Accreditation Public Comment System





This project is now closed for new comments.
DocumentSectionItemFirst NameLast NameGroup NameComment 
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsMarkLumley Under 1 a, should there be an "or" between i and ii ? (under disclipline specific knownledge) that is, a program has to do either 1.a.i or 1.a.ii currently it reads as if Both are required.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsRobertPerl I support all comments made on behalf of NCSPP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsKathleenAshton I appreciate the CoA's work on this issue and overall agree with the document. I believe collecting outcome data on training programs is a valuable addition for programs, trainees, and the public. I would suggest that more specific guidelines and/or examples for assessing competencies be provided.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsLeahHorvath I agree with the NCSPP comments/responses.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsStephanieWood I support all comments made on behalf of NCSPP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsRyanSharma I appreciate the CoA's work on this issue. My biggest qualm with both this version and the previous that applied to the G&P is that there appears to be some conflation between program outcomes and MLAs. The second statement in this IR highlights this conflation: program outcomes and proof of student attainment serve divergent functions. MLAs, in my opinion, are really for policing programs in graduating only students that attain the expected levels of professional competency. I understand and agree with this. Program outcomes, on the other hand, is for systemetizing the feedback that would be used in any program evaluation, such that the feedback would be used to make program improvement decisions. You cannot use MLAs for such program evaluation because if all students will eventually meet MLAs (as programs are directed to do through remediation plans if necessary), then the outcomes will all be 100%. We have resolved to report MLAs and program outcomes separately so that we ... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsMiltonFuentes I support NCSPP's comments and responses.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsBrandonGibb I endorse the comments made on behalf of CUDCP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsBarryTammy I endorse the comments made on behalf of CUDCP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsEllenKoch I endorse the comments made on behalf of CUDCP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsDavidKahn As they are currently written, the implementing regulations contain a general requirement that doctoral programs collect and disclose data that is informative to prospective students and the general public. Given the current need for APA and its affiliates to be as transparent as possible, the implementing regulations need to be specific to ensure that programs are transparent in what they disclose to current students, prospective students, former students, and the general public. In particular, many members of the general public are confused about the levels of training and credentials existing among providers of mental health and psychological services. Since APA has taken the position that the doctoral degree is the entry level degree for the profession and the degree required for independent practice and licensure as a psychologist, doctoral programs should be required to disclose (a) the percentage of program faculty who are licensed as psychologists, (b) the names of the indiv... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsKevinArnoldCouncil of Specialties in Professional PsychologyThe Council of Specialties thanks COA for its hard work on the IRs. We support the IR as written.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsJulieKochCouncil of Counseling Psychology Training Programs BoardStandard II.B.1.a.D. We still disagree with the example of GRE subject tests as a possible way to meet this standard. Until we can see that the GRE subject tests are not biased based on social class, gender, race, or ethnicity, it is unacceptable to offer this as criteria for student selection. We strongly recommend that the wording “e.g., GRE Subject Tests” be removed from this language. Definitions of proximal and distal data. Both definitions are not very specific and are focused more on what not to do. In the definition of proximal data, we are provided with some statements about what the minimum is, but for distal, there is no parallel statement. We are only provided with statements on what is insufficient. It is not clear what might actually be considered sufficient. We recommend the addition of what might be considered sufficient. Level of specificity. This will require some programs to change how they structure courses so that they can assess that students can apply ... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsGraysonHolmbeck I endorse the comments made on behalf of CUDCP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsLindaCraighead I support the CUDCP comments
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsSteveDeMersASPPBASPPB is very appreciative of CoA’s commitment to quality and collaboration in the process of developing the SoA for Health Service Providers and the associated implementing regulations of the SoA. The profession and the public are well served by CoA’s careful attention to process, detail and outcome in the development of the implementing regulations. ASPPB is in support of the IR’s regarding Outcome Data for Doctoral Programs. Overall the document is clear, detailed, and comprehensive. In addition, we want to address key aspects of the implementing regulations that are critically important from a public protection and regulatory viewpoint including: • We support the requirement that “the program must describe how the curriculum builds upon foundational knowledge that may be initially obtained during undergraduate coursework, as indicated by the GREs, with further documentation of how students demonstrate graduate level discipline-specific knowledge.” This will be critically importan... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsHidekoSeraNCSPP (National Council of Schools and Programs of Professional Psychology)NCSPP Recommended Public Comments-Outcome Data for Doctoral Programs There are several key and important elements raised in this IR around which NCSPP recommends additional clarification. Specifically: • On page 1, 1.a.i refers to GRE subject tests. NCSPP agrees that the development of such a test(s) for psychology would be very beneficial. In its absence, however, NCSPP recommends modifying the example slightly to read “GRE subject tests or similar measures,” which will provide greater flexibility in creating appropriate examinations. • On page 2, 1.b.ii specifies the time frame for collection of distal data. However, on page 3, the fourth bullet under Distal data states that "Although CoA does not specify the interval at which distal data should be collected, the interval should be appropriate to allow the program to evaluate its success in promoting expected competencies to determine if changes need to be made, consistent with Standard II.” It is recommended that the pa... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsTremblayGeorge I endorse the comments made by both CUDCP and NCSPP, which appear to be seeking similar clarifications.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsRenePuliattiCalifornia Psychology Internship Council (CAPIC)While we are generally in support of this IR and find it to be a significant step in the right direction, we are concerned about internal inconsistencies with other IR’s, in particular with IR C-17-D (on Expected Internship Placement) and with IR D-4-7(b) (Doctoral Program Achievement Thresholds). This IR calls on accredited programs to use outcome data on all of their students, regardless of whether the internship or postdoc experience was at an APA-accredited site. We believe this is the right standard, which should be applied uniformly across the board in the regulations, including IR C-17-D, which uses a separate standard for non-APA-accredited internships. As mentioned even in this IR and pointed out by colleague Dr. Sharma, program outcomes must be designed to measure and evidence whether the program is achieving its stated aims. Therefore, it seems particularly crucial that these IR’s emphasize that program outcome measurement be directly measuring the doctoral academic... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsBethWildman I endorse the comments made on behalf of CUDCP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsKathleenSikkema I endorse the comments made on behalf of CUDCP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsBethanyTeachman I endorse the comments made on behalf of CUDCP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsAmyPeterman I endorse the comments and suggestions made by CUDCP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsMichaelO'Hara I have reviewed and do endorse the comments made on behalf of CUDCP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsCrystalCollier I support all comments made on behalf of NCSPP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsWatsonDavid I endorse the comments made on behalf of CUDCP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsDeborahBeidel I agree with the CUDCP comments
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsJeffreyGoodie I endorse the comments made on behalf of CUDCP
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsCavellTimCUDCPCUDCP sees merit in proposed Implementing Regulations pertaining to disclosure of outcome data for doctoral training programs. These IRs make explicit some important issues that were not always clearly articulated in previous IRs. Particularly appreciated were the following: 1. Making explicit that requirement that programs should report discipline-specific knowledge (DSK) data only at the proximal level. 2. Clarification of the preferred format (tables) for outcome data and for the types of statistical information to provide. 3. The expectation that data on profession-wide competencies (PWC) should be provided at the level of each of the nine competencies and not at the level of specific elements that comprise each of the PWC competencies. 4. Clarifying what is meant by distal data and specifying the time points for obtaining distal data (i.e., 2 years & 5 years postgraduation). CUDCP did have questions or requests about aspects of the IR that were unclear. These are noted below... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsBonnieKlein-Tasman I endorse the comments made on behalf of CUDCP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsLee AnnaClark I endorse the comments made on behalf of CUDCP. Thank you for your careful consideration of their comments, which were constructed thoughtfully and reflect the views of the CUDCP Board on behalf of its members.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsAmyFiske I endorse the comments made on behalf of CUDCP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsMarkLumley I endorse the comments made on behalf of CUDCP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsMary LouiseCashel I endorse the comments made on behalf of CUDCP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsEddyAmeenAPAGS (Amer. Psyc. Assoc. of Graduate Students)The American Psychological Association of Graduate Students (APAGS) is pleased to comment on the latest draft Implementing Regulations for the Commission on Accreditation. APAGS is supportive of the recommended changes to the Commission on Accreditation’s Data and Disclosure IRs; however, we wish to make the following recommendations that would improve the IRs and their implications for the training experiences of graduate students. For “Outcome Data for Doctoral Programs,” we recommend the removal of the reference to the subject GRE as an example of a standardized assessment for establishing students’ foundational knowledge. Listing the GRE subject test as the only example of competency evaluation increases the likelihood of its use for the purpose of establishing student competencies without a rationalization for why it should be used. The absence of an example assessment does not adversely affect the implementing regulation in question. Additionally, greater clarity should be bro... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsLeeCooper I endorse the comments made on behalf of CUDCP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsBradRoper I am pleased that the CoA is working to provide clear definitions of a) the profession-wide competencies previously defined and b) the level of outcome data requested. Reporting data at the level of the overall competency, and clearly defining those competencies, will provide useful guidance for programs on the level of detail needed by CoA. I do have some observations and suggestions regarding this IR and how it relates to the Profession-Wide Competencies (PWC) IR. *** The data IR makes reference to PWC and “elements” within those competencies. The current IR requires that programs are required to operationalize competencies in terms of “multiple elements.” In reviewing the PWC IR, there is no reference to “elements” specifically, but there are bullet points below each competency. It is unclear whether the bulleted points represent the “elements” referred to in the current IR. If so, then the Supervision competency in the PWC IR has only one element each for doctoral and internship p... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsMerileeMcCurdyCDSPPResponse of the Council of Directors of School Psychology Programs (CDSPP) regarding the Outcome Data for Doctoral Programs Implementing Regulations: CDSPP appreciates the time of and effort of the CoA to develop these implementing regulations. Included below are three considerations for the CoA as these IRs are finalized. With respect to “discipline specific knowledge (page 1 first section in italics) 1.a(i),” CDSPP believes that programs may struggle to determine a minimum level of achievement (MLA) that will satisfy the CoA. This is particularly true as there is not consensus surrounding a “standard for the profession” regarding many sub-competencies. Likewise, the IR might also be revised to illustrate specific technical properties of a standardized assessment that would satisfy the CoA. Furthermore, it may also be helpful to programs for the IR to provide illustrative examples of “evaluation methods and MLA [that] are appropriate for the measurement of each competency” and... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsSmithRonald I endorse the comments and suggestions made on behalf of CUDCP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsAshleyMaynardCOGDOP1. This paragraph under distal data should be deleted because it is already stated in the SoA and on pp. 1-2 of this document that data should be collected at 2 years and at 5 years: Although CoA does not specify the interval at which distal data should be collected, the interval should be appropriate to allow the program to evaluate its success in promoting expected competencies to determine if changes need to be made, consistent with Standard II. 2. This paragraph, on aggregation of data, needs to be clarified: If data are aggregated over a number of years (i.e., not broken down by cohort or years), the program needs to demonstrate how aggregating the data in this way facilitates the program’s self-improvement. We suggest clarifying what sort of demonstration would suffice in order to meet the SoA. There is a hint in the section on "Level of Specificity: DSK," but this should probably refer forward to the section on Aggregation of Data. And it should be more clear what... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Doctoral ProgramsJasonWashburnNorthwestern University Feinberg School of MedicineI endorse the comments made on behalf of CUDCP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Internship ProgramsJanetYang This IR on Outcome Data on Internship programs seems clear and appropriate.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Internship ProgramsKathleenAshton I appreciate the CoA's work on this issue and overall agree with the document. I believe collecting outcome data on training programs is a valuable addition for programs, trainees, and the public. I would suggest that more specific guidelines and/or examples for assessing competencies be provided, as well as direction for specialty competencies (perhaps in conjunction with ABPP boards).
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Internship ProgramsRobertPerl I support all comments made on behalf of NCSPP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Internship ProgramsSteveDeMersASPPBASPPB is in support of the IR’s regarding Outcome Data for Internship Programs. Overall the document is clear, detailed, and comprehensive. In addition, we want to address key aspects of the implementing regulations that are critically important from a public protection and regulatory viewpoint including: • The evaluation of competencies as well as the collection of distal data, including licensure, all serve the goal of training a competent workforce and promoting public protection. • The definition of the evaluation of competencies, and the requirement of evaluative data, is appropriate and necessary from a regulatory perspective. • The distal data that speaks to competency may need to be further flushed out. • We are pleased that distal data includes licensure as an important competency and benchmark to achieve and track. The sensitivity that CoA has displayed toward licensure requirements and viewing licensure as a competency for Health Service Providers to achieve promotes p... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Internship ProgramsStephanieWood I support all comments made on behalf of NCSPP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Internship ProgramsMiltonFuentes I support NCSPP's comments and responses.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Internship ProgramsBarryTammy I endorse the comments made on behalf of CUDCP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Internship ProgramsHidekoSeraNCSPP (National Council of Schools and Programs of Professional Psychology)NCSPP Recommended Public Comments-Outcome Data for Internship Programs The internship outcome table allows only a single response to stipend/benefit amounts. Although discouraged, some Consortia are unable to offer a single stipend level as members have various internal resources, collective bargaining agreements, etc. NCSPP recommends that this possibility is anticipated, and the Table be modified to include something akin to the following: "If the program is a Consortium, please specify by training partner."
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Internship ProgramsKevinArnoldCouncil of Specialties in Professional PsychologyThe Council of Specialties thanks COA for its hard work on the IRs. We support the IR as written.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Internship ProgramsLeahHorvath I agree with the NCSPP comments/responses.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Internship ProgramsClaytieDavis IIIAPPICThe Association of Psychology Postdoctoral and Internship Programs (APPIC) represents 769 internship and 186 postdoctoral programs. The APPIC Board greatly appreciates the opportunity to comment on the proposed Implementing Regulations (IRs). The profession will benefit by increased transparency on the part of programs and we see the revised IRs as a step in that direction. The Board is pleased to see the requirement of a single location for prospective applicants to review program content and expectations. Further, asking all programs to title the section the same – “Internship Admissions, Support, and Initial Placement Data” – will also be of benefit to applicants. APPIC commends the CoA for continued efforts to allow for program-defined competencies in addition to profession-defined competences. We believe that it is critical for programs to have latitude to include goals and competencies outside the scope of the generally accepted competencies. APPIC is also pleased to see the requ... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Internship ProgramsJoelSchmidtVA Psychology Training CouncilThe VA Psychology Training Council (VAPTC) Executive Committee (EC) represents 124 internship and 75 postdoctoral training programs within the department of Veterans Affairs. The VAPTC EC is pleased to provide public comment on the proposed Implementing Regulations (IRs). Outcome Data for Internships VAPTC EC is in support of profession wide competencies at both the internship and postdoctoral level of training and we are pleased to see that this IR allows programs the flexibility to identify additional program specific competencies. A few areas would benefit from further clarification. For example, with the direct observation requirement, will all competencies need to be directly observed and how often? Similarly, the definition of distal data could be improved by providing further explanation and/or examples of acceptable distal data points (especially those that would link back to profession wide competencies) at both the internship and postdoctoral level of training. More spe... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Internship ProgramsRenePuliattiCalifornia Psychology Internship Council (CAPIC)While we are generally in support of this IR and find it to be a significant step in the right direction, we are concerned about internal inconsistencies with other IR’s, in particular with IR C-17-D (on Expected Internship Placement) and with IR D-4-7(b) (Doctoral Program Achievement Thresholds). This IR calls on accredited programs to use outcome data on all of their students, regardless of whether the internship or postdoc experience was at an APA-accredited site. We believe this is the right standard, which should be applied uniformly across the board in the regulations, including IR C-17-D, which uses a separate standard for non-APA-accredited internships. As mentioned even in this IR and pointed out by colleague Dr. Sharma, program outcomes must be designed to measure and evidence whether the program is achieving its stated aims. Therefore, it seems particularly crucial that these IR’s emphasize that program outcome measurement be directly measuring the program’s objecti... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Internship ProgramsCrystalCollier I support all comments made on behalf of NCSPP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Internship ProgramsBradRoper I am pleased that the CoA is working to provide clear definitions of a) the profession-wide competencies previously defined and b) the level of outcome data requested. Reporting data at the level of the overall competency, and clearly defining those competencies, will provide useful guidance for programs on the level of detail needed by CoA. I do have some observations and suggestions regarding this IR and how it relates to the Profession-Wide Competencies (PWC) IR. *** The data IR makes reference to PWC and “elements” within those competencies. The current IR requires that programs are required to operationalize competencies in terms of “multiple elements.” In reviewing the PWC IR, there is no reference to “elements” specifically, but there are bullet points below each competency. It is unclear whether the bulleted points represent the “elements” referred to in the current IR. If so, then the Supervision competency in the PWC IR has only one element each for doctoral and internship p... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Internship ProgramsKennethAdams  I do not support the definitions of how distal data are to be conceptualized and collected. Internship training is pretty universally held to be a generalist-focused final year of training before completion of the doctoral program. It is perfectly reasonable to define those competencies that constitute professional and program goals of the training goals in the internship year and measure their realization and completion. CoA has typically set a standard of 100% success in all competency attainments espoused by programs to be their endpoints of the training experience. Yet it is clear that professional development and more refined skills achievement will continue post internship. With respect to distal data, following the completion of Internship the CoA the IR imposes an unrealistic standard (i.e., “but alone are not sufficient because they do not reflect achievement of all expected competencies”). Don’t we get told by CoA that 100% achievement of competencies is the requirement... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Postdoctoral Residency ProgramsHidekoSeraNCSPP (National Council of Schools and Programs of Professional Psychology)NCSPP Recommended Public Comments-Outcome Data for Post-Doctoral Residency Programs NCSPP concurs with the proposed Implementing Regulations pertaining to Post-Doctoral Residency as drafted.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Postdoctoral Residency ProgramsKathleenAshton I appreciate the CoA's work on this issue and overall agree with the document. I believe collecting outcome data on training programs is a valuable addition for programs, trainees, and the public. I would suggest that more specific guidelines and/or examples for assessing competencies be provided, as well as direction for specialty competencies (perhaps in conjunction with ABPP boards).
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Postdoctoral Residency ProgramsRobertPerl I support all comments made on behalf of NCSPP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Postdoctoral Residency ProgramsStephanieWood I support all comments made on behalf of NCSPP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Postdoctoral Residency ProgramsSteveDeMersASPPBASPPB is in support of the IR’s regarding Outcome Data for Postdoctoral Residency Programs. Overall the document is clear, detailed, and comprehensive. In addition, we want to address key aspects of the implementing regulations that are critically important from a public protection and regulatory viewpoint including: • We are in support of clear outcome data for postdoctoral residency programs that include assessment of specialty competencies. • We are pleased that distal data includes licensure as an important competency and benchmark to achieve and track. The sensitivity that CoA has displayed toward licensure requirements and viewing licensure as a competency for Health Service Providers to achieve promotes public protection. • We are in support of distal data tracking employment, memberships and affiliations as important outcome data. Workforce data serves to promote public protection in a number of ways, which includes being an important indicator of a training programs success... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Postdoctoral Residency ProgramsBarryTammy I endorse the comments made on behalf of CUDCP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Postdoctoral Residency ProgramsKevinArnoldCouncil of Specialties in Professional PsychologyThe Council of Specialties thanks COA for its hard work on the IRs. We support the IR as written.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Postdoctoral Residency ProgramsLeahHorvath I agree with the NCSPP comments/responses.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Postdoctoral Residency ProgramsJoelSchmidtVA Psychology Training CouncilThe VA Psychology Training Council (VAPTC) Executive Committee (EC) represents 124 internship and 75 postdoctoral training programs within the department of Veterans Affairs. The VAPTC EC is pleased to provide public comment on the proposed Implementing Regulations (IRs). VAPTC EC is in support of profession wide competencies at both the internship and postdoctoral level of training and we are pleased to see that this IR allows programs the flexibility to identify additional program specific competencies A few areas would benefit from further clarification. For example, with the direct observation requirement, will all competencies need to be directly observed and how often? Similarly, the definition of distal data could be improved by providing further explanation and/or examples of acceptable distal data points (especially those that would link back to profession wide competencies) at both the internship and postdoctoral level of training. More specifics about the profession wid... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Postdoctoral Residency ProgramsRenePuliattiCalifornia Psychology Internship Council (CAPIC)While we are generally in support of this IR and find it to be a significant step in the right direction, we are concerned about internal inconsistencies with other IR’s, in particular with IR C-17-D (on Expected Internship Placement) and with IR D-4-7(b) (Doctoral Program Achievement Thresholds). This IR calls on accredited programs to use outcome data on all of their students, regardless of whether the internship or postdoc experience was at an APA-accredited site. We believe this is the right standard, which should be applied uniformly across the board in the regulations, including IR C-17-D, which uses a separate standard for non-APA-accredited postdoctoral residencies. As mentioned even in this IR and pointed out by colleague Dr. Sharma, program outcomes must be designed to measure and evidence whether the program is achieving its stated aims. Therefore, it seems particularly crucial that these IR’s emphasize that program outcome measurement be directly measuring the prog... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Postdoctoral Residency ProgramsCrystalCollier I support all comments made on behalf of NCSPP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Outcome Data for Postdoctoral Residency ProgramsBradRoper I am pleased that the CoA is working to provide clear definitions of a) the profession-wide competencies previously defined and b) the level of outcome data requested. Reporting data at the level of the overall competency, and clearly defining those competencies, will provide useful guidance for programs on the level of detail needed by CoA. I do have some observations and suggestions regarding this IR and how it relates to the Profession-Wide Competencies (PWC) IR. *** Under the section on Definitions, Distal data, it is unclear what is meant by success in "promoting" expected competencies. Clearly the decision to change from "achieving" of the prior IR was intentional, but the rationale is unclear. *** Under the section on Definitions, Distal data, the first bullet point, there is reference to both profession-wide competencies and program specific competencies but not specialty competencies. I would suggest that the sentence end with “. . . mastery of profession wide competencies, pr... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Public Disclosure for Internship ProgramsJanetYang This IR on Public Disclosure for Internship Programs seems clear and appropriate.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Public Disclosure for Internship ProgramsKathleenAshton I agree with the document and appreciate the CoA's work. I believe these changes are consistent with increasing trends toward transparency. They appear to be reasonable requests for an accredited program.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Public Disclosure for Internship ProgramsRobertPerl I support all comments made on behalf of NCSPP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Public Disclosure for Internship ProgramsMiltonFuentes I support NCSPP's comments and responses.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Public Disclosure for Internship ProgramsBarryTammy I endorse the comments made on behalf of CUDCP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Public Disclosure for Internship ProgramsSteveDeMersASPPB ASPPB is in support of the IR’s regarding Public Disclosure for Internship Data. Overall the document is clear, detailed, and comprehensive. In addition, we want to address key aspects of the implementing regulations that are critically important from a public protection and regulatory viewpoint including: • This document will not only promote public protection of the clients who are treated by students, interns and post docs but also includes elements that will serve to protect the “public” of individuals who are applying for programs, internships and post docs. Therefore, ASPPB supports the public disclosure concerning admissions process, support and outcome data for the program, internships and post-doc. • The presentation of required information assures that the requirement of public disclosure must meet the spirit, and not simply the letter, of the law, in that information cannot be buried and must be easily accessible. Thank you for allowing us to provide feedback to y... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Public Disclosure for Internship ProgramsKevinArnoldCouncil of Specialties in Professional PsychologyThe Council of Specialties thanks COA for its hard work on the IRs. We support the IR as written.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Public Disclosure for Internship ProgramsJoelSchmidtVA Psychology Training CouncilOne area that is much appreciated is the requirement for increased transparency on the part of programs via the requirement for a single location, with a consistent title (“Internship Admissions, Support, and Initial Placement Data” and “Postdoctoral Residency Admissions, Support, and Initial Placement Data”), where prospective applicants can review program content, requirements, and selection/screening criteria. In summary, VAPTC EC supports the revised IRs as written, though would request some additional clarification (as noted above). Thank you for the opportunity to provide feedback.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Public Disclosure for Internship ProgramsCrystalCollier I support all comments made on behalf of NCSPP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Public Disclosure for Internship ProgramsBradRoper I agree that developing a standard format for the information in this IR will assist prospective applicants as they consider applying to programs.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Public Disclosure for Internship ProgramsEddyAmeenAPAGS (Amer. Psyc. Assoc. of Graduate Students)We applaud the development of this guidance and the request for tables, as APAGS has strongly advocated for these changes previously (see our request at www.tinyurl.com/apagscoar1 for details). For “Public Disclosure of Internship Programs,” we recommend the following revisions: 1) Please further clarify the intent of making all of the information in the table available without request to all prospective applicants. We suggest the following modification of the first paragraph on Page 13: Modify “...and must be presented in a manner that allows applicants to make informed decisions about entering the program” to “...and must be presented in a manner that allows all prospective applicants to make informed decisions about applying to and entering the program without making any special requests for such information.” 2) For the “Internship Program Admissions” table, where a site has more than one track, divide the number of minimum hours required along tracks. For example, a neuropsych tr... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Public Disclosure for Postdoctoral Residency ProgramsKathleenAshton I agree with the document and appreciate the CoA's work. I believe these changes are consistent with increasing trends toward transparency. They appear to be reasonable requests for an accredited program.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Public Disclosure for Postdoctoral Residency ProgramsRobertPerl I support all comments made on behalf of NCSPP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Public Disclosure for Postdoctoral Residency ProgramsMiltonFuentes I support NCSPP's comments and responses.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Public Disclosure for Postdoctoral Residency ProgramsBarryTammy I endorse the comments made on behalf of CUDCP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Public Disclosure for Postdoctoral Residency ProgramsSteveDeMersASPPBASPPB is in support of the IR’s regarding Public Disclosure for Postdoctoral Residency Programs. Overall the document is clear, detailed, and comprehensive. In addition, we want to address key aspects of the implementing regulations that are critically important from a public protection and regulatory viewpoint including: • This document will not only promote public protection of the clients who are treated by students, interns and post docs but also includes elements that will serve to protect the “public” of individuals who are applying for programs, internships and post docs. Therefore, ASPPB supports the public disclosure concerning admissions process, support and outcome data for the program, internships and post-doc. • The presentation of required information assures that the requirement of public disclosure must meet the spirit, and not simply the letter, of the law, in that information cannot be buried and must be easily accessible. Thank you for allowing us to prov... See Full Comment
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Public Disclosure for Postdoctoral Residency ProgramsKevinArnoldCouncil of Specialties in Professional PsychologyThe Council of Specialties thanks COA for its hard work on the IRs. We support the IRs as written.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Public Disclosure for Postdoctoral Residency ProgramsJoelSchmidtVA Psychology Training CouncilOne area that is much appreciated is the requirement for increased transparency on the part of programs via the requirement for a single location, with a consistent title (“Internship Admissions, Support, and Initial Placement Data” and “Postdoctoral Residency Admissions, Support, and Initial Placement Data”), where prospective applicants can review program content, requirements, and selection/screening criteria. In summary, VAPTC EC supports the revised IRs as written, though would request some additional clarification (as noted above). Thank you for the opportunity to provide feedback.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Public Disclosure for Postdoctoral Residency ProgramsCrystalCollier I support all comments made on behalf of NCSPP.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Public Disclosure for Postdoctoral Residency ProgramsBradRoper I agree that developing a standard format for the information in this IR will assist prospective applicants as they consider applying to programs.
Implementing Regulations (Data and Disclosure).pdfImplementing Regulations (Data and Disclosure)Public Disclosure for Postdoctoral Residency ProgramsEddyAmeenAPAGS (Amer. Psyc. Assoc. of Graduate Students)For “Public Disclosure of Postdoctoral Programs,” we recommend modifications that mirror our previously listed suggestions for Internship Programs which are equally relevant here. 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.