Accreditation Public Comment System





This project is now closed for new comments.
DocumentSectionItemFirst NameLast NameGroup NameComment 
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Internship ProgramsMiltonFuentes I support NCSPP’s responses.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Internship ProgramsRobertPerl I support the NCSPP comment.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Internship ProgramsTestTestTest Group ATest Test Test
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Internship ProgramsHidekoSera  NCSPP endorses this IR.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Internship ProgramsLeahHorvath I support NCSPP's responses for all 7 IRs.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Internship ProgramsBradRoperSociety for Clinical Neuropsychology (Division 40)The Society for Clinical Neuropsychology welcomes the opportunity to comment on the draft implementing regulations. This IR appears to be quite similar to the IR for the same purpose within the G&P, and SCN supports it.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Internship ProgramsheatherSheets I support NCSPP’s responses for all 7 IRs
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Internship ProgramsTorreyWilson I support the NCSPP's position regarding the IR.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Internship ProgramsStephanieWood I support NCSPP's responses for all 7 IR's.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Internship ProgramsSteveDeMersASPPBASPPB continues to be appreciative of the time, effort and collaboration that CoA has exhibited throughout the current revision process. As you know, we support collaboration of all major psychology professional associations as this advances public protection. Thank you for continuing to include us in this important discussion of implementing regulations for the new SoA. We hope you find our comments helpful. “Accredited on Contingency” Status for Internship and Postdoctoral Programs ASPPB supports CoA’s IR for “Accredited, on contingency” for both Internship and Postdoctoral programs. The definitions that this is an accredited status “if and only if the program meets all standards except for the inclusion of all required outcome data on interns/residents in the program and after program completion” is clear and as such will assist licensing boards in their work. The amount of time that programs can be in the status “accredited, on contingency” seems appropriate to us. The... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Internship ProgramsDonnaJohnson I support NCSPP’s responses for all 7 IRs.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Internship ProgramsAnnemarieSlobig I agree with the NCSPP comments
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Internship ProgramsEddyAmeenAPAGS (Amer. Psych. Assoc. of Graduate Students)APAGS is pleased to comment on the Implementing Regulations (IRs) for the Commission on Accreditation. Consistent with our comment during Phase I, APAGS is supportive of the recommended changes to the IRs; however, we have some recommendations, listed below, that we feel would improve the IRs and their implications for the training experiences of our constituents. For the “Accredited, on Contingency” IRs for both Internship and Postdoctoral Programs, there should be a requirement that programs with an “Accredited, on Contingency” status convey the implications of that status to prospective and current students (e.g., whether “Accredited, on Contingency” qualifies as full accreditation; whether this status is a testament to program quality; whether graduates of the program can claim they completed an accredited internship; whether attending a contingently accredited program would affect their eligibility for certain postdoctoral residencies, specifically those within the VA system). ... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Internship ProgramsLindaCraighead The IR needs to specify this time line better and what is required when- esp re a two year half time program the current IRs say the date of accreditation is the date of the site visit (retroactively after it is approved)- The procedure for the on contingency program to apply for full is not clear- do they just send in the outcome data or do they submit a whole new self study- do they have another site visit two years after the initial one? it is very confusing if that still the case and the accredited time is only two years, the program will have to start the second self study almost as soon as it is accredited on contingency???? what happens with interns who are enrolled in the program if it does not meet standards at that second self study does it go on probation or accreditation revoked? do they have a chance to respond and make changes- how does that work within the time frame can those students who started it while it was accredited complete it as accredited how w... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Postdoctoral ProgramsMiltonFuentes I support NCSPP’s responses.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Postdoctoral ProgramsRobertPerl I support the NCSPP comment.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Postdoctoral ProgramsTorreyWilson I support the NCSPP position on this IR.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Postdoctoral ProgramsHidekoSera NCSPP endorses this IR.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Postdoctoral ProgramsBradRoperSociety for Clinical Neuropsychology (Division 40)This IR appears to be quite similar to the IR for the same purpose within the G&P, and SCN supports it.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Postdoctoral ProgramsheatherSheets I support NCSPP’s responses for all 7 IRs
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Postdoctoral ProgramsSteveDeMersASPPBASPPB supports CoA’s IR for “Accredited, on contingency” for both Internship and Postdoctoral programs. The definitions that this is an accredited status “if and only if the program meets all standards except for the inclusion of all required outcome data on interns/residents in the program and after program completion” is clear and as such will assist licensing boards in their work. The amount of time that programs can be in the status “accredited, on contingency” seems appropriate to us. The requirement that interns, residents and the public “must be kept informed of any change in the program’s timeline that could negatively impact accreditation” and that programs “must publish the date of expiration of the status in its public materials” will also assist our member boards in their assessment of applications for licensure. It may be helpful to further elucidate how programs will inform the public of any change in their timeline that could negatively impact accreditation. We would... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Postdoctoral ProgramsAnnemarieSlobig I agree with NCSPP's comments
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIAccredited on Contingency IR for Postdoctoral ProgramsEddyAmeenAPAGS (Amer. Psych. Assoc. of Graduate Students)For the “Accredited, on Contingency” IRs for both Internship and Postdoctoral Programs, there should be a requirement that programs with an “Accredited, on Contingency” status convey the implications of that status to prospective and current students (e.g., whether “Accredited, on Contingency” qualifies as full accreditation; whether this status is a testament to program quality; whether graduates of the program can claim they completed an accredited internship; whether attending a contingently accredited program would affect their eligibility for certain postdoctoral residencies, specifically those within the VA system). We highly encourage CoA to be diligent in making the differences between various program statuses as clear as possible to students. For both the “Intent to Apply” and “Accredited, on Contingency” Implementing Regulations, students would benefit from understanding what occurs if the program does not apply for accreditation or achieve full accreditation within the tw... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRShannonLynch I support comments from COGDOP regarding the discipline specific knowledge IR and faculty qualifications IR.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRGeorgeRonan I support the CUDCP comment.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRMiltonFuentes I support NCSPP’s responses.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRMichaelNadorff I support the CUDCP comment.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRJenniferCallahanUniversity of North Texas Clinical Psychology Doctoral ProgramWe support the CUDCP comment.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRRadhikaKrishnamurthy I support the NCSPP comment.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRBrandonGibb I support the CUDCP comment.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRDianeBlau I support NCSPP's statements.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRRebeccaReady I support the CUDCP comments.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRdeannabarch I support the comments made by COGDOP.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRTimCavell I support the CUDCP comment.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRRobertPerl I support the NCSPP comment.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRKennethSolberg While not part of the final IR, I find FAQ #3 problematic in view of current research and theory in neuroscience. Cognition and affect are viewed as heavily interconnected, and much current research considers both in the same study. To say that cognition and affect are "separate domains of inquiry" is simply not accurate anymore.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRJorgeVarela I first would like to thank the members of CoA for their efforts in developing and disseminating training standards for our field. At this point, the Discipline Specific Knowledge section for doctoral programs remain ambiguous and training programs are still left wondering how to meet these requirements. What does advanced integrative knowledge mean? How much integration is necessary? Which components? I appreciate CoA does not want to be overly prescriptive, but examples will be necessary here as well as further clarification.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRJeffreyGoodie I support the CUDCP comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRBethBoyd I agree with the CUDCP comment.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRHamLindsay I support the CUDCP comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRLeeCooper I support the CUDCP comment.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRPaulKwon I support the CUDCP comment.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRJohnCurry I agree with the CUDCP statement. It is critical that CoA make clear that the two levels of discipline-specific knowledge do not represent a new requirement for even more courses. This is not clear in the current draft, which could be interpreted as requiring that programs do BOTH of the following: 1) either accept from demonstrated undergraduate proficiency (e.g., GRE scores)or provide basic doctoral level courses; AND ALSO 2) provide doctoral level integrative courses. On a different point, given the historical tendency of CoA and of licensing boards to reify and then "require a course in" every single term that is included in an IR paragraph, it will be important to clarify that not every single term included as examples under such required areas as "research design" or "quantitative methods" must be covered by every program in its curriculum. This seems to be the intent of the CoA, but it was also the intent in the last comprehensive revisions of the G & P and the intent got co... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRTorreyWilson I support the NCSPP comments/position on this IR.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRDeborahBeidelCouncil of University Directors of Clinical PsychologyCUDCP would like to offer the following comments with respect to this area: 1. Immediately above the second category of listings of discipline specific knowledge areas, there is an explanatory paragraph. CUDCP believes that this paragraph could create confusion (regarding whether a program would ONLY need to do the basic content areas or must also include education in advanced integrative knowledge). Therefore, CUDCP recommends that the statement be rewritten as follows (with changes highlighted in yellow) The second category of discipline-specific knowledge must be acquired at the graduate level and must result in substantial understanding and competence in the following areas 2. CUDCP recommends that in the last line of the bullet that begins “Advanced Integrative Knowledge…, the word “and” be replaced by the word “or” (i.e., …developmental or social… 3. CUDCP is still concerned that the bullet describing Advanced Integrative Knowledge of Basic Discipline-Specifi... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRCarterJocelynCUDCUPI support the CUDCP comment.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRAmyPeterman I support the CUDCP comment. Thank you.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRDavidPantalone I support the CUDCP comment.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRMichelleSalyers I support the CUDCP comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRSamanthaGregus I support the CUDCP comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRSteveLawyer I continue to be perplexed by the fact that 'Learning' is still not included as a fundamental domain within domain-specific knowledge. Many of the contemporary ESTs our students use include interventions drawn from learning theory. Yet, the new IRs suggest that a clear understanding of learning principles is not important.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRSteveLawyer I support the CUDCP statements.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IROksanaYakushko Many of the "discipline specific" knowledge areas appear to draw primarily from foundations needed for Behavioral or Cognitive-Behavioral approaches to understanding human experience. Specifically, focus on "behavior" in many areas emphasizes that this area of human experience supersedes others, which include human emotional, relational, and spiritual experiences. These area of human functioning not only reflect broader areas of psychology outside of Behavioral and Cognitive Behavioral approaches but specifically reflect experiences of diverse populations and non-Western worldviews. Thus, I would like to encourage the CoA to encourage the language of "human experience" and "human functioning" rather than "behavior" that attends to multiple forms of human experience. In addition, the language of "interventions" is specific to Behavioral and Cognitive Behavioral approaches exclusively and thus shows very open prejudice and exclusion of those approaches that do not see clinical work with ... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRLindaCraighead I support the CUDCP comments As I understand the goal of the IR grad level training in each of the 5 areas must be provided and be documented for each student but it no longer needs to be quite as clearly "Broad and general" so it can occur in highly integrated coursework and other types of training but this is only IF prior undergrad work or GRE scores indicate some general level of knowledge has already been acquired (and otherwise programs must continue to demonstrate broad and general coverage of the areas however as I read these regulations that is not clear to me If this IF has been articulated in the regulation, it is not very obvious so I think it is still going to create misunderstanding so I hope that some wording might state that more clearly or be clearer just how broad of coverage of the areas at the grad level is going to be required. I think this issue is very confusing and will promote very uneven judgements from site visitors and ensuing chaos as DCTs try to... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRBethanyTeachman I support the CUDCP comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRKathleenSikkema I support the CUDCP comments.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRRobertCarels I support the CUDCP comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRGregoryMiller I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRMeghanVinograd I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRHidekoSera As reflected in comments offered in Phase I, NCSPP appreciates CoA’s detailed description of expectations for discipline-specific knowledge. However, NCSPP also strongly suggests that some of the language related to the demonstration of discipline-specific knowledge is ambiguous. As currently worded, the IR 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 are of the opinion that the delineation as proposed is unnecessary and uneven. It clearly sets two different standards for level of knowledge acquisition. Therefore, NCSPP proposes eliminating subsections i and ii of this section and amending section (a) to establish a single, universal standard that reads as follows: a)…represent... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRMartitaLopez I support the CUDCP comment.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRMonicaCarsky I support the D 32 recommendations.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRKarenGuan I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRHeidiLevitt I am writing to support the comments of Division 32 and 29. In addition, I am adding the following note of support for the inclusion of educational standards on both qualitative methods and the epistemological bases of varying approaches to psychological research methods: Researchers and psychologists often are confused about what types of research constitute evidence and fall under the rubric of empiricism. The use of qualitative methods has been growing in psychology over the last forty years – as noted by their increased publication in journals (summarized in Ponterotto, 2013; Gergen, Josselson, & Freeman, 2015) and the recent change in the name of APA’s Division 5 to Quantitative and Qualitative Methods. These methods have been in use in psychology since its inception and are already status quo (Wertz, 2014). Since the 1980s, the use of qualitative methods is increasing each year manifold and interest in mixed methods. This acceptance also has been indicated by the endorsem... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRDianeBlau Qualitative research models and methodology are essential for all psychologists to understand and apply, especially as "evidence based" practice evolves as foundational for clinical competence. Quantitative methodology does not adequately cover, describe or explicate the spectrum of human experience open to qualitative ways of knowing. Qualitative research meets rigorous research standards of trustworthiness and credibility and should also represent the science of psychology, e.g. the study of human experience. Qualitative research models and methodology should be included as a curricular requirement in doctoral education for psychologists.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRheatherSheets I support NCSPP’s responses for all 7 IRs
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRBarryDauphin I support John Norcross' comment.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRCarolynDavies I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRJulieKochCouncil of Counseling Psychology Training ProgramsThe Council of Counseling Psychology Training Programs (CCPTP) Board would like to thank the Commission on Accreditation for their diligence in providing Implementing Regulations that are clearly written and helpful to Directors of Training of counseling psychology training programs. We would also like to commend the CoA on their attention to issues of diversity and addressing the importance of inclusion. We also continue to have some concerns about the Implementing Regulations, which we delineate below. 1.) We continue to be concerned by the suggestion that GRE subject tests are an appropriate measure that can be used to assess discipline specific knowledge. Does the CoA have evidence that the GRE subject tests do not differentiate by either their slopes or levels on the basis of social or demographic factors (race, gender, etc.)? We have not found any information of this sort on the GRE subject tests to be readily available. This makes it difficult to determine whether GRE subject ... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRBradRoperSociety for Clinical Neuropsychology (Division 40)The Society for Clinical Neuropsychology strongly supports this IR, for reasons detailed in our response to Phase I public comment.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRSteveDeMersASPPBASPPB appreciates your acknowledgement and concern that the demonstration of student competencies be clearly communicated with regard to prerequisite coursework. (i.e., If a program elects to use students’ prior education or experiences to partially satisfy discipline-specific knowledge requirements, the program must also document how each student demonstrates graduate-level understanding and competence in the relevant content.) ASPPB remains concerned, however, about how discipline specific knowledge and competencies will be documented and communicated so that it is clear to licensing boards. At this point, it appears that a student could graduate from an APA-accredited program but not be license eligible because the documentation of needed knowledge/competencies that weren’t obtained during graduate training are not clearly identified as having been met. Or, if someone does obtain a license, he or she might not be mobile if it cannot clearly be demonstrated how graduate level com... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRAndreaClements I support COGDOP recommendations.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRMargaretBauer I support the COGDOP statement
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRLindsayStaples I support the COGDOP statement
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRWallaceDixonCOGDOP The Council of Graduate Departments of Psychology finds highly troubling that its comments regarding the Round 1 version of the DSK IR went unheeded. Furthermore, in our view, at least one of the revisions has made the IR worse. We reiterate our positions below. We also highlight how the revised IR has been made worse, and we note in this round two new concerns. We first address the change that made the IR worse, and then turn to our new understandings of the Round 1 IR language. The revised IR now includes a clause that specifies that the purpose of DSK is to allow students to “apply psychological principles in their health services psychology work.” This IR comes dangerously close to specifying that programs will now need to demonstrate HOW DSK is used in Health Service Psychology. If CoA doesn’t intend this interpretation, it should remove it or clarify further. If CoA does intend this interpretation, then COGDOP opposes strongly this goal of DSK training. COGDOP holds ... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRSuzanneMeeks I support the COGDOP comments on this IR.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRKevinArnoldCouncil of Specialties in Professional PsychologyThe Council of Specialties in Professional Psychology (CoS) thanks CoA for all its hard work to ensure the quality of health service psychologists through education and training standards and program accreditation. CoS wishes to bring to CoA's attention to its failure to adopt the standard language when referring to essentially what are specialties in professional psychology. In two instances, on pages 6 and 15, the term used is "substantive area(s) of practice." CoS believes that adopting the same terminology used by APA, CoS, and other organizations will reduce confusion on the part of the public (including students), and CoS respectfully offers that the use of any phrase other than "specialty" in fact creates confusion, leading to less (rather than more) protection of the public. CoS recommends that CoA adopt the term "specialty" when it refers to specialties within the IRs.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRAnnemarieSlobig I agree with NCSPP's comments
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRLaurenHarris I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRToddBrown I support the COGDOP statement
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRKellyCourtney I fully support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRCindyYee-Bradbury I support the statement submitted by COGDOP.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRSpencerBujarski I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRJenniferGamarra I support the COGDOP statement
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRKevinArnoldCommission for the Recognition of Specialties and Proficiencies in Professional PsychologyThe Commission for the Recognition of Specialties and Proficiencies in Professional Psychology (CRSPPP) thanks CoA for all its hard work to ensure the quality of health service psychologists through education and training standards and program accreditation. CRSPPP wishes to bring to CoA's attention our continued position that CoA should incorporate the term "specialty" when referring to education and training, and incorporate only CRSPPP recognized specialties. In two instances, on pages 6 and 15, the term "substantive area(s) of practice" is used. Using the term “specialty” would reduce the public’s confusion (including that of students). CRSPPP is concerned that the use of any phrases other than "specialty" increases confusion, leading to less (rather than more) protection of the public. CRSPPP respectfully recommends that CoA adopt the term "specialty" when it refers to specialties within the IRs.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRReadJoan Support NCSPP position
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRBruceChorpita I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IREddyAmeenAPAGS (Amer. Psych. Assoc. of Graduate Students)APAGS strongly advocates for the removal of the e.g. statement that lists the GRE subject test as a method for evaluating discipline specific knowledge. The GRE historically has stood as a barrier for students of underrepresented backgrounds seeking to enter the field of psychology. Listing the GRE subject test as the only example of competency evaluation only increases the chances of its use as a gatekeeper (which CoA alludes to in the FAQ appended to this IR), whereas leaving it out entirely does not adversely affect the quality of the IR as written.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRConstanceHammen I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRCatherineFiorello I support comments from COGDOP regarding the discipline specific knowledge IR.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IREddyAmeenAPAGS (Amer. Psych. Assoc. of Graduate Students)A second comment from APAGS for this IR: Programs should be required to demonstrate to students and prospective students how their program meets licensure requirements, at least in the jurisdiction where the program is located. We recommend this requirement based on the potential for students not to get licensed if/when a licensing board does not count undergraduate coursework as qualifying for knowledge in a discipline specific domain, despite their graduate program allowing these courses to fulfill program requirements.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRRuthellenJosselson Qualitative inquiry has been central to the history of important ideas in psychology and, despite its falling into disfavor in the rush to quantification, it is enjoying a major renaissance with its recognition as a method by Division 5 and the inception of the Qualitative Psychology journal. As these methods are often consonant with the epistemological approaches within clinical psychology, I would advocate that they be taught - and required - on a par with quantitative methods.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRDavidSbarra I support the COGDOP statement
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRLindaCraighead I agree with the COGDOP comments on the IR
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRBitaMesri  support the COGDOP statement
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRMichelleFenesy I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRDanielleKeenan-Miller I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRKristenJezior I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRJuliaHammett I support the COGDOP statement
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRElizabethDalton I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRAlaynaPark I support the COGDOP statement
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRAnnaLau I support the COGDOP statement
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRAnnaLau I support the COGDOP statement
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRHalinaDour I support the COGDOP statement
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRCompasBruce I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIDiscipline Specific Knowledge IRThomasBradbury I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRMiltonFuentes I support NCSPP’s responses.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRDianeBlau I support NCSPP's statements.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRJulieKochCouncil of Counseling Psychology Training ProgramsWe would like to encourage the CoA to include some kind of assessment of faculty multicultural competence or for faculty to provide evidence of how multicultural/diversity issues are integrated into the courses they teach.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRRobertPerl I support the NCSPP comment.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRRadhikaKrishnamurthy I support NCSPP's comments concerning this IR.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRTorreyWilson I support the NCSPP comments/position on this IR.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IROksanaYakushko It is vital that faculty within each institutions represent not only diverse backgrounds but also diverse theoretical perspectives and training. Each program must ensure that students receive training from faculty that do not represent monocultural perspectives.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRKarenFondacaroAPTCOn behalf of the APTC (Association of Psychology Training Clinics), I thank you very much for the opportunity to comment on the Standards of Accreditation for Health Service Psychology. We believe the standards are clear, concise, and very thorough - and we applaud the excellent work that went into creating this document. We have one area of concern related to "Faculty Sufficiency" where it is stated on p.20, that "at least one member of the core faculty needs to hold professional licensure as a psychologist to practice in the jurisdiction in which the program is located." As currently written, this allows for all but 1 core faculty member to be unlicensed or licensed in another jurisdiction. We believe that at least 25% of core faculty being licensed in the jurisdiction where the program is located is a more reasonable (though minimal) standard to meet the expectation established regarding faculty sufficiency to supervise students' clinical practice. Thank you in advance f... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRGregoryMiller I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRHidekoSera NCSPP is concerned that the definition of faculty qualifications implies that only those individuals with formal doctoral or postdoctoral training in a given content area are qualified to teach subjects related to that content area (e.g., that a faculty member with clinical training is unqualified to teach in content areas such as social or experimental psychology -- even with continuing education in this area). To avoid such narrow interpretation of faculty qualifications, NCSPP strongly recommends revising the final sentence of this IR as follows (emphasis added): That evidence should include: (a) current and relevant expertise (e.g., ongoing professional development, research productivity, systematic study, clinical competence, professional credential); AND/OR (b) appropriate training (e.g., academic degree/area of study, respecialization, formal or other relevant post-doctoral training).
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRReadJoan Support NCSPP position
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRheatherSheets I support NCSPP’s responses for all 7 IRs
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRWallaceDixonCOGDOPCOGDOP believes that the IR on Faculty Qualifications fails to adequately define and ultimately kicks the can down the road to the program review process, which is an invitation for confusion on the part of programs and inconsistency in CoA review. Given current wording, programs would have to provide evidence of BOTH “current and relevant expertise” AND “appropriate training” for all faculty relative to their roles in the program.  How does one become qualified to teach advanced history and systems?  Or Research Methods?   If you are a practicum coordinator or DCT (or department chair for that matter), where do you get the appropriate training for serving in this administrative role overseeing the program? Although faculty qualifications are clearly essential, what the language in the present IR requests is both vague and infeasible.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRCarolynDavies I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRBradRoperSociety for Clinical Neuropsychology (Division 40)The CoA is reminded that many internship and postdoctoral programs refer to staff as “faculty.” The CoA therefore may wish to clarify that this IR applies only to the doctoral level of training.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRSteveDeMersASPPBWe would suggest the addition of “…professional credential and/or licensure” (for faculty that teaches or supervises in applied settings/courses) in paragraph 2, (a). Again, thank you for the opportunity to comment on these IRs. We applaud CoA’s work in this needed update of the accreditation requirements.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRAndreaClements I support COGDOP recommendations.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRMargaretBauer I support the COGDOP statement
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRLindsayStaples I support the COGDOP statement
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRSuzanneMeeks I support the COGDOP comments on this IR.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRSuzanneMeeks I support the COGDOP comments on this IR.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRLaurenHarris I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRKellyCourtney I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRSpencerBujarski I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRKevinArnoldCouncil of Specialties in Professional PsychologyThe Council of Specialties in Professional Psychology (CoS) thanks CoA for all its hard work to ensure the quality of health service psychologists through education and training standards and program accreditation. On page 10, there is a series of examples of how faculty can provide evidence of "current relevant expertise." CoS has a position that the American Board of Professional Psychology is its recognized credentialing body to document specialists with specialty competencies. CoS respectfully recommends that the series of examples, following the "e.g.," include board certification from ABPP. CoS again believes that reliance on ABPP Board Certification would further the protection of students by ensuring that credentialing is seen as evidence of "relevant expertise."
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRKevinArnoldCommission for the Recognition of Specialties and Proficiencies in Professional PsychologyThe Commission for the Recognition of Specialties and Proficiencies in Professional Psychology (CRSPPP) thanks CoA for all its hard work to ensure the quality of health service psychologists through education and training standards and program accreditation. In addition to our other comments, on page 10, there is a series of examples of how faculty can provide evidence of "current relevant expertise." CRSPPP respectfully recommends that the series of examples, following the "e.g.," include board certification in a CRSPPP recognized specialty. CRSPPP believes that use of established credentialing as an example of “relevant experience” would further the protection of students, since doing so would incorporate competency-based evidence of expertise.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRReadJoan Support NCSPP position
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRBruceChorpita I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRJenniferGamarra I support the COGDOP statement
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRCatherineFiorello I support comments from COGDOP regarding the faculty qualifications IR.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRCindyYee-Bradbury I support the statement submitted by COGDOP.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRLindaCraighead I agree with the COGDOP comments on the IR
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRAnnemarieSlobig I agree with NCSPP's comments.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRDavidSbarra I support the COGDOP statement
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRBitaMesri I support the COGDOP statement
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRMichelleFenesy  I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRDanielleKeenan-Miller I support the COGDOP statement. The standards as written are vague and infeasible with regards to how expertise and training for each role would be substantiated.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRKristenJezior I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRJuliaHammett I support the COGDOP statement
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRElizabethDalton I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRAlaynaPark I support the COGDOP statement
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRAnnaLau I support the COGDOP statement
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRHalinaDour I support the COGDOP statement
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRCompasBruce I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIFaculty Qualifications IRThomasBradbury I support the COGDOP statement.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIIntent to Apply IR for Internship ProgramsTimothyShea I think these changes will be a positive change. It will be important that the terms are clearly explained and easily found/posted so students going through the internship application process can make an informed decision about a site.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIIntent to Apply IR for Internship ProgramsMiltonFuentes I support NCSPP’s responses.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIIntent to Apply IR for Internship ProgramsRobertPerl I support the NCSPP comment.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIIntent to Apply IR for Internship ProgramsTorreyWilson I support the NCSPP Comments/position on this IR.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIIntent to Apply IR for Internship ProgramsHidekoSera NCSPP endorses the CoA’s IR for Intent to Apply for Internship Programs.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIIntent to Apply IR for Internship ProgramsheatherSheets I support NCSPP’s responses for all 7 IRs
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIIntent to Apply IR for Internship ProgramsAnnemarieSlobig I agree with NCSPP's comments.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIIntent to Apply IR for Internship ProgramsEddyAmeenAPAGS (Amer. Psych. Assoc. of Graduate Students)Students would benefit from understanding what occurs if the program does not apply for accreditation or achieve full accreditation within the two year timeframe. The process should either be explained in more detail within this document or refer the reader to another document that includes such an explanation.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIIntent to Apply IR for Internship ProgramsBradRoperSociety for Clinical Neuropsychology (Division 40)The SCN supports this IR. We believe that “intent to apply” status for internships is important in developing new accredited internship programs. We had significant concerns regarding “intent to apply” status at the doctoral level due what we believe is a greater potential for abuse via claims regarding accreditation at that level.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIIntent to Apply IR for Postdoctoral ProgramsMiltonFuentes I support NCSPP’s responses.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIIntent to Apply IR for Postdoctoral ProgramsRobertPerl I support the NCSPP comment.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIIntent to Apply IR for Postdoctoral ProgramsheatherSheets I support NCSPP’s responses for all 7 IRs
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIIntent to Apply IR for Postdoctoral ProgramsHidekoSera NCSPP endorses the CoA’s IR for Intent to Apply for Postdoctoral Programs.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIIntent to Apply IR for Postdoctoral ProgramsTorreyWilson I support the NCSPP comments/position on this IR.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIIntent to Apply IR for Postdoctoral ProgramsAnnemarieSlobig I agree with NCSPP's comments.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIIntent to Apply IR for Postdoctoral ProgramsBradRoperSociety for Clinical Neuropsychology (Division 40)The SCN supports this IR. We believe that “intent to apply” status for postdoctoral programs is important in promoting accreditation at the postdoctoral level, especially considering that the large majority of postdoctoral programs are not accredited. We had significant concerns regarding “intent to apply” status at the doctoral level due what we believe is a greater potential for abuse via claims regarding accreditation at that level.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRKeithMagnus I strongly agree with and support ACCTA's comments related to the research competency for interns.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRRadhikaKrishnamurthy I support NCSPP's response for this IR.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRMiltonFuentes I support NCSPP’s responses.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRLouiseBaca I support NCSPP statements on the seven implementing regulations.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRPhilKleespiesDiv. 12 and CCER at Palo Alto UniversityThis comment is being submitted on behalf of the Section on Clinical Emergencies and Crises, Section VII of APA Division 12, and on behalf of the Clinical Crises and Emergency Research Group (CCER) at Palo Alto University and Stanford University. We want to thank the Commission on Accreditation for this opportunity to comment (in Phase II) on the Implementing Regulations for the new Standards of Accreditation for Health Service Psychology (SoA), and particularly on the Implementing Regulation entitled Profession-Wide Competencies. In submitting this comment, we are aware of the previous comments on the importance of suicide risk assessment and management submitted to the Commission on Accreditation on 10/9/12 by William Schmitz, Psy.D., on behalf of the American Association of Suicidology Task Force on Improving Clinical Competency in Suicide Risk Assessment and Management and on 10/10/12 by Daniel Reidenberg on behalf of the National Council for Suicide Prevention. While we concur w... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IREricSchwartz Profession Wide Competencies I. Interns: • Demonstrates the substantially independent ability to critically evaluate and disseminate research or other scholarly activities via professional publication or presentation at the local, regional or national level. I have a concern regarding the language used to describe how doctoral interns can demonstrate this competency; specifically, "via professional publication or presentation at the local, regional, or national level." It is not clear to me who is responsible for finding a venue for the doctoral intern to publish or present while on internship. It is not clear to me if the SoA is suggesting that doctoral interns conduct research while on internship and then attempt to get it published or it truly has to be published to demonstrate competency (or presented this at some venue). What does local mean? What if the interns conduct research at the internship site and presents it to the administration of the agency? Is this local eno... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRKarenLese-FowlerAssociation of Counseling Center Training Agencies (ACCTA)ACCTA strongly believes that the competency to "...disseminate research or other scholarly activities via professional publication or presentation at the local, regional or national level" should be cultivated and mentored at the graduate school level rather than internship. Internship is a direct service experience by design that takes place in direct service agencies where psychologist staff, particularly in counseling centers, are hired with specific focus on direct service and training expertise. In very large proportion, internships are not geared toward training in the area of disseminating research, whereas academic programs are. Further, adding this expectation to the already demanding expectations on interns who are transitioning to full time employment as service providers, completing dissertations in their graduate programs, and acclimating to a new environment for a one year intensive training experience, is an expectation that ACCTA perceives as unreasonable and disproport... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRHeatherNoble As a Training Director, I fully support ACCTA's comment: ACCTA strongly believes that the competency to "...disseminate research or other scholarly activities via professional publication or presentation at the local, regional or national level" should be cultivated and mentored at the graduate school level rather than internship. Internship is a direct service experience by design that takes place in direct service agencies where psychologist staff, particularly in counseling centers, are hired with specific focus on direct service and training expertise. In very large proportion, internships are not geared toward training in the area of disseminating research, whereas academic programs are. Further, adding this expectation to the already demanding expectations on interns who are transitioning to full time employment as service providers, completing dissertations in their graduate programs, and acclimating to a new environment for a one year intensive training experience, is an expec... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRMollieHermanACCTAI strongly agree with and support the statement below drafted by ACCTA: ACCTA strongly believes that the competency to "...disseminate research or other scholarly activities via professional publication or presentation at the local, regional or national level" should be cultivated and mentored at the graduate school level rather than internship. Internship is a direct service experience by design that takes place in direct service agencies where psychologist staff, particularly in counseling centers, are hired with specific focus on direct service and training expertise. In very large proportion, internships are not geared toward training in the area of disseminating research, whereas academic programs are. Further, adding this expectation to the already demanding expectations on interns who are transitioning to full time employment as service providers, completing dissertations in their graduate programs, and acclimating to a new environment for a one year intensive training experi... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRJenCrockett I appreciate that the Profession-Wide Competencies IR contains separate expectations for doctoral students and interns for Research, Supervision, and Consultation. It would be helpful if separate expectations existed for Graduate Programs and Internships for Assessment and Intervention. I understand that there is the expectation for increasing levels of independence and complexity, but the MLAs for each will be a challenge to define, observe, measure when the core competencies are the same.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRPamelaMiller I. Research Interns: Demonstrates the substantially independent ability to critically evaluate and disseminate research or other scholarly activities via professional publication or presentation at the local, regional or national level. Regarding this research competency, I would like to submit my agreement with the comment submitted by ACCTA (Association of Counseling Center Training Agencies), which states: ACCTA strongly believes that the competency to "...disseminate research or other scholarly activities via professional publication or presentation at the local, regional or national level" should be cultivated and mentored at the graduate school level rather than internship. Internship is a direct service experience by design that takes place in direct service agencies where psychologist staff, particularly in counseling centers, are hired with specific focus on direct service and training expertise. In very large proportion, internships are not geared toward training in ... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IROksanaYakushko The language of this IR must be examined for the bias toward Behavioral and Cognitive Behavioral approaches as well as natural science (quantitative) perspectives exclusively. "Interventions" as well as the language of "evidence" does not show equal valuing of multiple theoretical views and practices in psychology. Even though practices outside of Behaviorism and Cognitive Behaviorism are indeed effective and "evidence based," until students, interns, and practicing psychologists are trained and informed of values of other approaches (including significant data supporting them), the language included in this IR will continue to privilege the Behavioral/Cognitive-Behavioral practices at the exclusion of others. This systematic suppression of diverse theoretical perspectives is now shown through evidence (see multiple articles in the monoculture in accredited programs). This IR has to be reviewed by theorists and representatives of multiple other theoretical orientations. In addition, th... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRRobertPerl I support the NCSPP comment.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRTriciaHanley As a training director at a university counseling center, I strongly support ACCTA's statement: ACCTA strongly believes that the competency to "...disseminate research or other scholarly activities via professional publication or presentation at the local, regional or national level" should be cultivated and mentored at the graduate school level rather than internship. Internship is a direct service experience by design that takes place in direct service agencies where psychologist staff, particularly in counseling centers, are hired with specific focus on direct service and training expertise. In very large proportion, internships are not geared toward training in the area of disseminating research, whereas academic programs are. Further, adding this expectation to the already demanding expectations on interns who are transitioning to full time employment as service providers, completing dissertations in their graduate programs, and acclimating to a new environment for a one year int... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRKirkSchneider I acknowledge and appreciate CoA’s responsiveness to multiple comments about the proposed initial IRs, specifically, (1) the inclusion of evidence-based therapy relationships, (2) clarification that students must be exposed to a broad array of theoretical systems, and (3) greater attention to qualitative research methodologies. These improvements indicate a receptivity to multiple ways of conceptualizing and conducting psychological services but, in my view, there is more that needs to be both clarified and addressed. See revisions in capital letters and bold within brackets (except for references and portion on qualitative methodology which are in bold only): 1. VII. PSYCHOTHERAPY PROCESSES [DELETEIntervention] This competency is required at the doctoral and internship level. Trainees are expected to respond professionally in increasingly complex situations with a greater degree of independence across levels of training. Trainees demonstrate competence in evidence-based [PS... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRJohnNorcrossDivision 29The APA Division of Psychotherapy/Society for the Advancement of Psychotherapy acknowledges and appreciates CoA’s responsiveness to our multiple comments about the proposed initial IRs, specifically, the (1) inclusion of evidence-based therapy relationships, (2) clarification that students must be exposed to a broad array of theoretical systems, and (3) greater attention to qualitative research methodologies. These improvements demonstrate a receptivity to multiple ways of conceptualizing and conducting psychological services and should avoid a divisive fight on the floor of the APA Council of Representatives. At the same time, the APA Division of Psychotherapy respectfully requests two additional revisions: - Revise use of the term “intervention.” It is NOT a neutral, generic term for psychological services outside CBT. One rarely hears or reads psychodynamic, humanistic, experiential, feminist, or multicultural psychologists using “interventions” unless forced to do so. “Int... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRHeidiLevitt I commend CoA for the changes in the IR. I am writing to support the statements made by Division 29 and 32. In addition I am submitting the following statement in support of greater clarity on the meaning of 'evidence' in psychology: Concern #1: When reading the term ‘evidence-based therapy or practice,’ readers might think it refers to the lists of research supported psychological treatments that have been complied by organizations, such as Division 12 of APA. Evidence also can come in the form of the plethora of meta-analyses that show equivalence across major psychotherapy orientations (Wampold & Imel, 2015) as well as across interventions (e.g., Bell et al., 2013). Writings from groups that promote the selection of empirically-based therapies based upon which lists of those therapy orientations that have had the opportunity to and interest in conducting randomized clinical trials (RCTs) often fail to integrate the substantial evidence that shows equivalence across methods, c... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRheatherSheets I support NCSPP’s responses for all 7 IRs
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRHidekoSera NCSPP appreciates the revisions that CoA has made to the initial Professions-Wide Competencies IR and, overall, believes that these changes remove ambiguity and the potential for arbitrary narrowing of competency definitions and/or evaluative methodology. However, there is one area for which NCSPP strongly suggests additional revisions so as to avoid the two conditions indicated above. Specifically: 1. Research a. It is unclear as to how bullet point two (“Conduct research and other scholarly activities”) under the Doctoral students’ section substantively differs from bullet point one, which clearly exemplifies the activities associated with research and other scholarly activities. As such, it is strongly recommended that bullet point two be deleted. b. Bullet point three of the Doctoral students’ section, as currently written, implies that students must publish or present original material as a successful condition for graduation. Given that programs have no jurisdiction ov... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRDianeBlau I support NCSP's statements.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRTorreyWilson I support the NCSPP comments/position on this IR.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRKirkSchneiderDivision 32Division 32 acknowledges and appreciates CoA’s responsiveness to multiple comments about the proposed initial IRs, specifically, the (1) inclusion of evidence-based therapy relationships, (2) clarification that students must be exposed to a broad array of theoretical systems, and (3) greater attention to qualitative research methodologies. These improvements indicate a receptivity to multiple ways of conceptualizing and conducting psychological services but, in our view, there is more that needs to be both clarified and addressed. See revisions in capital letters and bold within brackets (except for references and portion on qualitative methodology which are in bold only): 1. VII. PSYCHOTHERAPY PROCESSES [DELETEIntervention] This competency is required at the doctoral and internship level. Trainees are expected to respond professionally in increasingly complex situations with a greater degree of independence across levels of training. Trainees demonstrate competence in evidenc... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRClaytieDavis IIIAPPIC Board of DirectorsThe Association of Psychology Postdoctoral and Internship Programs (APPIC) represents 760 internship and 178 postdoctoral programs. The APPIC Board of Directors greatly appreciates the opportunity to comment on the proposed Implementing Regulations (IRs) Phase II. Below we offer a few recommendations for the Commission on Accreditation (CoA) to consider. I. Research “Demonstrates the substantially independent ability to critically evaluate and disseminate research or other scholarly activities via professional publication or presentation at the local, regional or national level.” APPIC agrees that the ability to evaluate and produce research is a necessary skill. We ask for clarification regarding what MUST occur during the internship year. For example, if an intern completed their dissertation or presented at a conference prior to beginning the internship year would CoA consider this as meeting the IR? Or does the "demonstration" need to occur during the internship year? V. ... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRJulieKochCouncil of Counseling Psychology Training ProgramsRegarding I. Research: Are students actually required to publish or present at a conference to demonstrate research competence? Given the competitive nature of publishing and getting presentations/posters accepted, this might be challenging to implement. We would like to encourage the CoA to consider other options that would also demonstrate this competency.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRMelanieBaer As an internship director in a practice-oriented behavioral health setting, I strongly support comments that the competency to "...disseminate research or other scholarly activities via professional publication or presentation at the local, regional or national level" should be conducted at the graduate school level rather than internship. Many internships are not part of research institutions. Many practice-oriented internships are able to exist primarily because of their focus on the provision of professional services, where interns help generate revenue that can offset or partially offset the costs of training. To expect research activities and presentations/publications at the professional level (local, regional, national) during internship would disrupt the delicate balance between training costs and revenue generation for many of our sites. I also question how an internship could arrange an experience for each intern to publish or present professionally, unless the presentations ... See Full Comment
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRRebeccaReady Under 'Research' for doctoral students, first bullet point, I recommend removing "or other scholarly activities." Doctoral students should conduct research. It is imperative for the future viability of the field, which will rely on an evidence base. The other scholarly activities are so broadly defined that anything counts and this IR seems meaningless and may ill-prepare students for challenges of evidence-based care, accountability, etc. (Of note, the other scholarly activities do appear to be valuable but I do not think they are an adequate replacement for research.)
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRRebeccaReady I support APA Division 40/Society for Clinical Neuropsychology comments.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRJulieKochCouncil of Counseling Psychology Training ProgramsRegarding VII. Intervention: We continue to have concerns about the requirement of “direct observation” regarding supervision of students. Our concern relates to potentially reducing services available to underserved groups that may be hesitant to be videotaped or settings that may not allow videotapes (such as prisons, schools, court-mandated settings, domestic violence agencies, and assessment settings).
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRReadJoan Support NCSPP position
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRAnnemarieSlobig I agree with NCSPP's comments.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IREddyAmeenAPAGS (Amer. Psych. Assoc. of Graduate Students)With respect to Profession-Wide Competencies, we strongly recommend the addition of advocacy on issues related to the profession, the public welfare, and social justice to the “Professional values and attitudes” subsection. As laid out in our strategic plan, APAGS aims to advance the development of a student leadership culture within psychology, and a constituency competent in advocacy is critical for the success of that aim. In the wake of the Independent Review, our field has the opportunity to reform training practices to better cultivate a professional constituency versed in leadership and good conscience. APAGS thanks the Commission on Accreditation for the opportunity to comment on the IRs. We appreciate the concern that the Commission has for the voice of students and look forward to seeing the new Standards of Accreditation implemented in 2016.
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRTaniaIsraelCommittee on Sexual Orientation and Gender DiversityWe think it is appropriate that "trainees must demonstrate knowledge, awareness, sensitivity, and skills when working with diverse individuals and communities who embody a variety of cultural and personal background and characteristics." We support the expectation that trainees demonstrate “the ability to work effectively with individuals whose group membership, demographic characteristics, or worldviews create conflict with their own.”
Implementing Regulations for Public Comment Phase IIImplementing Regulations for Public Comment Phase IIProfession Wide Competencies IRBradRoperSociety for Clinical Neuropsychology (Division 40)“GENERAL AREAS”: Under the "Level-appropriate training" bullet point, we note that specific mention is made of postdoctoral training as providing advanced preparation for practice within specialties. We support clear distinctions regarding specialty training at the postdoctoral level. However, this section makes reference to "general areas of HSP" as distinct from specialties, and it is unclear what those "general areas" are. The SoA's scope of accreditation at the postdoctoral level references a) "developed practice areas," b) a focus area within one or more developed practice area(s), and c) a recognized specialty area. Nowhere in the SoA is there reference to "general areas" of HSP. (There is reference to “advanced general or specialty area practice” buried in the AOP under 8.P, but the distinction is not defined.) The CoA may wish to clarify the language within this draft IR, perhaps using "developed practice areas" rather than "general areas." One question to consider is whether o... See Full Comment