibility in how programs can assess requisite knowledge, by which the Implementing Regulations provide the GRE subject test as an example of standardized assessment, but do not require its use. Further, we agree with the areas of competence outlined in the Implementing Regulations, and appreciate that competence in these areas can be achieved through exposure across many courses, rather than requiring a quota of courses in a specific area.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRHannahWilliamson I endorse the APCS comments on this IR.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRTonyCellucciAPTCThis new IR affirms the importance of broad discipline-specific knowledge as the foundation of practice but allows greater flexibility for programs in ensuring foundational knowledge including requiring prerequisite undergraduate courses and standardized assessments. APTC see this as beneficial in that it recognizes the importance of undergraduate preparation in psychology and will allow more time for other academic, clinical or research experiences. On the bottom of page 14, the IR spells out a requirement for Advanced Integrative Knowledge of Discipline –Specific Content Areas. It is suggested that a range of possible examples of how programs might ensure this advanced knowledge might be provided for greater clarity.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRStewartShankman I endorse the comments made by CUDCP and APCS.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRLilyBrown I endorse the comments made by APCS.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRLindaCraighead I support the CUDCP and APCS responses
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRGuanKaren I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRBeckyReady I support the APCS comments.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRCindyYee-Bradbury I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRLindsayStaples I endorse comments made by APCS
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRMichelleFenesy I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRCarolynDavies I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRMichaelSipiora I strongly agree with Churchill's comments.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRAlaynaPark I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRThomasOltmannson behalf of the Academy of Psychological Clinical Science (APCS)Comments from the APCS Executive Committee: With regard to the first category of DSK – that is, knowledge that can be acquired at either the upper-undergraduate or entry graduate level – APCS sees great value in relying upon “standardized assessments of a foundational knowledge base (e.g., GRE subject tests)” for meeting this IR. With properly constructed tests, students who pass the GRE subject tests with a sufficiently high score should be viewed as having achieved sufficient mastery in the basic content domains for entry into graduate school, much like the MCAT does for medical school. With this mastery in place and documented, graduate students will then be able to build upon that foundation of basic knowledge in psychology, using advanced coursework, supervised clinical work, and research training without back-tracking to address those domains unless he or she is clearly deficient on the standardized assessment. At the same time, however, even with these student selection ... See Full Comment
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRBrianDOnofrio I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRLaurenHarris I endorse comments made by APCS
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRYakushkoOksana This comment seeks to address issues of what are considered "discipline-wide" competencies and how diversity of orientations, worldviews, and cultural perspectives do not appear to be represented or adequately safeguarded under past or proposed standards and regulations on accreditation. Recent longitudinal data on programs, accredited by the American Psychological Association, show that the doctoral training has become “less intellectually diverse” and offers an ever “narrowing” training, leading to “monocultural” approaches, currently represented by the Cognitive-Behavioral (CBT) methods (see Levy & Anderson, 2013 for data and review). New standards on accreditation appear to propose to further contribute to this creation of the “monoculture.” NO efforts are made to safeguard that programs ensure that multiple perspectives are represented. Moreover, multiple scholars have highlighted that this narrowing of psychotherapy and theoretical orientations has significant and negative imp... See Full Comment
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRScottChurchill Under "The second category of discipline-specific knowledge..." there are four bullet points, *each* of which presumably describes an area of discipline-specific knowledge in which a graduate student must demonstrate "understanding and competence." Under the first bullet point "Research Methods" there is a list of methods, techniques, designs that apparently need not *all* be represented in a grad student's education; rather, *some* of those listed would appear to be adequate - thereby potentially leaving completely out of a grad student's education exposure to *any* of those methods, techniques, designs. However, this general category which "includes" the list of possibilities, is then followed by separate bullet points - Quantitative Methods and Psychometrics - which were already included in the general bullet point, but now are being singled out for elaboration -- and also singled out as among those four "points" that "must" be included in every graduate student's education.... See Full Comment
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRKristenJezior I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRDanielleKeenan-Miller I endorse the comments made by APCS.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRAnnaLau I endorse the comments made by APCS. The current coursework requirements for students in our Clinical Science program in no way contribute to their preparation for the integration of science and practice in Clinical psychology. They are a source of considerable stress and burden in what is becoming a more and more onerous course of study, which little value for learning.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRBrentRobbins At the doctoral level, training in research should include both quantitative and qualitative methods of inquiry.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRBrentRobbins Division 5 of APA is the Division dedicated to research in psychology, and is now named the Division of "Quantitative and Qualitative Methods." This Division has peer-reviewed journals that include a journal, Qualitative Psychology, dedicated to qualitative research in psychology. To emphasize quantitative research but to exclude emphasis on qualitative methods is a form of epistemological prejudice that narrows the range of legitimate, scientific inquiry necessary for our field to remain at the cutting edge of psychological inquiry. Thus, training in accredited programs must require training in BOTH qualitative AND quantitative methodologies. If both are not required, then another option, far less optimal though it may be, would be to give programs the option of emphasizing EITHER quantitative OR quantitative methods. Again, to emphasize the requirement of the former (quantitative methods), but not the latter (qualitative methods), is a form of epistemological narrow-mindedness that f... See Full Comment
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRBrentRobbins Advanced integrative knowledge should ideally include integration of not only models, but also major theoretical systems of psychology. Students should learn the deep, philosophical roots of the models, theories, and methodologies used in various competing paradigms of the field. Comparing, contrasting, integrating, and critically evaluating theories should not be relegated to history classes, but should also be an active part of training in most if not all classes.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRdenisechavira I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRDavidSacks I endorse the NCSPP response to this IR.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRElizabethDalton I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRStephanieWood I support NCSPP's recommendations.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRRobertBarrett I support the comments made by NCSPP
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRStephenDeMersASPPBYou are proposing a substantial change in how students can demonstrate that they have acquired requisite knowledge. While we (ASPPB) understand and in theory support the concept that advanced undergraduate coursework may be substantially equivalent to entry level graduate coursework in some basic areas, licensing boards have not traditionally allowed for undergraduate coursework to be accepted. We are concerned that a student could graduate from an APA accredited program but not be license eligible in some states if they cannot clearly demonstrate graduate level coursework in core areas. Many state licensing boards may not accept an equivalent undergraduate course for a graduate level course unless a transcript clearly states the course is accepted and meets criteria for graduate level work. We are also concerned that if someone is license eligible in a state when they have met a graduate core requirement with an undergraduate course, there still may be a negative impact on the mobilit... See Full Comment
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRLorettaBraxtonVAPTCVAPTC is in support of the discipline specific knowledge IR. VAPTC requests clarification regarding whether this IR is fully the responsibility of the graduate programs or if it also applies to the doctoral internship and postdoctoral residency programs.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRRajaDavid I endorse the NCSPP response for this section.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRAliciadel Prado I endorse the NCSPP response for all sections.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRLaurenBerkovits I endorse comments made by APCS on this IR.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRDianeBlau It concerns me that Quantitative Methods have a separate listing but qualitative methods are included only within the category of Research Methods. I believe each need a separate listing and are of equal importance. The fact that they do not, furthers a perceived bias of APA toward quantitative research and the sole use of quantitative methodology as valid evidence based data.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRTorreyWilson I strongly support the NCSPP recommendations.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRHeatherSheets "I endorse the NCSPP response for all sections."
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRTimothyBrown I endorse the NCSPP response to this section of the revised IR.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRAndrewChristensen I endorse comments made by APCS
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRWallaceDixonCouncil of Graduate Departments of Psychology (COGDOP) COGDOP is very much in support of the spirit of the change from traditional “Broad and General” coverage to the new “Discipline Specific Knowledge” coverage. However, COGDOP finds a number of ambiguities in the language of the new IR that doctoral programs will find difficult to navigate without further clarity. These are itemized here: Definition of “non-discriminatory:” COGDOP requests explicit clarification of this term, as well as how it would be possible to demonstrate non-discrimination. Even the Educational Testing Service, with all its resources, cannot meet this standard. We anticipate that it could be very difficult or virtually impossible for departments to do so, unless it is operationalized feasibly and the criteria for judging its success are explicit. Definition of “multiple” in the category of “Advanced Integrative Knowledge:” If the CoA intends “multiple” to mean “at least two,” then it should say so explicitly. However, COGDOP believes that the minima... See Full Comment
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRMargaretBauer I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRAlisaManulkin I endorse the NCSPP response
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRConstanceHammen I support the APCS position.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRChristineMaleckiCouncil of Directors of School Psychology Programs Executive CommitteeThe Council Of Directors Of School Psychology Programs (CDSPP) Executive Committee notes that discipline-specific knowledge can be “acquired at either the upper-undergraduate or entry graduate” levels. If a program elects to use the first method of using a standardized assessment such as the GRE subject test to verify the presence of the requisite knowledge, must the program establish on an individual student basis from where the student actually learned the information? For example, when a student performs to the program’s satisfaction on the subject test, must the program verify/infer through a transcript review that the information was primarily learned through “upper-undergraduate” studies? Is it required that History and Systems of Psychology foundations and the foundations of the 5 content areas be addressed within the first one or two years of graduate study? Similarly, if a program has Biological Basis of Behavior and History and Systems in years 3 and 4, is this a pro... See Full Comment
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRThomasKubiszynCRSPPPCRSPPP appreciates CoA’s development of the proposed IRs. CRSPPP believes that the proposed IRs provide important specificity and guidance that doctoral, internship and postdoctoral programs need to enhance professional health service psychology training. That guidance should also prove helpful in enabling more focused preparation for the adoption of the SoA in 2016. CRSPPP also recognizes that the proposed IRs, like any attempt to address complex, evolving and important professional training issues, will invariably prove controversial, include unintended consequences, and defy universal approval. Nevertheless, CRSPPP believes that the proposed IRs, once public comments have been considered, will benefit the public and the profession.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRDianeBlau I endorse NCSPP's response
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRDianeBlau I support the position of Division 32.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRKareenMalone Paragraphs on requisite disciplinary knowledge appear to be broad in scope in terms of theory and approach. Still,I am not truly assured that, particularly given the many frameworks that have successfully functioned as clinical modalities that the document is as robust as it might be. It would seem to better reflect this diverse spectrum of approaches would ask that the authors be quite explicit that a broad knowledge of the many approaches to such interventions and clinical work would be requisite. Further that the area of specialization need not necessarily refer to what, for many, are therapeutic practices more amenable to being tested than being effective in "real time" and "on the ground". Rather it would seem that a multilayered and "critical" (as the document notes) of the many approaches and a thorough comprehension of the logic, ethics, and underlying principles would be ideal. This is particularly true if any specific approach is championed by any program and /or chosen by th... See Full Comment
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRMargaretBauer I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRMargaretBauer I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRThomasBradbury I strongly support the APCS position on DSK.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRDeborahDiGilioCommittee on Aging, Society of Clinical Geropsychology, and Council of Professional Geropsychology Training Programs We would like the following text(IN CAPS)added to the bullet: Developmental Aspects of Behavior Across the Lifespan, including transitions, growth, and development across an individual's life FROM INFANCY TO OLD AGE. Curricula limited to one developmental period is not sufficient. Rationale: If one looks at most psychology curricula, at the undergraduate and graduate level, coursework (and texts used in those courses) tends to focus on the earlier end of the lifespan, usually through adolescence, sometimes into early adulthood, and rarely into middle age and beyond. Even when courses and texts do address later life, the focus is often limited to cognitive deterioration, bereavement, and social isolation. Students are typically exposed to very little about the wide diversity among older adults in terms of their physical, psychological, and social status. Nor is it emphasized that development continues in important ways well beyond the century age mark, and that positive growth... See Full Comment
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRDianeBlauMichigan School of Professional PsychologyMiSPP supports the position of Division 32.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRAnnetteStanton I endorse the CUDCP comments.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRBradRoperSociety for Clinical Neuropsychology (Div. 40), representing 4,330 membersThe Society for Clinical Neuropsychology strongly supports the possibility for the undergraduate degree to represent meaningful preparation for graduate school, similar to “premed” training as preparation for MD training. We support the distinction between the basic content areas, which may be addressed at the undergraduate level, and the areas of Research Methods, Quantitative Methods, Psychometrics, and Advanced Integrative Knowledge of Discipline-Specific Content Areas, which are required at the doctoral level. We believe that the CoA has chosen wisely regarding the areas of required coverage at the doctoral level, and the focus on higher-level integrative knowledge. We hope that the change will also reduce the overall number of courses required. As the CoA is aware, Houston Conference Guidelines indicate that training in clinical neuropsychology takes place at the doctoral, internship, and postdoctoral levels. As such, we support the ability for students to satisfy basic psycholo... See Full Comment
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRJeffreyGoodie I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRCornishJennyAssociation of Psychology Postdoctoral and Internship Centers (APPIC)APPIC generally supports Discipline-Specific Knowledge, although it would be helpful to clarify whether this pertains only to doctoral programs or should also be relevant to internship and postdoctoral programs.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRAlliAnderson I endorse ACCTA’s response.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRMarkLumley I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRJesseOwen There are a few issues that I was wondering about: 1) Could a program develop its own test to determine minimal competence at entry into the program? If so, what standards would the test need to meet to be accepted by the CoA? 2) If a program was able to demonstrate that all of their students met the standards for the various domain area (e.g., affective, cognitive, etc), what additional experiences/competencies could be counted? For instance, could a program offer a Neuropsych Assessment for Kids course to build on the Broad and General foundation of biological bases? 3) Would a program be required to offer additional courses/experiences to build upon the Broad and General foundation? My understanding is that the foundations were meant to have such a foundation. 4) I am less clear on what could count as a discipline-specific competency. For instance, could a course that focuses on Affect Phobia or Emotion-focused therapy (treatment approaches) count as meeting the requirements ... See Full Comment
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRStewartShankman 1. I think it was a great decision to cut "individual differences" from the list in the "Broad and General" content area. In the old C-16 IR, it was unclear how this should be distinguished from psychopathology and diversity. I notice that "individual differences" is included (sort of) in "Individual and cultural diversity" and this seems like a good place. 2. I think it might be worth thinking about broadening the "cognitive aspects of behavior" to include basic principles of behavior change. For example, anyone who calls themselves a health service psychologist should know (or at least be exposed to) basic behavioral principles and concepts such as primary and secondary reinforcers, different schedules of partial reinforcement, context conditioning, etc. These are as important (if not more important) than the affective bases of behavior domain.
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IREdelynVerona I agree that more can be said about how to evaluate competency in the broad and general areas before matriculation. Would a GRE subject test do? It's also unclear what is being targeted by the following: "a comprehensive vetting process must include systematic methods that assess knowledge in a non-discriminatory fashion." What type of discrimination is of concern here? Does this just mean that the methods be standardized for all students and not done on a case by case basis?
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRCarlaSharp I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IDiscipline Specific Knowledge IRDiscipline Specific Knowledge IRBeckyReady I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionBrandonGibb I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionMartitaLopez I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionMeganO'Banion I support NCSPP's response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionTonyCellucciAPTCAPTC perceives these competencies as written to be largely in keeping with other competency documents and are supportive of competency-based education for health service providers.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionMichellePaul I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionLeeCooper I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionDavidMarcus I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionKathleenSikkema I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionNabilEl-GhorouryAPAGSFor Profession-Wide Competencies, the organization of competencies by training level makes clear the gradual acquisition of knowledge and skills overtime, clarifying to training directors what to expect from students and fellows at all levels. In regards to areas of competency, the introduction of knowledge, awareness, sensitivity and skills in relation to diversity stands as a timely and admirable addition, aligning with the interest of many APAGS members at becoming more competent in the diversity-related aspects of practice. Further, the inclusion of supervision and consultation as profession-wide competencies will likely benefit students, as gaining exposure to these competencies as trainees will strengthen their capacity to train future students and interact across disciplines with other professionals. While we generally support the competencies listed within the Implementing Regulations, we would recommend the addition of advocacy on issues related to the profession, the public w... See Full Comment
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionHannahWilliamson I endorse the APCS comments on this IR.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionStewartShankman I endorse the comments made by CUDCP and APCS.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionLindaCraighead I support the CUDCP and APCS responses
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionKrishnaKumar P.. 15: Profession-wide competencies · Consistency with the professional value of scientific practice (SoA Introduction, Section II.B2.d). The CoA expects that all profession-wide competencies will be grounded in the empirical literature and in a scientific orientation toward psychological knowledge and methods (ENCOMPASSING QUALITATIVE AND SINGLE CASE METHODS). THESE COMPETENCIES INCLUDE EVIDENCE-BASED THERAPY RELATIONSHIPS (WHICH STRESS THE ALLIANCE, EMPATHY, RUPTURE REPAIR, AND COLLECTING FEEDBACK). THEY ALSO REQUIRE EXPOSURE TO A BROAD ARRAY OF EMPIRICALLY BASED THEORETICAL ORIENTATIONS.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionGuanKaren I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionCindyYee-Bradbury I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionLeilaniCraneDivision 39 Representative to APA Council; BOD Division 39P.. 15: Profession-wide competencies · Consistency with the professional value of scientific practice (SoA Introduction, Section II.B2.d). The CoA expects that all profession-wide competencies will be grounded in the empirical literature and in a scientific orientation toward psychological knowledge and methods (ENCOMPASSING QUALITATIVE AND SINGLE CASE METHODS). THESE COMPETENCIES INCLUDE EVIDENCE-BASED THERAPY RELATIONSHIPS (WHICH STRESS THE ALLIANCE, EMPATHY, RUPTURE REPAIR, AND COLLECTING FEEDBACK). THEY ALSO REQUIRE EXPOSURE TO A BROAD ARRAY OF EMPIRICALLY BASED THEORETICAL ORIENTATIONS.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionHeidiLevitt I agree with the comments that John Norcross posted for Division 29. I am writing in strong support of the Division 29 statement of concerns. There is a lack of understanding of what constitutes ‘empirically based’. These are my recommendations: (1) The statement should specify that empirically-based evidence includes the vast body of meta-analytic evidence that supports equivalence between many psychotherapy orientations in each section where it is mentioned. (2) It should explicitly state that there is a wealth of empirical evidence across the major psychotherapy traditions and should recommend that students receive training across multiple theoretical orientations. (4) In addition, the guidelines should make clear that empirical evidence includes both qualitative and quantitative research as people often confuse the term empirical with quantitative and there is valuable clinically-relevant qualitative research that this statement appears to discount at present. (5) I strongly a... See Full Comment
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionJerroldShapiro It is important that we not lose the true meaning of the word "empirical" which includes deriving knowledge from experience and inductive reasoning. In recent years it has narrowed to indicate deductive observations for which we have available instruments. The reduction to those kinds of observations can run afoul of the "Law of the Instrument" and actually limit rather than expand scientific inquiry. I agree with and recommend inclusion of the recommended edit proposed by Kirk Schneider, reproduced here (recommended edit in CAPS) The CoA expects that all profession-wide competencies will be grounded in the empirical literature and in a scientific orientation towardpsychological knowledge and methods (ENCOMPASSING QUALITATIVE AND SINGLE CASE METHODS). THESE COMPETENCIES INCLUDE EVIDENCE-BASED THERAPY RELATIONSHIPS (WHICH STRESS THE ALLIANCE, EMPATHY, RUPTURE REPAIR, AND COLLECTING FEEDBACK). THEY ALSO REQUIRE EXPOSURE TO A BROAD ARRAY OF EMPIRICALLY BASED THEORETICAL ORIENTATI... See Full Comment
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionkrugorah  · P.. 15: Profession-wide competencies · Consistency with the professional value of scientific practice (SoA Introduction, Section II.B2.d). The CoA expects that all profession-wide competencies will be grounded in the empirical literature and in a scientific orientation toward psychological knowledge and methods (ENCOMPASSING QUALITATIVE AND SINGLE CASE METHODS). THESE COMPETENCIES INCLUDE EVIDENCE-BASED THERAPY RELATIONSHIPS (WHICH STRESS THE ALLIANCE, EMPATHY, RUPTURE REPAIR, AND COLLECTING FEEDBACK). THEY ALSO REQUIRE EXPOSURE TO A BROAD ARRAY OF EMPIRICALLY BASED THEORETICAL ORIENTATIONS.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionKirkSchneiderOn behalf of Division 32Under "Consistency with the professional value of scientific practice" I submit the following revision in capital letters on behalf of Division 32: SoA Introduction, Section II.B2.d). The CoA expects that all profession-wide competencies will be grounded in the empirical literature and in a scientific orientation toward psychological knowledge and methods-ENCOMPASSING QUALITATIVE AND SINGLE CASE METHODS ALONG WITH QUANTITATIVE MEASURES. THESE COMPETENCIES FURTHER STRESS THERAPY RELATIONSHIPS THAT REFLECT EVIDENCE BASED FACTORS SUCH AS THE ALLIANCE, EMPATHY, RUPTURE REPAIR, AND ADJUSTING TO GATHERED FEEDBACK. THEY ALSO EMBRACE PROFESSION-WIDE STANDARDS THAT INCLUDE EXPOSURE TO AND FAMILIARITY WITH A BROAD DIVERSITY OF EMPIRICALLY VALIDATED THEORETICAL ORIENTATIONS CURRENTLY AVAILABLE.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionThomasOltmannson behalf of the Academy of Psychological Clinical Science (APCS)Comments from the APCS Executive Committee: Related to APCS’s concern for the DSK IR, we raise a similar concern with respect to frequent reference that training is sequential and graded. Although this obviously happens to a certain degree by default, there is little evidence to support the validity of these fine distinctions over a simpler model of accumulation over time (that may or may not be sequential or graded) increasing competency. In fact a recent study showed clearly that ratings of practicum competency increased from the first to the second practicum but did not change significantly from 2 to 3 or 3 to 4. It is unclear if this reflects early ceiling effects or some other phenomenon, but clearly the science of our ability to evaluate competencies is not at a point at which we can make such fine distinctions. Again, this may well happen but, as written, this IR presents an unnecessary burden on a program to document that their practica represent meaningfully sequential and gr... See Full Comment
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionLaurenHarris I endorse comments made by APCS
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionKirkSchneider I strongly support Divisions 29 and 39's comments in this area.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionStephanieBudge  Under "Interventions" I submit on behalf of Division 32 the following revisions in capital letters: p. 19: VII. Intervention Trainees demonstrate competence in evidence-based interventions AND RELATIONSHIPS consistent with the scope of health service psychology. Competence in intervention includes determining an evidence-based treatment plan, implementing appropriate interventions, evaluating intervention outcomes, and adapting intervention goals and methods consistent with ongoing evaluation. To achieve competence in intervention, trainees must demonstrate the following specific skills: o Identify, select, and apply appropriate evidence-based interventions AND RELATIONSHIPS specific to the service delivery goals. Such interventions shall be informed by the current scientific literature, assessment findings, diversity characteristics, and contextual variables. IT SHOULD BE NOTED THAT THE CURRENT SCIENTIFIC LITERATURE STRESSES THE CENTRALITY OF THE QUALITY OF THERAPEUTIC RELATIONSHIPS... See Full Comment
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionBarryDauphinDivision 39 Board of Directors and Education & Training CommitteeConsistency with the professional value of scientific practice (SoA Introduction, Section II.B2.d). The CoA expects that all profession-wide competencies will be grounded in the empirical literature and in a scientific orientation toward psychological knowledge and methods (ENCOMPASSING QUALITATIVE AND SINGLE CASE METHODS). THESE COMPETENCIES INCLUDE EVIDENCE-BASED THERAPY RELATIONSHIPS (WHICH STRESS THE ALLIANCE, EMPATHY, RUPTURE REPAIR, AND COLLECTING FEEDBACK). THEY ALSO REQUIRE EXPOSURE TO A BROAD ARRAY OF EMPIRICALLY BASED THEORETICAL ORIENTATIONS.---we support the statement of Kirk Schneider, Ph.D. We also would support that the statement should include grounding in the philosophical underpinnings of science and the role of ethics in the practice of science. With respect to Level Appropriate Training: Although the language of preparation for entry level practice makes sense in principle, how relevant is the language when APA’s model licensing act would no longer require ... See Full Comment
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionNancyMcWilliams Re: Consistency with the professional value of scientific practice: There should be explicit acknowledgment of qualitative science, the value of single case methods, and the relevance of scholarly traditions other than psychology that may bear on practice. I would also want the inclusion of some acknowledgment of the scientific status of long and varied clinical experience; in science, there is a tradition of disciplined naturalistic observation (Lister, Pasteur, Darwin, Einstein), and part of the scientific role of therapists is to pay careful attention to the particularity of each patient, thinking about what is needed in the larger context of empirical and theoretical literature about personality, development, neuroscience, cultural diversity, and other areas. Therapists are often confronted with problems on which academics have not done research yet (e.g., the sadistic patient, the client from some minority group about which there is little empirical literature), and they need to... See Full Comment
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionRobertBarrett I support the comments made by NCSPP
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionStephenDeMersASPPBThe comments in the previous sections also reflect concerns in this area as well, especially with the “variety of methods to ensure competency.” The idea of a portfolio is one we have expressed before and hope that CoA requires that each training director keep this kind of documentation in a form that can be easily transmitted to licensing boards. ASPPB appreciates your comments that your interpretation of what competencies are necessary for successful psychology education are not considered the sole authority on the subject. The ASPPB Competencies Expected at the Point of Licensure and other competency models, including the CoA model, have much overlap.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionKennethLevy I strongly support Divisions 29 and 39's comments in this area as well as those of John Norcross, Nancy McWilliams, Heidi Levitt, Barry Farber, Barry Dauphan, Kirk Schneider, and Art Bohart. I am faculty member at a top clinical psychology program but one that is unique in its diversity with regard to theoretical orientation. I have written a paper, along with Tim Anderson, highlighting the seriousness of the problem (see attached). Psychology programs are becoming near monocultures with almost 80% of faculty having a CBT orientation and less than 10 percent with dynamic or humanistic orientations among the top clinical scientist programs. The problem is only slightly better among non-clinical scientists PhD programs. The trend is so strong that it is difficult to imagine how it can be righted without strong leadership from APA to enforce the importance of offering more than one perspective. CBT is an important approach and has much to offer but the evidence suggests that there is “mor... See Full Comment
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionLorettaBraxtonVAPTCVAPTC is in strong support of the profession-wide competency IR. VAPTC requests that level appropriate competencies be delineated from the graduate level through the postdoctoral level for each competency and particularly for the three competencies required by the SoA for postdoctoral programs (i.e., Integration of Science and Practice, Individual and Cultural Diversity, and Ethics and Legal Matters).
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionRajaDavid I endorse the NCSPP response for this section.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionAliciadel Prado I endorse the NCSPP response for all sections.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionClaireLeBeauSeattle University Graduate Psychology ProgramI strongly endorse comments made by Divisions 29, 39, and 32 for this section.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionKennethCritchfield I support the comments submitted on behalf of Division 29.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionHeatherSheets "I endorse the NCSPP response for all sections."
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionTerriDavis I endorse the NCSPP response for all sections.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionAndrewChristensen I endorse comments made by APCS
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductiondavidlarami I strongly support the comments from Divisions 29, 32, and 39.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionWallaceDixonCouncil of Graduate Departments of Psychology (COGDOP)COGDOP endorses this IR.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionAlisaManulkin I endorse the NCSPP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionConstanceHammen I support the APCS position.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionBradRoperSociety for Clinical Neuropsychology (Div. 40), representing 4,330 membersThis IR clarifies profession-wide competencies for doctoral and internship programs much better than those for postdoctoral programs. In fact, there is potential for this IR to be more confusing than it is clarifying for postdoctoral programs. The Introduction makes clear that the IR applies to postdoctoral programs; however, it is not clear throughout the IR which competencies apply to postdoc programs. Additionally, the title of the IR “Profession-Wide Competencies” raises questions regarding whether it should pertain to the postdoc level. We note that, in contrast to the doctoral and internship SoA, the postdoc SoA do not specify “Profession-Wide Competencies” but rather specify “Competencies” and define three levels of competencies. The three “Level 1” competencies are required of all programs, but these are not defined as profession-wide competencies. The only mention of profession-wide competencies in the postdoc SoA is in Section II.B.2(b) (i.e., “CoA profession-wide competenci... See Full Comment
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionCraigErik Consistency with the professional value of scientific practice (SoA Introduction, Section II.B2.d). The CoA expects that all profession-wide competencies will be grounded in the empirical literature and in a scientific orientation toward psychological knowledge and methods. Comment: The terms empirical and scientific both lack a clear definition. Experience in the past has shown that that these terms have tended to be defined in strictly quantitative terms in spite of the fact that many APA journals now accept qualitative, hermeneutic and theoretical investigations and our own Division 5 now includes such so-called qualitative studies as a valued approach to psychology as both a natural and human science. The distinction between proof (the aim of calculative or natural science) and understanding (the aim of meaning-centered or human science) was established in the 19th century and is the scientific basis for qualitative, historical, participant observation, and clinical case stud... See Full Comment
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionChristinaCarroll-Pavia I endorse ACCTA’s response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionJeffreyGoodie I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionJulieCorkery I endorse ACCTA's response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionCornishJennyAssociation of Psychology Postdoctoral and Internship Centers (APPIC)APPIC supports the Profession-Wide Competency IR and recommends extending the developmental levels (doctoral, internship, postdoctoral) throughout the competencies since some (e.g., ethical and legal standards) lack any such guidelines.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionMarkLumley I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionArpanaInmanCCPTPPlease note that these are CCPTP's overall comments on Profession wide competencies: There are several concerns in this area: (1) Knowledge/Awareness/Skills traid is out of date and over-used and there is not enough evidence that these three components make someone culturally competent. (2) why is a simulated supervision experience okay at the Internship level? Is this because other fields in psychology don’t supervise? For example our School Psych people and Clinical Psych people don’t get any training in supervision (3) it is interesting that in the first paragraph on page 17 it is stated that “trainees must demonstrate knowledge, awareness, sensitivity, and skills when working with diverse individuals and communities”, but then there is no inclusion of in the operationalization of what the trainees must demonstrate. (4) there is a concern for the push for evidence-based practices when so many treatment modalities have not been examined for efficacy or effectiveness with diverse c... See Full Comment
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionMeganO'Banion I support NCSPP's responses regarding all of the Profession-Wide Competency IR's. I would also strongly encourage CoA to review these IR's and to modify the language to ensure inclusivity rather than inadvertent discrimination particularly pertaining to communication, assessment and supervision sections.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionHeatherNoble I endorse ACCTA’s response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionDeborahBeidelCouncil for University Directors of Clinical Psychology (CUDCP)CUDCP notes that under Profession-wide Competencies there is no category specifically labeled Psyschopathology. We encourage specific inclusion of this area as competence in psychopathology is part of the bedrock of our profession.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionKarenLese-FowlerAssociation of Counseling Center Training Agencies (ACCTA)Section II.B2.d. While ACCTA supports the CoA’s professional value of scientific practice, certain competencies such as Ethical and Legal Standards, Professional Values and Attitudes, and Communication and Interpersonal skills appear more rooted in professional values than science per se. We encourage rewording of this section to more accurately reflect this. One possible suggestion might be: The CoA expects that all profession-wide competencies will be grounded in the empirical or other professional literature and experience, and in a scientific orientation toward psychological knowledge and methods.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIntroductionBeckyReady I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchRadhikaKrishnamurthy I support NCSPP's recommendations.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchBrandonGibb I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchMartitaLopez I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchHidekoSeraNCSPPNCSPP applauds CoA for supporting a competency-based approach to education and training, and appreciates the detailed and developmentally-sensitive operational definitions offered for each content area. NCSPP is concerned, however, that several sections as currently written can be narrowly interpreted and/or misinterpreted, and result in an unintended disadvantage to certain programs, particularly Psy.D. programs. To avoid such a circumstance, NCSPP recommends the following modifications to the proposed text: Under I. Research: NCSPP suggests that the current operational definition of research may be narrowly and inappropriately interpreted, and may be misconstrued to value the production of original research above equally critical scientific endeavors, including the understanding and application of evidence-based practices, and engagement in empirically-based program evaluation. Consequently, NCSPP recommends three changes to this section: a. Modify sentence two under I. ... See Full Comment
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchMichellePaul I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchLeeCooper I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchJohnNorcrossAPA Division of Psychotherapy (29)Dear CoA Colleagues: The following comments are submitted on behalf of, and with the approval of, the APA Division of Psychotherapy (recently renamed the Society for the Advancement of Psychotherapy). In particular, our proposed additions reflect our serious and abiding concerns about the CBT-biased wording and technically oriented content of the document. A dispassionate reader would have no earthly idea that “psychotherapy” is a human relationship or that there are multiple evidence-based theories from the proposed wording. “Interventions” do NOT contain or represent “relationships.” That is the narrow precept of a few theoretical orientations. Indeed, “relationships” is the more inclusive term that may or may not contain discrete “interventions.” Frankly, the current insular language strikes many of us as insulting and disrespectful. Please find more theoretically neutral and collegially inclusive language throughout. Thank you for considering our recommendations. We wish... See Full Comment
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchSherrylGoodman I fully support the responses submitted by CUDCP and APCS.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchKathleenSikkema I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchLanceSwenson I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchScottChurchill I worry that the reference to "substantial knowledge of scientific methods, procedures, and practices" could in many cases be interpreted to mean: "substantial knowledge of *the* scientific method, and its procedures, etc." We celebrated a Decade of Science not so long ago, and at Leadership Conferences sponsored by the AAPA Directorates, there were often break-out groups where the appointed leaders of those groups presumed that everyone at the table shared the same common identity as "science" based psychologists - where "science" was defined according to STEM standards. Often these group discussion facilitators were from among those subfields in psychology where experimentation and randomized control trials are considered the one and only "gold standard" for psychological research. At these breakout groups, I dared to identify myself as a "qualitative researcher" - and was encouraged when I saw friendly nods coming from several at the table who also identified as researchers with n... See Full Comment
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchJeanCarter I support the comments submitted on behalf of Division 29.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchRobertRomanyshyn Robert D. Romanyshyn, Ph.D. Emeritus Prof of Clinical Psychology Pacifica Graduate Institute Scott Churchill raises some very key issues regarding ‘the APA’s commitment to scientific methods, procedures and practices.’ He focuses on two concerns with that commitment. On one hand, he correctly points out the slippage from a commitment to scientific methods to the singular method of the natural sciences, which is the operative norm in psychology as a STEM science. Second, he shows that such a commitment dismisses epistemological diversity in psychology’s research practices, which contradicts the APAs commitment to diversity regarding gender, race, sexual orientation and other issues. To these two concerns I want to add a third. Psychology’s commitment to a STEM view of science lies within and fosters philosophical assumptions, which, even after a half-century of critiques of those assumptions by phenomenology and its convergence with the human science movement, continue... See Full Comment
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchRobertBarrett I support the comments made by NCSPP
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchBarryDauphinDivision 39 Board of Directors and Education & Training CommitteeDemonstrates the ability to formulate, conduct, critically evaluate, and disseminate, via professional publication or presentation, research or other scholarly activities that are of sufficient quality and rigor to contribute to the scientific or psychological knowledge base. This requires substantial knowledge of scientific methods, procedures, and practices. --- Should also include this to mean understanding the philosophical bases for research as well as strengths and limitations of all research methods.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchBrentRobbins It should be specified that competency in science requires the ability to produce, apply and critically evaluate knowledge based on not only quantitative approaches to science, but also qualitative studies. Graduate training must give students the opportunity to use and understand the full range of scientific methodologies in the field. Students should not only be able to produce, use and critically evaluate correlational and experimental research, they should be able to produce, use and critically evaluate various qualitative approaches, including, for example, case study, ethnography, phenomenological research, and grounded theory research. In addition, students should be required to understand the philosophical presuppositions of their methodologies and theories, including the epistemological assumptions of the research methods they use in the field.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchKimberlyHays Since internship is focused more on practice in many settings I hope that the presenting information does not necessitate being able to present at a conference. Our interns certainly do presentations in our setting (eg. a formal midyear and end of year case presentation), and are sometimes able to present at professional conferences, but not always.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchYakushkoOksana - The current guidelines and new standards reflect unquestioned commitment to quantitative and positivists methods in psychology. Qualitative research methods and human science tradition, which embraced as essential for multicultural, contextual, and transformative influence of psychology (Gergen, Josselson, & Freeman, 2015; Morrow, 2007; Ponterotto, 2005; Wertz, 2011), have received greater attention. Therefore, the standards must be examined in their relation to over-representation of a natural sciences approaches and absence of requirements for the inclusion of human science training.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchStephanieWood I support NCSPP's recommendations.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchClaireLeBeauSeattle University Graduate Psychology ProgramThe language of "scientific methods, procedures, and practices" is indeed quite limiting with regard to the connotations of what "scientific" could mean. Human science training programs provide rigorous training to students in psychological phenomena which do not lend themselves to an exclusive natural science exploration. Amending this language to include a human science research focus is needed. In considering a broader scope for what constitutes rigor in research we explore the idea that "the truths that researchers search for are elusive and can be spoken of in a multitude of ways. Truths in human life are elusive not because they are abstract or unreal but because they transcend us even as they touch us deeply. Phenomena such as friendship, despair, grief, or love are realities at the core of human existence, realities that elude measurement, and it is to them that we bear witness as researchers within a human science orientation" (Halling, 2010, p. 142). We agree with Dr. Chu... See Full Comment
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchRajaDavid I endorse the NCSPP response for this section.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchAliciadel Prado I endorse the NCSPP response for all sections.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchTorreyWilson I strongly support the NCSPP recommendations.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchHeatherSheets "I endorse the NCSPP response for all sections."
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchAndrewChristensen I endorse comments made by APCS
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchAlisaManulkin I endorse the NCSPP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchMartiKranzberg I strongly support Div. 29 positions on research.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchChristineMaleckiCouncil of Directors of School Psychology Programs Executive CommitteeThe Council of Directors of School Psychology Programs (CDSPP) Executive Committee wonders how the CoA will consider the impact of this IR on practice-oriented doctoral training programs. The IR states that a doctoral-level student must demonstrate the ability to “formulate” and “conduct” research that is of “sufficient quality and rigor to contribute to the scientific or psychological knowledge base.” Practice-oriented doctoral programs, like PsyD programs, seek to train students to “critically evaluate and disseminate” research, and even formulate and conduct analyses of data to contribute to the understanding of problems, but not necessarily “conduct” generalizable research that “contributes to the scientific knowledge base” as a program competency. The IR should be clear that both scientific contributions AND applied psych contributions are equally appropriate as long as they match the stated aims of the degree program and meet the standard.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchTimothyBrown I endorse the NCSPP response for the revised Research section of the Profession-Wide Competency IR. I also support the sentiments expressed in a number of comments that the language in this section reflects a narrow and limiting definition of what constitutes scientific inquiry.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchThomasKubiszynCRSPPPCRSPPP appreciates CoA’s development of the proposed IRs. CRSPPP believes that the proposed IRs provide important specificity and guidance that doctoral, internship and postdoctoral programs need to enhance professional health service psychology training. That guidance should also prove helpful in enabling more focused preparation for the adoption of the SoA in 2016. CRSPPP also recognizes that the proposed IRs, like any attempt to address complex, evolving and important professional training issues, will invariably prove controversial, include unintended consequences, and defy universal approval. Nevertheless, CRSPPP believes that the proposed IRs, once public comments have been considered, will benefit the public and the profession.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchBradRoperSociety for Clinical Neuropsychology (Div. 40), representing 4,330 membersThis competency does not appear to apply to the postdoc level, and that needs to be clarified. Regarding the expectation for doctoral and internship training, we strongly support this clarification of the profession-wide Research competency.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchChristinaCarroll-Pavia I endorse ACCTA’s response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchRadhikaKrishnamurthy I support NCSPP's recommendations.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchJulieCorkery I endorse ACCTA's response to the proposed Research IR.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchEdelynVerona I support Mitch Prinstein's statement on behalf of SSCP.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchAlliAnderson I endorse ACCTA’s response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchAmyWilliams I endorse ACCTA's comments
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchLindaScott I am in support in the recommendations outlined by ACCTA
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchC. PatriciaHanley I strongly support the comments submitted by the Association of Counseling Center Training Agencies (ACCTA).
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchBrooksMorse I support ACCTA comments
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchBrooksMorse I support ACCTA comments
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchKarinMcCoy I have reservations about the requirement that "[g]raduates of HSP programs ... demonstrate ... attitudes sufficient to produce new knowledge...". How might the attitudes be measured? If a student has the skills and knowledge to produce new knowledge, but not the interest, would that mean this individual does not have the appropriate attitude and should not graduate?
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchHeatherNoble I endorse ACCTA’s response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchDeborahBeidelCouncil for University Directors of Clinical Psychology (CUDCP)CUDCP agrees with the language of this IR
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchDeborahBeidelCouncil for University Directors of Clinical Psychology (CUDCP)CUDCP agrees with the language of this IR and applauds the I. Research text for doctoral programs that states “Demonstrates the ability to formulate, conduct, critically evaluate, and disseminate, via professional publication or presentation, research or other scholarly activities that are of sufficient quality and rigor to contribute to the scientific or psychological knowledge base. This requires substantial knowledge of scientific methods, procedure, and practices. We agree that the best way for doctoral level psychologists to integrate science and practice is for training in research to be as advanced and immersive as clinical training.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchKarenLese-FowlerAssociation of Counseling Center Training Agencies (ACCTA)ACCTA appreciates the clarification that interns are not expected to conduct research at their internships, which are by intention practically and experientially focused and generally take place at service delivery organizations. Given the practice focus of internship, the expectation to disseminate research by professional presentation or publication at the intern level may be unrealistic.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRI. ResearchBeckyReady I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsBrandonGibb I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsMartitaLopez I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsMichellePaul I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsKathleenSikkema I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsSherrylGoodman I fully support the responses submitted by CUDCP and APCS.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsLanceSwenson I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsBarryDauphinDivision 39 Board of Directors and Education & Training CommitteeEthical and legal standards should be separate categories or more clearly differentiated as not the same. Students should be knowledgeable about general ethical principles not only the APA Ethical Principles of Psychologists and code of conduct.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsStephenDeMersASPPBASPPB appreciates the continued inclusion of relevant laws, regulations, rules and policies governing health service psychology.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsRobertBarrett I support the comments made by NCSPP
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsRajaDavid I endorse the NCSPP response for this section.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsAliciadel Prado I endorse the NCSPP response for all sections.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsClaireLeBeauSeattle University Graduate Psychology ProgramStrong agreement with Dauphin's comments here. Legal standards and ethical principals should be completely separate headings.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsTorreyWilson I strongly support the NCSPP recommendations.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsHeatherSheets "I endorse the NCSPP response for all sections."
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsAlisaManulkin I endorse the NCSPP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsThomasKubiszynCRSPPPCRSPPP appreciates CoA’s development of the proposed IRs. CRSPPP believes that the proposed IRs provide important specificity and guidance that doctoral, internship and postdoctoral programs need to enhance professional health service psychology training. That guidance should also prove helpful in enabling more focused preparation for the adoption of the SoA in 2016. CRSPPP also recognizes that the proposed IRs, like any attempt to address complex, evolving and important professional training issues, will invariably prove controversial, include unintended consequences, and defy universal approval. Nevertheless, CRSPPP believes that the proposed IRs, once public comments have been considered, will benefit the public and the profession.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsBradRoperSociety for Clinical Neuropsychology (Div. 40), representing 4,330 membersThis competency refers to “trainees” and appears to cover the postdoc level, since it is included as a Level 1 competency in the postdoc SoA.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsBradRoperSociety for Clinical Neuropsychology (Div. 40), representing 4,330 membersThis competency offers a specific and easily understandable definition of the expectations for the postdoctoral level, which builds upon the other training levels.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsJeffreyGoodie I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsLeeCooper I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsAlliAnderson I endorse ACCTA’s response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsBeckyReady I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRII. Ethical and Legal StandardsDeborahBeidelCouncil for University Directors of Clinical Psychology (CUDCP)CUDCP agrees with the language of this IR
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityJulieNeJame I agree with CoA comments about cultural diversity.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityBrandonGibb I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityMartitaLopez I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityMichellePaul I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityKathleenSikkema I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityTonyCellucciAPTC. Under assessment competence, APTC wonders if it would be helpful to discuss expectations by level of training or further state how diversity characteristics should be considered in assessment (e.g., selection, interpretation of instruments).
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityLanceSwenson I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityLeilaniCraneDivision 39 Representative to APA Council; BOD Division 39o SKILLS: The ability to integrate awareness and knowledge of individual and cultural differences in the conduct of professional roles (e.g., research, services, and other professional activities). This includes the ability apply a framework for working effectively with areas of individual and cultural diversity not previously encountered over the course of their careers. Also included is the ability to work effectively with individuals whose group membership, demographic characteristics, PERSONALITY STYLES, or worldviews create conflict with their own.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityKrishnaKumar p. 17: Trainees must demonstrate: o SKILLS: The ability to integrate awareness and knowledge of individual and cultural differences in the conduct of professional roles (e.g., research, services, and other professional activities). This includes the ability apply a framework for working effectively with areas of individual and cultural diversity not previously encountered over the course of their careers. Also included is the ability to work effectively with individuals whose group membership, demographic characteristics, PERSONALITY STYLES, or worldviews create conflict with their own.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityHeidiLevitt I am writing in strong support of the Division 29 statement of concerns. There is a lack of understanding of what constitutes ‘empirically based’. These are my recommendations: (1) The statement should specify that empirically-based evidence includes the vast body of meta-analytic evidence that supports equivalence between many psychotherapy orientations in each section where it is mentioned. (2) It should explicitly state that there is a wealth of empirical evidence across the major psychotherapy traditions and should recommend that students receive training across multiple theoretical orientations. (4) In addition, the guidelines should make clear that empirical evidence includes both qualitative and quantitative research as people often confuse the term empirical with quantitative and there is valuable clinically-relevant qualitative research that this statement appears to discount at present. (5) I strongly advocate for the creation of a task force composed of experts from acro... See Full Comment
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityMichaelSipiora I strongly support the comments from Divisions 39, 29, & 32
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityMichaelSipiora I strongly support Churchill's comments
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityKirkSchneiderOn behalf of Division 32Under "Individual and Cultural Diversity" I submit the following revisions in capital letters on behalf of Division 32: p. 17: Trainees must demonstrate: o SKILLS: The ability to integrate awareness and knowledge of individual and cultural differences in the conduct of professional roles (e.g., research, services, and other professional activities). This includes the ability apply a framework for working effectively with areas of individual and cultural diversity not previously encountered over the course of their careers. Also included is the ability to work effectively with individuals whose group membership, demographic characteristics, PERSONALITY STYLES, or worldviews create conflict with their own.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityKirkSchneider I strongly support Divisions 29 and 39's comments in this area.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural Diversitykrugorah  p. 17: Trainees must demonstrate: o SKILLS: The ability to integrate awareness and knowledge of individual and cultural differences in the conduct of professional roles (e.g., research, services, and other professional activities). This includes the ability apply a framework for working effectively with areas of individual and cultural diversity not previously encountered over the course of their careers. Also included is the ability to work effectively with individuals whose group membership, demographic characteristics, PERSONALITY STYLES, or worldviews create conflict with their own.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityBrentRobbins Under skills, therapists should also be able to work with those who have personality styles that differ from their own as well as those who differ in terms of group membership, demographic characteristics, or worldviews.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityBarryDauphinDivision 39 Board of Directors and Education & Training Committee--- The document should contain an overt inclusion in its enumeration of differences that are explicitly psychological, such as values, attitudes, and beliefs. We would prefer something explicit in a document pertaining to inherently psychological characteristics and not only the language “but not limited to”. SKILLS: The ability to integrate awareness and knowledge of individual and cultural differences in the conduct of professional roles (e.g., research, services, and other professional activities). This includes the ability apply a framework for working effectively with areas of individual and cultural diversity not previously encountered over the course of their careers. Also included is the ability to work effectively with individuals whose group membership, demographic characteristics, PERSONALITY STYLES, or worldviews create conflict with their own
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityJerroldShapiro Psychologists pride themselves in integrating both ideographic and nomothetic understanding. It is essential that trainees can comprehend both the "emic" (culturally unique) and "etic (humanly universal). I strongly agree with the ecologic formulation of culture formulated by Vontress and Epp (2015) comprising five nested interacting rings: 1) Universal culture: invariable facets of human existence 2) Ecological culture: ecosystems that deeply influence day-to-day living 3) National culture: the sum of allegiances to community heritage, customs, language, economic realities, government, territory etc. 4) Regional culture: focused on neighboring cultures, climate, ethnic mixtures and blending with those in proximity 5) Racial/ethnic culture: where people of similar ethnic and racial backgrounds tend to live in enclaves that provide separateness from others. For most of the 20th century in large U.S. cities, there were identifiable “neighborhoods” (Ghettos) that limited diversi... See Full Comment
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityYakushkoOksana - Current guidelines and new standards in psychology appear to reflect primarily the dominant Western American worldview, which emphasizes individual determinism (belief in the individual free will), atomism (belief that individual human experiences can be broken down into distinct and measurable aspects), positivism (empiricism), materialism (physic-chemical foundations of all human behavior), and hedonism (emphasis on person happiness and achievement) (Danzinger, 2006; Gergen, Gulerce, Lock & Misra, 1998; Marsella, 1998; Parker, 2014; Prelleltensky, 1997; Teo, 2006). In contrast, the worldviews and values of individuals from diverse communities and those who emphasize social justice frameworks in psychology reflect significance of intersubjectivity, holism, contextuality, postmodern/deconstructivist notions of sciences, and the empowerment and emancipatory focus (Morrow & Howxhurst, 2012; Prelletensy & Fox, 1997; Prilleltensky & Nelson, 2008; Tate, Rivera, & Edwards, 2012; Watkins &... See Full Comment
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityRobertBarrett I support the comments made by NCSPP
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityJuneChing Under Individual and Cultural Diversity p. 17: Trainees must demonstrate: SKILLS: The ability to integrate awareness and knowledge of individual and cultural differences in the conduct of professional roles (e.g., research, services, and other professional activities). This includes the ability apply a framework for working effectively with areas of individual and cultural diversity not previously encountered over the course of their careers. Also included is the ability to work effectively with individuals whose group membership, demographic characteristics, PERSONALITY STYLES, or worldviews create conflict with their own. Please add “personality styles” to the description of individual diversity. A compelling body of research literature finds that psychological treatment tailored to the patient (e.g., stage of change, preferences, spirituality/religions)and his/her personality (e.g., reactance level, coping style, attachment style) demonstrably reduces dropouts and increases ... See Full Comment
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityRajaDavid I endorse the NCSPP response for this section.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityAliciadel Prado I endorse the NCSPP response for all sections.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityTorreyWilson I strongly support the NCSPP recommendations.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityHeatherSheets "I endorse the NCSPP response for all sections."
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural Diversitydavidlarami I strongly support Divisions 29, 32, and 39's comments in this area.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityAlisaManulkin I endorse the NCSPP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityThomasKubiszynCRSPPPCRSPPP appreciates CoA’s development of the proposed IRs. CRSPPP believes that the proposed IRs provide important specificity and guidance that doctoral, internship and postdoctoral programs need to enhance professional health service psychology training. That guidance should also prove helpful in enabling more focused preparation for the adoption of the SoA in 2016. CRSPPP also recognizes that the proposed IRs, like any attempt to address complex, evolving and important professional training issues, will invariably prove controversial, include unintended consequences, and defy universal approval. Nevertheless, CRSPPP believes that the proposed IRs, once public comments have been considered, will benefit the public and the profession.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityCraigErik Under skills: demographic and individual characteristics
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityBradRoperSociety for Clinical Neuropsychology (Div. 40), representing 4,330 members(Note that this comment was inadvertently entered under the "Ethical and Legal" section): This competency offers a specific and easily understandable definition of the expectations for the postdoctoral level, which builds upon the other training levels.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityJeffreyGoodie I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityLeeCooper I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityBeckyReady I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityKirkSchneider I submit the following revision request in capital letters: p. 17: Trainees must demonstrate: o SKILLS: The ability to integrate awareness and knowledge of individual and cultural differences in the conduct of professional roles (e.g., research, services, and other professional activities). This includes the ability apply a framework for working effectively with areas of individual and cultural diversity not previously encountered over the course of their careers. Also included is the ability to work effectively with individuals whose group membership, demographic characteristics, PERSONALITY STYLES, or worldviews create conflict with their own.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIII. Individual and Cultural DiversityDeborahBeidelCouncil for University Directors of Clinical Psychology (CUDCP)CUDCP agrees with the language of this IR
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and AttitudesBrandonGibb I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and AttitudesMartitaLopez I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and AttitudesTonyCellucciAPTCAlthough included in the revised Benchmarks competency document, we note and support CoA’s inclusion of the concept of psychologist well-being under professional values and attitudes.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and AttitudesMichellePaul I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and AttitudesKathleenSikkema I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and AttitudesSherrylGoodman I fully support the responses submitted by CUDCP and APCS.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and AttitudesLanceSwenson I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and AttitudesRobertBarrett I support the comments made by NCSPP
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and AttitudesRajaDavid I endorse the NCSPP response for this section.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and AttitudesAliciadel Prado I endorse the NCSPP response for all sections.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and AttitudesTorreyWilson I strongly support the NCSPP recommendations.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and AttitudesHeatherSheets "I endorse the NCSPP response for all sections."
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and Attitudesdavidlarami I very strongly support the Division 32 comments.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and AttitudesAlisaManulkin I endorse the NCSPP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and AttitudesMartiKranzberg I strongly support the position of Div. 39.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and AttitudesThomasKubiszynCRSPPPCRSPPP appreciates CoA’s development of the proposed IRs. CRSPPP believes that the proposed IRs provide important specificity and guidance that doctoral, internship and postdoctoral programs need to enhance professional health service psychology training. That guidance should also prove helpful in enabling more focused preparation for the adoption of the SoA in 2016. CRSPPP also recognizes that the proposed IRs, like any attempt to address complex, evolving and important professional training issues, will invariably prove controversial, include unintended consequences, and defy universal approval. Nevertheless, CRSPPP believes that the proposed IRs, once public comments have been considered, will benefit the public and the profession.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and AttitudesBradRoperSociety for Clinical Neuropsychology (Div. 40), representing 4,330 membersThis competency refers to “trainees” generically. It is not included as a Level 1 competency in the postdoc SoA. As such, it does not apply to postdoc programs as it is currently written, although that is not clear in the section.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and AttitudesJeffreyGoodie I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and AttitudesLeeCooper I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and AttitudesAlliAnderson I endorse ACCTA’s response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and AttitudesBeckyReady I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and AttitudesDeborahBeidelCouncil for University Directors of Clinical Psychology (CUDCP)CUDCP agrees with the language of this IR
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRIV. Professional Values and AttitudesKirkSchneider I submit the following revisions to "Profession-wide competencies." My feedback is in capital letters: • P.. 15: Profession-wide competencies o • Consistency with the professional value of scientific practice (SoA Introduction, Section II.B2.d). The CoA expects that all profession-wide competencies will be grounded in the empirical literature and in a scientific orientation toward psychological knowledge and methods (ENCOMPASSING QUALITATIVE AND SINGLE CASE METHODS). THESE COMPETENCIES INCLUDE EVIDENCE-BASED THERAPY RELATIONSHIPS (WHICH STRESS THE ALLIANCE, EMPATHY, RUPTURE REPAIR, AND COLLECTING FEEDBACK). THEY ALSO REQUIRE EXPOSURE TO A BROAD ARRAY OF EMPIRICALLY BASED THEORETICAL ORIENTATIONS.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsBrandonGibb I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsBrandonGibb I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsMartitaLopez I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsMichellePaul I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsKathleenSikkema I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsSherrylGoodman I fully support the responses submitted by CUDCP and APCS.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsLanceSwenson I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsScottChurchill  Section V. indicates as one of its directives: "Develop and maintain effective relationships with a wide range of individuals receiving professional services, colleagues, organizations, professions, and communities." I would like to suggest that some of the evidence-based aspects of professional practice go beyond "interventions" [see section VII] and include the "effective relationships" named in section V. Perhaps we need to include reference in Section V. to the evidence-based criteria on which therapeutic relationships are based? (Or else, include in Section VII. that both "interventions" and "effective [therapeutic] relationships" are to be grounded in scientific evidence, where "scientific" is not reduced to the more limited literature of RCT research on operationally-defined interventions (of which one finds plentiful examples in psychopharmacological and CBT research on efficacy), but rather includes all forms of research - quantitative as well as qualitative - that has been p... See Full Comment
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsHeidiLevitt I am writing in strong support of the Division 29 statement of concerns.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsJeanCarter It is unclear what either the basis or purpose is for stating that communication and interpersonal skills are grounded in science. It seems a gratuitous introduction of supposed science and neither helpful nor necessary. I would recommended deleting "grounded in science and". We have many other opportunities to include appropriate references to and reliance on science.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsRobertBarrett I support the comments made by NCSPP
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsRajaDavid I endorse the NCSPP response for this section.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsAliciadel Prado I endorse the NCSPP response for all sections.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsTorreyWilson I strongly support the NCSPP recommendations.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsHeatherSheets "I endorse the NCSPP response for all sections."
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsHeatherSheets "I endorse the NCSPP response for all sections."
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsAlisaManulkin I endorse the NCSPP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsThomasKubiszynCRSPPPCRSPPP appreciates CoA’s development of the proposed IRs. CRSPPP believes that the proposed IRs provide important specificity and guidance that doctoral, internship and postdoctoral programs need to enhance professional health service psychology training. That guidance should also prove helpful in enabling more focused preparation for the adoption of the SoA in 2016. CRSPPP also recognizes that the proposed IRs, like any attempt to address complex, evolving and important professional training issues, will invariably prove controversial, include unintended consequences, and defy universal approval. Nevertheless, CRSPPP believes that the proposed IRs, once public comments have been considered, will benefit the public and the profession.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsBradRoperSociety for Clinical Neuropsychology (Div. 40), representing 4,330 membersThis competency does not appear to apply to the postdoc level, and that needs to be clarified.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsJeffreyGoodie I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsLeeCooper I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsBeckyReady I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsBeckyReady I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRV. Communication and Interpersonal SkillsKarinMcCoy The requirement that doctoral and internship level trainees are "able to produce and comprehend verbal, nonverbal, and written communications.." appears to ignore that some communication methods might not be available/used by individuals with disabilities. For example, a trainee who is deaf might not comprehend verbal communications, but this would not preclude the individual from being a successful trainee or psychologist.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentJulieNeJame I agree with statements provided under Assessment.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentBrandonGibb I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentMartitaLopez I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentTonyCellucciAPTCUnder assessment competence, APTC wonders if it would be helpful to discuss expectations by level of training or further state how diversity characteristics should be considered in assessment (e.g., selection, interpretation of instruments).
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentMichellePaul I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentJeffreyGoodie I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentKathleenSikkema I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentSherrylGoodman I fully support the responses submitted by CUDCP and APCS.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentLanceSwenson I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentKristenJezior I endorse comments made by APCS.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentAliciadel Prado I endorse the NCSPP response for all sections.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentKimberlyHays I endorse the comments offered by ACCTA
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentKimberlyHays I endorse the comments made by ACCTA
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentRobertBarrett I support the comments made by NCSPP
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentRajaDavid I endorse the NCSPP response for this section.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentTorreyWilson I strongly support the NCSPP recommendations.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentHeatherSheets "I endorse the NCSPP response for all sections."
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentBradRoperSociety for Clinical Neuropsychology (Div. 40), representing 4,330 membersThis competency refers to “trainees” generically. It is not included as a Level 1 competency in the postdoc SoA. As such, it does not necessarily apply to postdoc programs, although that is not clear in the section.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentAlisaManulkin I endorse the NCSPP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentThomasKubiszynCRSPPPCRSPPP appreciates CoA’s development of the proposed IRs. CRSPPP believes that the proposed IRs provide important specificity and guidance that doctoral, internship and postdoctoral programs need to enhance professional health service psychology training. That guidance should also prove helpful in enabling more focused preparation for the adoption of the SoA in 2016. CRSPPP also recognizes that the proposed IRs, like any attempt to address complex, evolving and important professional training issues, will invariably prove controversial, include unintended consequences, and defy universal approval. Nevertheless, CRSPPP believes that the proposed IRs, once public comments have been considered, will benefit the public and the profession.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentAmyWilliams I endorse ACCTA's comments
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentChristinaCarroll-Pavia I endorse ACCTA’s response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentJulieCorkery I support ACCTA's response to the Assessment IR.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentEdelynVerona I support Mitch Prinstein's comment on behalf of SSCP.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentLeeCooper I agree with the CUDCP response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentAlliAnderson I endorse ACCTA’s response.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentBeckyReady I agree with the CUDCP response
Implementing Regulations for Public Comment Phase IProfession-Wide Competency IRVI. AssessmentLindaScott I am in support of the recommendations outlined by ACCTA.
Implementing Regulations for Public Comment Phase IProfession-Wide Competency