Accreditation Public Comment System





This project is now closed for new comments.
DocumentSectionItemFirst NameLast NameGroup NameComment 
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)DianeBlau I endorse the NCSPP response for all sections.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)EricVogel As a member of the SQIP (Section of Div 5) EC, I am writing in support of the group comment made by us about the inclusion of orientation and training in qualitative methods in the revised APA accreditation requirements. Qualitative research training involves the development of skill sets that have direct value for clinicians, whereas quantitative research training contributes less in this regard. More qualitative research is urgently needed to address significant gaps in the evidence base for treatments. Please see http://ejop.psychopen.eu/article/view/750
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)MargaretRoller As a member of the Society for Qualitative Inquiry in Psychology (SQIP), I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods. Even after 40 years out of graduate school, I regret that my education was absolutely devoid of qualitative methods. It is critical for the integrity of psychological research that qualitative inquiry play a prominent role. As such, our students today must given the necessary knowledge and tools to make this a reality.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)MaryGergen In agreement with SQIP, I think it is very important that qualitative methods are included in the curriculums. It seems to me that understanding research, being able to do it, even informally, and keeping up with relevant social science literature makes this imperative. The future belongs to the qualitative world, in many respects, and to deprive students from accessing this valuable and fascinating area of research is a mistake. (Besides, most journal readers just skip over the statistical bits of articles anyway. Its an esoteric language, by and large, of specialists.)
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)ClaraHill I strongly advocate adding qualitative methods to required content coverage
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)CarolaSuarez-OrozcoExecutive Committee of the Society for Qualitative Inquiry in PsychologyI fully endorse the Executive Committee of the Society for Qualitative Inquiry in Psychology statement about the importance of adding qualitative and mixed-methods training for psychologists to the already requisite quantitative and psychometric requirements. Important for many reasons, it is essential for culturally and linguistically diverse populations where standardized measures are often not accurate and do not capture the experience of the populations under study. Carola Suarez-Orozco
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)JeanneMarecek The absence of training in qualitative approaches in US graduate programs means that US psychologists are rapidly losing ground in international psychology. As editor of an international journal, I have seen paper after paper by US-trained authors rejected on methodological grounds. I have also witnessed editors and reviewers of US journals offer crudely dismissive and inaccurate judgments regarding qualitative manuscripts. It's time to get in step with the rest of the world. Jeanne Marecek
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)WilliamHartmann In and under the heading "Discipline-Specific Knowledge Category 4: Research and Quantitative Methods" I urge inclusion of Qualitative methods. Qualitative methods are vital to knowledge production in psychology and should be recognized as such in professional training.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)BarryKlein I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)ShawnRubin I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods. It is essential that qualitative and mixed methods be included as essential in all training programs.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)ShawnRubin I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods. It is essential that qualitative and mixed methods be included as essential in all training programs.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)DelRapier I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)AnneBrodsky I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods. Qualitative methods are an essential part of a complete application of the scientific method and wholistic understanding of the person, environment, and outcomes related to both.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)DeborahMerchantDiv 32 and Saybrook UniversityI am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)JosephSchwab I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)SharonHorne I understand the intention of students learning to integrate two or more content areas but find the evaluation of this integration perplexing. Who will have the expertise to evaluate such an educational experience? It is rare to have faculty who are experts in both content areas, so it will require a team or group approach to determining the outcome. It would be helpful to have examples of what educational experiences would sufficiently meet this IR. I also wonder about the inconsistencies with determining who has the expertise to provide such content for DSK. On the one hand, the IR is saying that students can demonstrate that they have acquired the content for some of these areas prior to their doctoral training (and this could have been taught by a doctoral student or postdoc or independent study or demonstrated through content in a course, or even through a standardized test--so they could have studied this material through self-study or via reading materials), yet at the gradua... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)ChrisMcVittie I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)AutumnWinslow I am currently a doctoral student enrolled in an APA-accredited Clinical Psychology program. As part of both my Research Methods and Quantitative Methods (Statistics & Advanced Statistics), I have gained requisite knowledge to understand statistical methods and procedures in psychology. I have also taken a course in Qualitative Methodologies (as an elective, which would not count towards a Category 4 requirement), and research within my lab draws from many qualitative methodologies that are relevant and suitable to my own work. In working on this research, I often wish there was a qualitative study requirement for others in my program/field of study so that they have the same base knowledge and language for discussing qualitative methods and findings. If the APA were to include qualitative training as part of their accreditation requirements, I believe it would level the playing field in terms of having a common language for students and faculty in programs like mine to discuss both qu... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)NabilEl-GhorouryAPAGSThe American Psychological Association of Graduate Students (APAGS) is pleased to comment on the latest draft of the Commission on Accreditation’s (CoA) Standards of Accreditation for Health Service Psychology (SoA). APAGS is supportive of the proposed IRs; however, we wish to make the following recommendations that would improve the standards and their implications for the training experiences of graduate students. C-7 Discipline Specific Knowledge • p. 2 It may be helpful to provide clarification or examples of how programs can build upon foundational knowledge assessed through standardized assessment (e.g., GRE subject tests) in order to establish graduate-level discipline-specific knowledge. As standardized assessments like the GRE assess knowledge obtained at the undergraduate level, section II.B.1.a. appears to be emphasizing ways in which to assess discipline-specific knowledge at this level, rather than the graduate level. Although the disclaimer “In this case, the progr... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)LindaCraighead I concur with the CUDPCP comments on DSK
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)LeswinLaubscher I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)ReneeSpencer I endorse the SQIP (Society for Qualitative Inquiry in Psychology) Executive Committee comment on education on qualitative methods as pasted below: SQIP Executive Committee Comment: The Executive Committee of the Society for Qualitative Inquiry in Psychology (SQIP), a section of APA Division 5 (Quantitative and Qualitative Methods) recommends the inclusion of qualitative research and mixed methods research into the section on Discipline-Specific Knowledge Category 4: Research and Quantitative Methods (before the mention of meta-analysis). We recommend that this inclusion detail topics such as philosophies of science (e.g., ontology and epistemology), methodologies, methods of data collection/generation, methods of data analysis, criteria for evaluating quality, qualitative research ethics, researcher reflexivity, and the mobilization and dissemination of these research approaches (see implementation suggestion below). We are at a point in our profession in which the publi... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)Tuval-MashiachRivka As a member of the SQIP (Section of Div 5) EC, I am writing in support of the group comment made by us about the inclusion of orientation and training in qualitative methods in the revised APA accreditation requirements. Qualitative research training involves the development of skill sets that have direct value for clinicians, whereas quantitative research training contributes less in this regard. More qualitative research is urgently needed to address significant gaps in the evidence base for treatments.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)LeeCooper I fully support the CUDCP comment on this IR.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)KathieBates I concur with the NCSPP response as well as the SQIP commentary. I also endorse comments aimed at efforts to more closely integrate the APA statements on psychotherapy effectiveness into the model for DSK.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)StantonAnnette I strongly endorse CUDCP's comments.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)RyanBlackstock It is 2017 for Christ's sake. It is shameful that the APA is just NOW considering adding Qualitative research to Doctoral Education. I can't tell you how many APA grads I have met that don't have a clue/were never exposed to qualitative methods during their education. In my opinion, they have been cheated. It is time to correct that. I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods. This inclusion is way overdue.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)CallahanJenniferOn behalf of the 9 faculty in the APA-accredited Clinical Psychology Program at the University of North TexasWe fully support the Council of University Directors of Clinical Psychology (CUDCP) comment on this IR.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)HidekoSeraNCSPPI support and endorse Dr. Lavita Nadkarni's comments from NCSPP.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)ALEXANDRAREED I strongly endorse CUDCP’s comments.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)JeffreyGoodie I fully support the CUDCP comment on this IR
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)DeborahBeidel I fully support the comments submitted by the Council of University Directors of Clinical Psychology Program.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)MatthewJarrettCUDCPI fully support the CUDCP comment on this IR.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)DanielFishman As a member of the Society for Qualitative Inquiry in Psychology (SQIP), I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods. Training clinical psychologists in a PsyD program, I find learning qualitative research methods crucial to the development of students' sophisticated awareness, skills, and effectiveness in clinical assessment and psychotherapy. Also many students in our program do qualitative or mixed methods dissertations, requiring a knowledge of qualitative research methods. In short, education in qualitative research methods is as important as education in quantitative methods in the training of students about the foundations and best practice of clinical psychology.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)BarryTammyWashington State University Clinical Psychology Doctoral ProgramI fully support the Council of University Directors of Clinical Psychology (CUDCP) comment on this IR.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)MeghanVinograd I support CUDCP’s comments.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)MichaelSun I endorse CUDCP's comments
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)ElizabethMoroney I strongly endorse CUDCP’s comments.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)KathleenSkott-Myhre I am writing to strongly support the comment made by the SQIP executive committee for the inclusion of qualitative methods. The very nature of Psychology is a qualitative endeavor and to eliminate the necessity for understanding and/or executing qualitative research is asking that our future psychologists understand only half of the picture.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)JessicaAndradeBoard of Educational AffairsThe Board of Educational Affairs (BEA) thanks the Commission on Accreditation for the opportunity to provide comment on the draft Discipline Specific Knowledge Implementing Regulation (IR). BEA reviewed this draft IR and provide their comments below: The concept of discipline specific knowledge is familiar to those involved in graduate training from past versions of the IRs. The current version expands the definition of required DSK in a way that is meaningful and designed to both insure that students receive advanced-integrated exposure and that they meet appropriate standards of knowledge at the time of admission to programs. Knowledge of history and systems, basic and integrative knowledge in scientific psychology and methods of inquiry and research continue to be germane currently. BEA’s concerns do not relate to the content of the IR per se, but in how Programs will interpret what is written. We are confident that training of Program administrators and site visitors over the ne... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)DeboraBell I fully support the Council of University Directors of Clinical Psychology (CUDCP) comment on this IR. Further, I am strongly supportive of CoA's role in assisting programs with identifying ways of implementing this IR within their own programs. There are admittedly many challenges that may come with introducing direct observation into practicum sites that may be geographically remote, have strong policies governing confidentiality and security, or serve a clientele who may be reluctant to allow observation. However, the expectation that a supervisor, who is pedagogically, ethically, and legally responsible for (and to) that student, as well as to the clients under that student's care, has direct evidence of the student's competencies and the quality of client care seems not just reasonable but critical. CoA's guidance in helping programs address implementation challenges will be a key factor in the success of this quality assurance step.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)LeslieRith-Najarian I strongly support CUDCP’s comments
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)YakushkoOksana - Recent longitudinal data on programs, accredited by the American Psychological Association, show that the doctoral training is becoming dramatically “less intellectually diverse” and offers an ever “narrowing” training, leading to “monocultural” approaches, currently represented by the Cognitive-Behavioral (CBT) methods (see Levy & Anderson, 2013 for data and review). New “standards” of accreditation appear to propose to further contribute to this creation of the “monoculture.” Multiple scholars have highlighted that this narrowing of psychotherapy orientations has significant and negative impact on the field (e.g., Heatherington et al., 2012) and contradicts available scientific data that shows that many of the approaches alternative to CBT, are as or more effective (Abbass et al., 2006; Leichsenring & Rabung, 2008; Levy et al., 2013; Shedler, 2010; Wampold et al., 2011; Weisz et al., 2009). This narrowing could not have occurred if it were not explicitly and implicitly supported by... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)PeterClayson I strongly support CUDCP's comments. Thank you.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)ErinSandler I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)FalkJulia I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods as one of the areas doctoral students need to be familiar with. The ability to process empirical findings is certainly critically important, but the characteristics of intra- and inter-personal expression are even more related to the work we do in the world, regardless of our subspecialty of interest.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)BradyWiggins I am writing to support SQIP executive committee's comment regarding the inclusion of qualitative methods.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)IsabelleLanser I strongly endorse CUDCP’s comments.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)EleftheriaTseliou I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)Staples-BradleyLindsay I strongly endorse CUDCP’s comments.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)YakushkoOksanaThe Psychotherapy Action NetworkComment to the Commission on Accreditation in Regard to Emphasis on Psychotherapy and Relationship in Accreditation Standards and Implementing Regulations February 1, 2017 The Psychotherapy Action Network, which includes a growing number of concerned practitioners, scholars, and activists is requesting for the Commission on Accreditation to review and address the following grave concerns in regard to accreditation of programs that license individuals to practice psychotherapy and other clinical applied work with human beings and diverse communities. An emphasis of current Standards and Implementing Regulations of the COA reflect neither current and past research (e.g., vital centrality of relationships in psychotherapy process and client healing/change; empirical evidence of multiple theoretical orientations, specifically psychoanalytic and psychodynamic in treatment of a wide range of disorders; lack of actual evidence behind supposed evidence based manualized treatments). In... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)AlaynaPark I strongly endorse CUDCP’s comments.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)JuliaHammett I strongly endorse CUDCP’s comments.” “I support CUDCP’s comments.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)PuliattiReneCalifornia Psychology Internship Council (CAPIC)CAPIC supports the comments of NCSPP in this matter on the need for a single but broad standard that recognizes the validity of diverse psychological methods. Consistent with this goal of recognizing valid and diverse methods, CAPIC also supports the comments of SQIP for the inclusion of orientation and training in qualitative methods. CAPIC also strongly encourages CoA to review this and all Implementing Regulations (IR's) for any unintended consequences on the profession and the public. As CAPIC has previously stated, IR's often have powerful impact on members by virtue of the IR's arising from the CoA which has the power to grant, limit or deny accreditation to its members. CAPIC also continues to contend that IR D-4-7(b) negatively impacts the diversity of the profession as well as and the diversity of populations served, by undervaluing valid quality unaccredited agencies and programs which serve diverse and often underserved communities and often better meet the needs of... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)ToddBrown I support CUDCP’s comments.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)RenaRepetti I support CUDCP’s comments.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)KodishTamar I support CUDCP’s comments.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)PatriciaDixon I support the comments of NCSPP
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)KarenFondacaroAPTC-Association of Psychology Training ClinicsAPTC encourages further guidance on the Discipline-Specific Knowledge (DSK) - Implementing Regulation. It would be helpful if CoA provided examples of how meeting these requirements might be demonstrated. Perhaps the SoA could include some "best practice" examples.  Also, thresholds are unclear. It seems possible to meet DSK for 2 individual areas plus the integrative requirement in the same course (e.g., a course on cognitive neuroscience could count for cognitive, biological and the integrative piece), though it is unclear how to determine that the course goes into sufficient depth on both individual topics as well as integration in order to determine the course would meet the threshold determined by APA. In addition, greater clarity on the program-devised methods for determining sufficient DSK background would be useful. APA indicated that a program could not use their own entry-level comprehensive exam to determine if students have sufficient background (as opposed to a GRE... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)CindyYee-Bradbury I strongly endorse CUDCP's comments.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)AliciaTrotman I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods. We have to use methods that prioritize MEANING to our students and their clients and that is accomplished to a DEEPER level with qualitative methods (e.g. phenomenology, grounded theory, discourse analysis, narrative research, consensual qualitative research).
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)Will W.Adams I am writing in support of the comment made by the Society for Qualitative Inquiry in Psychology executive committee about the inclusion of qualitative methods in graduate school training programs. The APA has long valued diversity in all its various form. It seems crucial to include epistemological and ontological diversity in this affirmation. For each particular research study, one’s research method should be developed according to the distinctive characteristics of the phenomenon under consideration, coupled with one’s particular research question about the phenomenon. Clearly, since psychological phenomena are immensely varied and complex, it is valuable to have a variety of methodologies from which one can draw in crafting one’s method and procedures for a particular project. Just as there are many phenomena that are best studied quantitatively, there are countless others that quantitative methods cannot access and are better approached qualitatively. In his book The Psychology... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)LaurenHarris I support CUDCP’s comments.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)NaomiRodas I strongly endorse CUDCP’s comments.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)FenesyMichelle I support CUDCP’s comments
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)DonnaRockwell I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods. By providing education on both qualitative and quantitative methods, psychological training programs can broaden the range of scientific tools available to support inquiry. These tools have many purposes and can stand on their own or can be combined with quantitative methods in mixed methods programs of research. Researchers who have an understanding of both philosophy of science and quantitative and qualitative research designs will be best equipped to consume, evaluate, and engage in the contemporary practices of their profession. This education can enable researchers to select, tailor, and combine methods to best fit their questions and the needs of the field. Quantitative and qualitative methods then can better complement one another and strengthen psychological science. Implementation Suggestion: In terms of implementation, we suggest that the text ... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)AdamsEve I believe some exposure to qualitative methodology should be a DSK requirement.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)BradRoperSociety for Clinical Neuropsychology (APA Division 40)The Society for Clinical Neuropsychology thanks the CoA for the opportunity to comment on draft regulations regarding Discipline Specific Knowledge for doctoral degree programs. We support the use of undergraduate coursework to meet some requirements of DSK as indicated in the draft IR. We believe that the revision both clarifies expectations and allows for flexibility both across programs and within students in a single program. Houston Conference on Specialty Education and Training in Clinical Neuropsychology call for training within the specialty to take place at the doctoral, internship, and postdoctoral levels. In order for such training to occur at the doctoral level, allowance is needed for both coursework and practical experiences within the specialty. For example, according to the Clinical Neuropsychology Taxonomy, a Major Area of Study at the doctoral level consists of a minimum of a) three neuropsychology courses, b) two clinical neuropsychology practica, and c) additional c... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)HeatherLyons I endorse the NCSPP response for all sections.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)MichaelKarson I suggest the CoA reread APA's statement on psychotherapy effectiveness and model DSK on that. Trainees should be evaluated on their ability to form a working alliance, develop case-specific and culturally-sensitive case formulations, and apply the clinical knowledge base to specific situations. They should also be able to critique the research on so-called empirically-supported treatments in light of the Statement's recognition that many therapies work equally well.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)RadhikaKrishnamurthy I endorse NCSPP's response concerning Discipline-Specific Knowledge (C-7 D).
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)RobertPerl I endorse the NCSPP response for all sections.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)JosephGone As a member of the SQIP (Section of Div 5) EC, I am writing in support of the group comment made by us about the inclusion of orientation and training in qualitative  methods in the revised APA accreditation requirements.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)DianeBlau I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods. It is essential that qualitative and mixed methods be included as essential in all training programs.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)StephanieWood I endorse the NCSPP response for all sections.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)RonPilato I endorse the NCSPP response for all sections.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)TroyPiwowarski I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)AmandaArena-Miller I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)MitchPrinstein I strongly support the CUDCP commments
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)AdeleCuthbert I write in support of the comment submitted by the SQIP executive committee that recommends that qualitative research and mixed methods research be included in the Discipline Specific Knowledge Category 4.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)AndrewGarrison I hope you will include expertise in qualitative research methods as part of these training goals. Qualitative methods have an increasing role in clinical, personality, and social research, and it is important that they be included in the epistemological practices of the discipline.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)JulieRadicoCommittee on Early Career PsychologistsThe Committee on Early Career Psychologists (CECP) appreciates the Commission on Accreditation’s (CoA) work in continuing efforts to revise the Implementing Regulations for Discipline Specific Knowledge (DSK) for doctoral degree programs. The regulations appear to provide clear expectations for foundational and graduate level DSK. We are supportive of programs needing to document how each student demonstrates graduate-level DSK, as it requires program reflection on each student’s learning trajectory and progress. It is also appreciated that the CoA states exceptions to established evaluation methods can be made in light of evaluation methods or minimum criteria which may discriminate against a student. We submit one final, minor typographical edit: In the second to last paragraph in the Considerations Specific To Category 1: The Major Field Test or other standardized evaluations of knowledge in scientific psychology may also be appropriate, as MAY (correct to MANY) evaluations develo... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)ThomasRodebaugh I fully support CUDCP's comments on this IR.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)DavidPantaloneUniversity of Massachusetts, BostonThe Clinical Psychology Doctoral Program at UMass Boston fully supports the CUDCP comment on this IR.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)MeganO'Banion I endorse the NCSPP response for C-7 D. Discipline-Specific Knowledge.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)GonzaloBacigalupe I fully support the comments by the Executive Committee of the Society for Qualitative Inquiry in Psychology (SQIP) (part of Div 5) recommending the inclusion of qualitative research and mixed methods research into the section on Discipline-Specific Knowledge Category 4: Research and Quantitative Methods.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)LavitaNadkarniNational Council of Schools and Programs of Professional PsychologyNCSPP would like to express its continued appreciation (previously reflected in comments related to this IR submitted during Phase I and Phase II of the public comment period) for allowing programs to exercise discretion in determining the appropriate means of supporting core competency development. However, it remains our unequivocal perspective that the delineation as proposed is unnecessary and uneven, and clearly sets two different standards for level of knowledge acquisition. Therefore, NCSPP proposes eliminating subsections i and ii of this IR and amending section (a) to establish a single, universal standard that reads as follows: a)…represents the requisite knowledge of psychology an individual must have to attain the profession-wide competencies. The Program must describe how its curriculum enables students to demonstrate graduate-level discipline-specific knowledge. Additionally, NCSPP suggests that Discipline-Specific Knowledge Category 3: Advanced Integrative Knowled... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)SueMotulsky I endorse Heidi Levitt and the Executive Committee of SQIP (Society for Qualitative Inquiry in Psychology)and agree with their comments about adding qualitative and mixed methods to the requirements of training programs.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)ElizabethFein In regard to Discipline-Specific Knowledge Category 4: Research and Quantitative Methods, I support the recommendation by the SQIP executive board that qualitative research be specifically included along with quantitative methods and psychometrics. Qualitative methods are foundational to the field of psychology, and were the basis of work by Freud, James, Dilthey, Wundt, and many others. They are an increasingly important part of psychology research in the present time as well. Students should be familiar with this component of our discipline.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)LeeBach I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods in the curricula of schools whose mission is to train students to be psychologists.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)CourtneyMcCluney "I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods."
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)PhyllisFlorian I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods. Qualitative methods of research serve to enrich the overall discipline of psychology. These methods have found a respected place in academic research. Undertaking research using qualitative methods enhances the overall diligence and rigor of the student of psychology.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)RuthellenJosselson To label Category 4 "Research and Quantitative Methods" privileges quantitative over qualitative methods. The "research methods" division of APA is now called "Quantitative and Qualitative Methods." Indeed, many clinical and counseling Ph.D. students do meaningful research using a qualitative approach to inquiry and need equal exposure to and training in this approach. I think this requirement should give equal weight to these two approaches.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)Susan GGoldberg As a member of SQIP (Section of Div 5), I am writing in support of the group comment made by SQIP about the inclusion of orientation and training in qualitative methods in the revised APA accreditation requirements. Qualitative research training involves the development of skill sets that have direct value for clinicians, whereas quantitative research training contributes less in this regard. More qualitative research is urgently needed to address significant gaps in the evidence base for treatments. Please see http://ejop.psychopen.eu/article/view/750
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)AaronRochlenCollated Board Comments of CCPTP 1 Qualitative methods: For the DSK IR there was expressed concern about qualitative methods not adequately being addressed. A few expressed is that excluding qualitative methods is an oversight, given the value of this work to our field. Is it possible to request exposure so that all students have some sense of qualitative methods and their validity in answering important research questions? 2 Additional DSK question on C-7D: The descriptions of the areas of DSK and how CoA will assess whether or not programs have ensured that students have DSK and advanced integrative DSK are clear. However, there are a few aspects that could be clarified further:  1. "By establishing foundation knowledge in this manner, trainees will have the opportunity to have educational experiences during the graduate program that, while by themselves are considered insufficient, will allow for considerable depth when the entirety of their educational records are considered"  - What types of educational expe... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)ElizabethKassoff  In my view, and I think this is consistent with the prevailing psychotherapy outcome research, the line under "VII Interventions" which reads: "establish and maintain effective relationships with the recipients of psychological services" should read something more to the effect: "establishing and maintaining effective relationships with the recipients of psychological services is the foundational first principle of competent psychotherapeutic training--and as such should be accorded priority status in CoA accredited clinical graduate prog
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)SprottRichard As a member of the Society for Qualitative Inquiry in Psychology, I urge the APA to include qualitative design and analysis as a key area in DSK - 4 : Research and *Quantitative* Methods. Advances in qualitative design, analysis and methods has resulted in a large body of empirical research that will affect health service psychological practice, and has created central concepts to understanding psychology as a science, with clear clinical implications. I point to designs and analytic methods such as classic grounded theory, interpretive phenomenological analysis, Carol Gilligan's "listening guide" method, and Robert Yin's work on rigorous case study methods.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)KirkSchneider I'm writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)DeboraBell I fully support the Council of University Directors of Clinical Psychology (CUDCP) comment on this IR.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)CrystalCollier I support and endorse Dr. Lavita Nadkarni's comments from NCSPP.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)WendyPeters I am writing in support of the group comment made by the SQIP executive committee about qualitative methods being included as part the training curriculums. It seems to me that understanding research, being able to do it, even informally, and keeping up with relevant social science literature makes this imperative. The future belongs to the qualitative world, in many respects, and to deprive students from accessing this valuable and fascinating area of research is a mistake. (Besides, most journal readers just skip over the statistical bits of articles anyway. Its an esoteric language, by and large, of specialists.) methods in the revised APA accreditation requirements
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)BeverlyPalmer In Discipline Specific Category 4 I strongly suggest qualitative methods be added. Division 5 of the APA now contains a Qualitative Inquiry Section. Qualitative methods can yield important psychological knowledge that quantitative methods often miss. Students are then given additional tools to research important questions in psychology.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)TimCavellCUDCPThe Council of University Directors of Clinical Psychology (CUDCP) would like to thank CoA for their continued hard work on the Standards of Accreditation and accompanying Implementing Regulations. We welcome the opportunity to comment on this draft revision of IR C-7: Discipline Specific Knowledge. This response represents the views of the CUDCP membership as discussed at our recent Midwinter Meeting and compiled by our Board of Directors. We have encouraged individual CUDCP member programs to review the IR and make their own comments, as well as to endorse or otherwise comment on this response. A. GENERAL REACTION: We are generally pleased with CoA’s obvious efforts to attend to the serious concerns we raised regarding the early 2016 draft revision. We believe that this draft returns us more closely to the goals of the SoA and gives programs greater flexibility in enabling their students to benefit from the most current, and continually evolving, knowledge base in psychology. In ... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)BethanyTeachman I fully support the CUDCP comment on this IR
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)DeboraBell I fully support the Council of University Directors of Clinical Psychology (CUDCP) comment on this IR.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)michaelsipiora"I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods."I am writing in strong support of the comment made by the SQIP executive committee about the inclusion of qualitative methods.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)GaryHowell I support and endorse comments from NCSPP.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)KelliJohnson I am writing to support and endorse NCSPP's response concerning all sections.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)JeffBakerAPPICAPPIC response to proposed SoA Implementing Regulation Revisions The Association of Psychology Postdoctoral and Internship Programs (APPIC) represents 798 Health Service Psychology Internship training programs and 194 Health Service Psychology Postdoctoral training programs. The APPIC Board greatly appreciates the opportunity to comment on proposed revisions to the SoA Implementing regulations. With regard to IR C-7 D Discipline-Specific Knowledge, we appreciate the clarity the proposed revision adds to required elements of doctoral level curriculum and have no concerns. With regard to C-14 D Direct Observation in doctoral program, the proposed revision adds clarity without changing the actual requirements or adding any burden on doctoral level practicum training. With regard to C-8 D, C-8 I, and C-9 P Profession-Wide Competencies, we generally appreciate the precision the proposed revisions add but there is some concern by what is meant by the two added bulleted items unde... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)HeidiLevittThe Executive Committee of the Society for Qualitative Inquiry in Psychology (Section of APA's Division 5)The Executive Committee of the Society for Qualitative Inquiry in Psychology (SQIP), a section of APA Division 5 (Quantitative and Qualitative Methods) recommends the inclusion of qualitative research and mixed methods research into the section on Discipline-Specific Knowledge Category 4: Research and Quantitative Methods. We recommend that this inclusion detail topics such as philosophies of science (e.g., ontology and epistemology), methodologies, methods of data collection/generation, methods of data analysis, criteria for evaluating quality, qualitative research ethics, researcher reflexivity, and the mobilization and dissemination of these research approaches (see implementation suggestion below). We are at a point in our profession in which the publication of these methods has been rising steadily (Hays, Wood, Dahl, & Kirk-Jenkins, 2016; Ponterotto, 2005a; 2005c). These methods (e.g., phenomenology, grounded theory, discourse analysis, narrative research, consensual quali... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)KelliJohnson I am writing to support and endorse NCSPP's response concerning all sections.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-7 D. Discipline-Specific KnowledgeDiscipline-Specific Knowledge (DSK)LeahHorvath I endorse the NCSPP comments for all sections.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationYakushkoOksana It is notable that the Direct Observations reflects practices and resources of Research 1 universities. Moreover, this regulation entirely disregards that for many diverse communities who have been marginalized and who indeed are now at great and grave risk from the governmental and other agencies themselves, are then required to allow for their therapy to be not just observed but recorded. Thus, this regulation clearly privileges settings where privileged people not worried about their social, political, or personal status can be observed by an external party. It may be far more valuable to encourage supervisors to begin to address how unconscious, implicit as well as implicit social issues (including receiving therapy from "labs" or "clinics" on campuses or in government institutions) influences people's capacity to build relational rapport with their therapists as well as to heal within a safe therapeutic environment.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationDu PlessisLiza I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationDu PlessisLiza I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationPasqualeBernadetteVA Psychology Training CouncilThe VA Psychology Training Council (VAPTC) supports the revisions to this IR for direct observation. The revisions clearly indicate the need for direct observation at the doctoral program level for all evaluations of competencies. We believe that direct observation is critical in the process of supervision with respect to providing formative and evaluative feedback. As the supervisory literature indicates, trainees may be lack the self-assessment capacity to recognize underdeveloped competency areas and/or trainees may be reluctant to disclose/discuss areas of weakness during supervision. Thus, direct observation in all practicum settings is crucial.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationHidekoSeraNCSPPI support and endorse Dr. Lavita Nadkarni's comments from NCSPP.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationLoringIngraham Dear Colleagues, As the Program Director and the Director of Clinical Training of an APA accredited doctoral training program in health service psychology we are writing with questions and comments about the proposed IRs for the new SoA. In particular, we would very much like to be able to have clarification in the IRs as to how best to address C-14 D (Direct Observation) of all training experiences. As supervisors, we value direct observation and wish to be compliant with both the letter and spirit of the SOA and associated IRs. Our students train in multiple settings including our in-house clinic (which has excellent video capability) and also may train at several of more than fifty local sites, not all of which are currently set up for direct observation. In particular, some community sites we highly value (and who highly value our services) may be unable to provide direct observation by on-site supervisors, and do not have the resources for secure video recording. The commun... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationBarryTammyWashington State University Clinical Psychology Doctoral ProgramI fully support the Council of University Directors of Clinical Psychology (CUDCP) comment on this IR.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationTimCavellCUDCPThe Council of University Directors of Clinical Psychology (CUDCP) would like to thank CoA for their continued hard work on the Standards of Accreditation and accompanying Implementing Regulations. We welcome the opportunity to comment on this draft of IR C-14 D Direct Observation. WE ARE GENERALLY PLEASED WITH THIS DRAFT AND HAVE ONLY TWO COMMENTS. 1. We would request that the following statement “Supervisors conducting direct observation must be appropriately trained, credentialed, and prepared in their discipline and in the health service psychology activities being supervised, legally authorized for independent practice in their jurisdiction, and legally responsible for the direct service activity” be modified as follows: “Supervisors conducting direct observation must be appropriately trained, credentialed, and prepared in their discipline and in the health service psychology activities being supervised, legally authorized for independent practice (or training a... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationGaryHowell I support and endorse Dr. Lavita Nadkarni's comments from NCSPP.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationDeboraBell I fully support the Council of University Directors of Clinical Psychology (CUDCP) comment on this IR.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationJessicaAndradeBoard of Educational AffairsThe Board of Educational Affairs (BEA) thanks the Commission on Accreditation for the opportunity to provide comment on the draft Direct Observation for doctoral degree programs Implementing Regulation (IR). BEA reviewed this draft IR and provide their comments below: CoA has provided clarification of Direct Observation (DO) IR for doctoral programs related to setting, requirements for the supervisor conducting the observation, and the nature and number of competencies to be included in DO. BEA is very much in support of including DO as integral to competency based training. The clarifications provide more detail and serve to emphasize the importance that CoA places on DO in doctoral training programs. To provide additional context, a relatively recent survey of practicum site coordinators (Hatcher, Wise, Grus, Mangione & Emmons, 2012) revealed that most supervision, outside of academic training clinics, is conducted primarily via verbal self-report (98%). Of concern is the findi... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationDeboraBell I would further encourage CoA to assist programs in considering how to address challenges in implementation of direct observation. There are understandably many challenges in implementation in settings that may be geographically remote, have strict confidentiality or security policies that limit the ways in which observation may occur, or serve clients who are reluctant to be observed. However, given that supervisors are pedagogically, ethically, and legally responsible for the students they supervise and for the clients whose care they supervise, it seems not only reasonable but critical that supervisors have direct, observed evidence of student competencies. CoA's guidance in implementation of this procedure across very diverse settings and constraints will be important to the success of this advance in quality assurance.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationKarenFondacaroAPTC-Association of Psychology Training Clinics APTC supports the Direct Observation IR as delineated by CoA. One APTC director added that the CoA may want to, over time, increase the number of required evaluation periods.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationPuliattiReneCalifornia Psychology Internship Council (CAPIC)Training at the practicum level is currently outside CAPIC's area of responsibility, although CAPIC supports the value of direct observation in the supervisory training, so long as it does not unduly burden training sites. CAPIC recommends further consideration of audiotaping, as suggested by NCSPP, as a means to address CoA’s concerns, particularly absent research for invalidating it as an evaluative method. CAPIC also strongly encourages CoA to review this and all Implementing Regulations (IR's) for any unintended consequences on the profession and the public. As CAPIC has previously stated, IR's often have powerful impact on members by virtue of the IR's arising from the CoA which has the power to grant, limit or deny accreditation to its members. CAPIC also continues to contend that IR D-4-7(b) negatively impacts the diversity of the profession as well as and the diversity of populations served, by undervaluing valid quality unaccredited agencies and programs which serve d... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationBradRoperSociety for Clinical Neuropsychology (APA Division 40)The Society for Clinical Neuropsychology welcomes the opportunity to comment on draft regulations regarding Direct Observation. We understand that the draft IR requires that at least one instance of direct observation be made per practicum rating by the appropriately credentialed psychologist. The draft IR also recognizes that supervision may take place by an intern or “postdoctoral fellow” but that the observation must be made by the supervisor who is legally responsible for service activities. (We would note that “resident” and “residency” is the term used within the SoA, and not “fellow.”) We also believe that practicum students, and especially those entering initial experiences in clinical neuropsychology, may legitimately receive training from psychological examiners or technicians on the administration and scoring of neuropsychological tests. Additionally, we note that practicum students in academic health settings may receive supervision in the context of integrated care teams t... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationEveAdams I still need further clarification of the following paragraph, "Per IR C-12 D, it is recognized that supervision on site can be provided by doctoral interns or postdoctoral fellows in health service psychology under the supervision of a psychologist appropriately credentialed in the jurisdiction. In these situations, the direct observation requirement may only be met by having the appropriately credentialed supervisor(s), legally responsible for the direct service activities, conduct the observation and evaluation." The first sentence of this paragraph suggests that some parts of the supervision can be provided by someone who is not yet independently licensed as long as they are being supervised by someone who is independently licensed. If that's the case then that should be stated in the paragraph about who can be a supervisor. Additionally, I think it is wrong to require in the second sentence of the paragraph that only the licensed supervisor must conduct the evaluation of t... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationKellyNichole As a faculty member at the University of Oregon, this requirement would be very difficult to implement in regards to lack of resources, and, if required, would impede our ability to provide training and clinical care to already marginalized patient populations (e.g., folks living in rural communities).
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationCynthiaRohrbeck I agree that this is good practice, but do not believe it needs to be applied across the board. Some training programs may have difficulty implementing this due to cost issues, etc.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationJessicaApfel I think in theory it is a good idea but very difficult for some programs to implement. I think the regulations should be more flexible in the types of observations allowed and also to not require, but maybe strongly encourage.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationKristaChronister This regulation is ideal, good practice. I completely see the value of direct observation. However, I am not in favor of approving this regulation because (a) it is not feasible for programs to implement and (b) it is difficult to implement direct observation with some of our more underrepresented, under-served communities (e.g. rural populations, working in agencies that are non-profit or poorer).
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationJessicaCronce Direct observation is a key tool in helping trainees develop clinical competence. Directly observing students as part of their overall training is essential; however, my colleagues and I are not in favor of the proposed regulation as written. Requiring direct observation to be a part of the performance evaluation for every practicum experience is not practical and may severely limit the variety of training opportunities in which students may engage. It may most negatively impact programs that heavily rely on externships that are geographically dispersed, especially if these settings have strict regulations regarding use of recording devices or serve populations that may be more uncomfortable with the use of recording. Greater flexibility in the regulation would likely best support both breadth of training and individual pursuit of specialization.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationRadhikaKrishnamurthy I endorse NCSPP's response concerning Direct Observation(C-14 D).
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationRobertPerl I endorse the NCSPP response for all sections.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationCindyMcGearyIntern Training CommitteeWhile I certainly agree there is benefit to direct observation, I cannot support this regulation. There is very little flexibility with this regulation and it would be very difficult to implement at different clinical training sites for every evaluation period. Perhaps direct observation could be highly encouraged, but not mandated.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationMiltonFuentes I support NCSPP comments.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationDeniseDeBarre Many trainees report no experience with direct observation of their test administration (e.g., WAIS-IV) in their doctoral programs. Doctoral programs should require such observation in order to ensure competency in test administration, following the standard procedures.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationLotteSmith-Hansen The direct observation requirement is a welcome addition, in my opinion. I agree it should be required for all practicum experiences at every level of training. It would be helpful to get clarification on whether students' clinical jobs outside of formal graduate program practicum experiences (counted as program-sanctioned work experiences on their internship applications) should also be subject to this requirement. I would recommend that PSWE supervisors should not be required to engage in direct observation, partly because students are always already getting direct observation at their regular practicum sites, partly because it may limit where students can go for PSWE which would impose even more financial burden on them than they are already shouldering.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationJulieRadicoCommittee on Early Career PsychologistsThe Committee on Early Career Psychologists (CECP) appreciates the Commission on Accreditation’s (CoA) work in continuing efforts to revise the Implementing Regulations for Direct Observation (IR). The IR states that training sites which do not permit in-person observation, live simultaneous audio-video streaming, or audio-video recording will not meet the requirements of direct observation. Whereas, ensuring that students are receiving feedback based on a form of observation is commendable and something we support, as it enriches their training, we are concerned that this regulation may limit the number of practicum sites available. There are many sites for which audio-recording is the standard and most feasible practice. Additionally, there are sites for which no recording is permitted due to the setting (e.g. inpatient). The CECP encourages the CoA to consider providing practicum sites with continued use of audio recording, otherwise long grace periods will be necessary to initiate ... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationGinaRaza I agree that direct observation has benefits, but within internship and post doc, it can vary as to which supervisors observe directly versus through audio recordings or other means (e.g., role play and session reviews). The current structure of this regulation seems more likely to create a burden on sites and trainees than to result in a training benefit.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationGayleNorbury I fully support direct observation given the range of options offered and available and the minimal amount required to meet this standard. Self report by a student is not adequate for practice. Given supervisors meet one on one with students for supervision this requirement can be met by jointly meeting with a client for this observation given the client already knows they are working under supervision.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationLavitaNadkarniNational Council of Schools and Programs of Professional PsychologyNCSPP appreciates the increased specificity that has been added to this IR. As indicated during Phase I and II, NCSPP remains concerned that audiotaping is not an acceptable alternative to video and live observation, particularly in the absence of research to suggest that audiotaping offers significantly different evaluative data. It is recommended that this be reconsidered, and that audiotaping be explicitly included as a valid alternative for direct observation.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationMeganO'Banion I endorse the NCSPP response for C-14 D. Direct Observation.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationDavidPantaloneUniversity of Massachusetts, BostonThe Clinical Psychology Doctoral Program at UMass Boston fully supports the CUDCP comment on this IR.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationCallahanJenniferOn behalf of the 9 faculty in the APA-accredited Clinical Psychology Program at the University of North TexasWe fully support the Council of University Directors of Clinical Psychology (CUDCP) comment on this IR.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationAaronRochlenCollated Board Comments of CCPTP Direct Observation C-14: This DO IR has gained a great deal in specificity from the original IR; however, concern remains that this requirement may impinge on opportunities for supervision during internship and post-doc because it says that the supervisor of supervision must also directly observe the work of the supervisee.  Additional input: There was some further concern noted that it could have an unintended negative consequence in that sites that might have done more than one observation will only do one in the future, given that one is the bar that is set by CoA, an accrediting body. Additionally, the opportunity for students to do practicum at some highly sought after sites may be curtailed if that institutional policy dictates no taping.  In the past language such as “a preponderance of sites” must enage in such practices was used and the question is whether that language could be used again. Taking "e.g., visual impairment" out as an example decreases the clarity of this IR. ... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationCrystalCollier I support and endorse Dr. Lavita Nadkarni's comments from NCSPP.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationBrigidCahillACCTAThe Association of Counseling Center Training Agencies (ACCTA) is appreciative of the work the COA has put into developing and expanding the Implementing Regulations (IRs). We find it helpful that under the Direct Observation IR, it is stated “In the rare event or special circumstances where audio recording is the only feasible method of meeting this requirement, the program must explain any unique circumstances and why direct observation as defined above is not possible, as well as how the observation being performed is consistent with the spirit of this IR.” We are concerned about internship or practicum sites that provide services to underserved populations and may not have the resources to video record/stream or provide one-way mirror observation. We hope that CoA would see the value of training in such sites and make an allowance for audio recording in the context of limited resources. In addition, we are concerned that the IR could be interpreted in such a way that the doctor... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-14 D. Direct ObservationDirect ObservationNabilEl-GhorouryAPAGSThe American Psychological Association of Graduate Students (APAGS) is pleased to comment on the latest draft of the Commission on Accreditation’s (CoA) Standards of Accreditation for Health Service Psychology (SoA). APAGS is supportive of the proposed IRs; however, we wish to make the following recommendations that would improve the standards and their implications for the training experiences of graduate students. • We would like clarification regarding the amount of direct observation contact that needs to be conducted (e.g., 1 hour per semester). • We would also like clarification regarding whose supervision can count as direct observation. For example, can LCSWs, MFTs, and MDs supervise? At many sites, psychologists and other health care professionals may supervise students. The current statement, “Supervisors conducting direct observation must be appropriately trained, credentialed, and prepared in their discipline and in the health service psychology activities being superv... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)HeidiLevitt I agree with Steve Smith's comment about attention to diverse basic theoretical orientation theory. Given the well established finding of psychotherapy equivalence, it seems that theoretical knowledge and some basic skills in multiple theoretical orientations should be necessary for psychologists. As psychologists, we need some fluency across the major theoretical orientation camps to equip us to supervise and develop research that is grounded in a depth of understanding of the processes of change and values intrinsic to each theoretical orientation culture. Increasingly, clinical psychology programs are losing theoretical orientation diversity and if we are to have intellectual diversity in our traditions then some attention should be paid to having instructors with expertise in less well represented traditions (e.g., humanistic-existential, psychodynamic-interpersonal) who can not only expose students to these theories but help them understand their epistemological framework, re... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)ElizabethBrisola I am writing to support SQIP executive committee's comment regarding the inclusion of qualitative methods.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)BarryDauphinDivision 39 Education and Training CommitteeThe current text in VII. Intervention, paragraph 2, which precedes the bullet points of what students must demonstrate reads as follows: “Trainees demonstrate competence in evidence-based interventions consistent with the scope of Health Service Psychology. Intervention is being defined broadly to include but not be limited to psychotherapy. Interventions may be derived from a variety of theoretical orientations or approaches. The level of intervention includes those directed at an individual, a family, a group, an organization, a community, a population or other systems.” The text sets the context for the competencies. We believe that language mistakenly prioritizes techniques over competency in developing effective professional relationships across processes of assessment, psychotherapy, and other professional activities. Extensive research has shown the singular importance of the professional relationship in effective psychological work, more so than any particular technique.... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)NabilEl-GhorouryAPAGS• III. Individual and cultural diversity. We would like to propose an addition to the following statement, “The CoA recognizes that development of competence in working with individuals of every variation of cultural or individual difference is not reasonable or feasible.” We suggest adding a statement that expresses, although obtaining competence in working with individuals of every variation of cultural/individual difference is not feasible, trainees are expected to demonstrate knowledge, awareness, sensitivity, and skills to the fullest extent possible. • IV. Professional values and attitudes. It is unclear what the CoA means in reference to ‘feedback’ in the last bullet point here. Inserting ‘professional’ or ‘training’ in front of feedback may clarify, as it could be misconstrued as written that doctoral students/interns are expected to be openly responsive to all forms of feedback, including those outside the domain of training. • V. Communication and interpersonal skills.... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)PasqualeBernadetteVA Psychology Training CouncilThe VA Psychology Training Council (VAPTC) supports this revision to the Implementing Regulation to require knowledge of client strengths and psychopathology and the application of this with sensitivity to cultural and individual differences. These elements are fundamental to the assessment process and should be specifically required and consequently evaluated at the internship level to assure competency in this core domain.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)TimCavellCUDCPThe Council of University Directors of Clinical Psychology (CUDCP) would like to thank CoA for their continued hard work on the Standards of Accreditation and accompanying Implementing Regulations. We welcome the opportunity to comment on this IR. WE ARE GENERALLY PLEASED WITH THIS DRAFT AND HAVE NO ADDITIONAL COMMENTS. This response represents the views of the CUDCP membership as discussed at our recent Midwinter Meeting and compiled by our Board of Directors. We have encouraged individual CUDCP member programs to review the IR and make their own comments, as well as to endorse or otherwise comment on this response.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)BarryTammyWashington State University Clinical Psychology Doctoral ProgramI fully support the Council of University Directors of Clinical Psychology (CUDCP) comment on this IR.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)JessicaAndradeBoard of Educational AffairsThe Board of Educational Affairs (BEA) thanks the Commission on Accreditation for the opportunity to provide comment on the draft Profession-Wide Competencies for doctoral degree and internship programs Implementing Regulation (IR). BEA reviewed this draft IR and provide their comments below: We appreciate the freedom to “… use a variety of methods to ensure trainee competence, consistent with their program aim(s), degree type, and level of training” while adhering to this SOA competency requirement. It is important to highlight differences across levels – and the graded expectations across from doctoral, internship, and postdoctoral fellowship. Introduction Doctoral students: • Conduct research or other scholarly activities. -- This is a vague statement that can be strengthened by noting the EXPECTATION to produce new research and not just a critical literature review to meet this standard.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)YakushkoOksana - Recent longitudinal data on programs, accredited by the American Psychological Association, show that the doctoral training is becoming dramatically “less intellectually diverse” and offers an ever “narrowing” training, leading to “monocultural” approaches, currently represented by the Cognitive-Behavioral (CBT) methods (see Levy & Anderson, 2013 for data and review). New “standards” of accreditation appear to propose to further contribute to this creation of the “monoculture.” Multiple scholars have highlighted that this narrowing of psychotherapy orientations has significant and negative impact on the field (e.g., Heatherington et al., 2012) and contradicts available scientific data that shows that many of the approaches alternative to CBT, are as or more effective (Abbass et al., 2006; Leichsenring & Rabung, 2008; Levy et al., 2013; Shedler, 2010; Wampold et al., 2011; Weisz et al., 2009). This narrowing could not have occurred if it were not explicitly and implicitly supported by... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)DeboraBell I fully support the Council of University Directors of Clinical Psychology (CUDCP) comment on this IR.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)AllanScholom > "Both research and clinical practice have have unequivocally demonstrated > the fundamental importance of the therapeutic relationship across all > treatment approaches. It is the foundation out of which any change process > emerges. > As relationships are the common link between all treatment approaches, this thereby allows > for a diversity of proven choices and options for the public. This grants > people the freedom to access the type of treatment most suited to their > individual needs from all of the theoretical modalities, whether they be > short or long term. Anything less moves toward monopoly, restriction and > exclusion, which does not serve the public. I therefore advocate for more > strongly emphasizing the importance of the therapeutic relationship and the > greater freedom of choice of approach and practitioner that follows from > this. This is the most inclusive way to provide services to the broadest > range of people and problems, thereby optimally se... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)YakushkoOksanaThe Psychotherapy Action NetworkComment to the Commission on Accreditation in Regard to Emphasis on Psychotherapy and Relationship in Accreditation Standards and Implementing Regulations February 1, 2017 The Psychotherapy Action Network, which includes a growing number of concerned practitioners, scholars, and activists is requesting for the Commission on Accreditation to review and address the following grave concerns in regard to accreditation of programs that license individuals to practice psychotherapy and other clinical applied work with human beings and diverse communities. An emphasis of current Standards and Implementing Regulations of the COA reflect neither current and past research (e.g., vital centrality of relationships in psychotherapy process and client healing/change; empirical evidence of multiple theoretical orientations, specifically psychoanalytic and psychodynamic in treatment of a wide range of disorders; lack of actual evidence behind supposed evidence based manualized treatments). In... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)KarenFondacaroAPTC-Association of Psychology Training ClinicsOverall, APTC supports these profession-wide competencies. Competencies regarding Professional Values and Communication and Interpersonal Skills are a bit vague, although this is not surprising given the challenge of providing specificity regarding professionalism, interpersonal skills, and other non-technical competencies. This is an area for additional work in the field in general.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)PuliattiReneCalifornia Psychology Internship Council (CAPIC)CAPIC supports the comments of NCSPP in this matter on the need to include psychopathology in the profession-wide competency of both Assessment AND Intervention. CAPIC also strongly encourages CoA to review this and all Implementing Regulations (IR's) for any unintended consequences on the profession and the public. As CAPIC has previously stated, IR's often have powerful impact on members by virtue of the IR's arising from the CoA which has the power to grant, limit or deny accreditation to its members. CAPIC also continues to contend that IR D-4-7(b) negatively impacts the diversity of the profession as well as and the diversity of populations served, by undervaluing valid quality unaccredited agencies and programs which serve diverse and often underserved communities and often better meet the needs of diverse and non-traditional students.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)RadhikaKrishnamurthy I endorse NCSPP's response concerning Profession-Wide Competencies.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)MeganO'Banion  I endorse the NCSPP response for C-8 D, C-8 I, and C-9 P. Profession-Wide Competencies.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)DavidJaquess These revisions further clarify that direct observation is to be a primary basis of trainee evaluation, and the flexibility to use observation of simulated activity for "supervision and "consultation" competencies is delineated in the PWC IR's. It would be advisable to add this flexibility to the other functional competencies, as well. Because not every rotation includes assessment in all its forms AND intervention, it may be difficult to fabricate practicum experiences simply to meet the proposed requirements for direct observation. The final paragraph in C-14 D alludes to this issue; however, there presumably will be an expectation for internship programs to use direct observation to provide ongoing feedback about progression toward MLA's in ALL competency areas, and this will not naturally occur in every internship setting. Allowing supervisors to use simulated activities in ALL functional domains as necessary would fix this likely gap between giving periodic structured feedba... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)JulieRadicoCommittee on Early Career PsychologistsThe Committee on Early Career Psychologists (CECP) appreciates the Commission on Accreditation’s work in continuing efforts to revise the Implementing Regulations including the revision to make explicit that psychopathology is a necessary aspect of competency in assessment. CECP is supportive of this specification, as learning about psychopathology relates to empowering cultural awareness in doctoral students and interns and emphasizes the importance of a recovery-oriented model which is especially germane for individuals who experience serious mental illness.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)MiltonFuentes I support NCSPP comments and support the comment made by the SQIP executive committee about the inclusion of qualitative methods.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)LavitaNadkarniNational Council of Schools and Programs of Professional PsychologyNCSPP endorses rendering psychopathology an explicit element of the Assessment competency. However, we strongly advocate similar inclusion of psychopathology as an explicit aspect of the Intervention competency, for which “current knowledge of functional and dysfunctional behaviors, including consideration of client strengths and psychopathology” and “an ability to apply the knowledge of client strengths and psychopathology… with sensitivity to cultural and individual differences” is equally critical. To include psychopathology in the profession-wide competency of Assessment, and not in the profession-wide competency of Intervention, creates an artificial divide between the two and potentially devalues the latter. It is recommended that psychopathology and cultural/individual differences be incorporated into the current second bullet point under Intervention as follows: “Develop evidence-based intervention plans specific to the service delivery goals that demonstrate knowledge of clie... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)KirkSchneider In my view, and I think this is consistent with the prevailing psychotherapy outcome research, the line under "VII Interventions" which reads: "establish and maintain effective relationships with the recipients of psychological services" should read something more to the effect: "establishing and maintaining effective relationships with the recipients of psychological services is the foundational first principle of competent psychotherapeutic training--and as such should be accorded priority status in CoA accredited clinical graduate programs"
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)BufkaLynnAdvisory Steering Committee for the Development of Clinical Practice GuidelinesIn the section C-8 D, C-8 I, and C-9 P. Profession-Wide Competencies (on p. 10), the proposed text lists: • Consistency with the existing and evolving body of general knowledge and methods in the science and practice of psychology (SoA Introduction, Section II.B.2.d). The CoA expects that all profession-wide competencies will be grounded, to the greatest extent possible, in the existing empirical literature and in a scientific orientation toward psychological knowledge and methods. We propose an addition to this important criterion to help programs clarify ways to obtain competency in this area. Specifically, we propose to add the following to the text: “For example, showing competency in the delivery of assessments and treatments that are recommended by clinical practice guidelines based on systematic reviews of the existing empirical literature would be one way to demonstrate competence in this area.”
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)MiltonFuentes I support NCSPP comments and support the comment made by the SQIP executive committee about the inclusion of qualitative methods.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)EdwardHunterUniversity of Kansas Medical Center Psychology InternshipThis seems like a welcome addition to the IR's. We have noticed improvement in the preparation of doctoral students who come into our internship regarding psychopathology in particular. However, we still get applicants who eschew a diagnosis. We don't rank such applicants because they have been taught to think in ways that are not consistent with a diagnosis leading to a treatment. Certainly the strengths of the individual also need to be noted in any such assessment.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)DavidPantaloneUniversity of Massachusetts, BostonThe Clinical Psychology Doctoral Program at UMass Boston fully supports the CUDCP comment on this IR.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)EricSchwartz I appreciate the work of the CoA on improving and broadening the language that is used to define and support the profession-wide competencies. In particular, is the CoA's effort to expand on the concept of evidence-based practice. This is a welcome effort, particularly when, in many practice contexts and situations interns are working with highly complex, multiproblem, individuals and systems. An additional shift in the way in which we think about the use of the term "evidence-base" might be helpful. For example, some of the language used, such as "modify and adapt evidence-based approaches effectively when a clear evidence-base is lacking" may give the impression that there is a definitive set of evidence-based practices, which should be effectively adapted or modified. I would suggest the following: Develop, modify, adapt and/or incorporate interventions found to be effective in the current professional literature and/or develop interventions based on the use of specific data o... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)SteveSmith There's no/little mention of clinical theory as part of intervention training. Rather than training clinical technicians who merely "implement interventions," we should be training flexible practitioners who have the capacity to understand how an intervention fits a larger conceptual framework (i.e., why, not just how). Finally, students should be trained to critically evaluate the "evidence" of evidence-based interventions.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)CharleneSenn I am writing in support of the comment made by the SQIP executive committee about the inclusion of qualitative methods.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)AaronRochlenCollated Board Comments of CCPTPPsychopathology and Cultural Considerations: An IR was modified to ensure psychopathology and strengths were covered and understood through culture and individual differences. An expressed concern that this could be further strengthened by not solely examining cultural and individual difference, but also by understanding expressions of psychopathology and strength and the impact of environmental barriers through the lived experience of marginalized people.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)AaronRochlenCollated Board Comments of CCPTPQuestions of “Evidence Based” Concerns: Overall, positive comments on these revisions. However, some expressed concerns on ever narrowing definitions of “evidence” (research methods/quant approaches) and not addressing systemic issues of oppression. In previous versions there seemed to be a wider range of data considered as “evidence,” including one’s clinical expertise. 
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)CrystalCollier I support and endorse Dr. Lavita Nadkarni's comments from NCSPP.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)BrigidCahillACCTAThe Association of Counseling Center Training Agencies (ACCTA) is appreciative of the work the COA has put into developing and expanding the Implementing Regulations (IRs). Assessment Competency: We strongly support the inclusion of knowledge and application competencies in the Assessment section. We would however like to see the language adjusted to be less pathologizing and more social justice focused– such as (changes in italics): “Current knowledge of the range of human functioning, including consideration of client strengths and mental distress….The ability to apply the knowledge of client strengths and mental distress to the assessment process with sensitivity to a wide range of cultural and individual differences, including the effects of social and environmental factors on client wellness.” Research Competency: Although there were no changes to the Research Competency IR, we would like to reiterate our concern expressed in the last call for comment. Internship is a dire... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)ElizabethBrisola I am writing to support SQIP executive committee's comment regarding the inclusion of qualitative methods.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))C-8 D, C-8 I, and C-9 P. Profession-Wide CompetenciesProfession-Wide Competencies (PWC)KirkSchneider I want to add to my former statement. See last paragraph for the addendum: In my view, and I think this is consistent with the prevailing psychotherapy outcome research, the line under "VII Interventions" which reads: "establish and maintain effective relationships with the recipients of psychological services" should read something more to the effect: "establishing and maintaining effective relationships with the recipients of psychological services is the foundational first principle of competent psychotherapeutic training--and as such should be accorded priority status in CoA accredited clinical graduate programs" Note: We need something that presses for priority status for the relational-contextual dimension that alerts site visitors to approving programs that hire more humanistic-relational faculty (vs. the present domination of about 80% by CBT faculty), more courses in this dimension, and more time to emphasize this dimension. This is all very compatible with the ... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (a). Use of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(a))JessicaAndradeBoard of Educational AffairsThe Board of Educational Affairs (BEA) thanks the Commission on Accreditation for the opportunity to provide comment on the draft Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs Implementing Regulation (IR). BEA reviewed this draft IR and provide their comments below: BEA acknowledges and appreciates the level of transparency and detail with which CoA describes the success indicators, their linkage to the standards of accreditation, and the process by which programs can provide supplemental information to avoid adverse action. While the accredited internship acceptance rate is a very appropriate success indicator, we are concerned that this indicator may disproportionately impact school psychology programs. While the number of accredited internship positions has increased substantially, there are still many internship sites that prefer counseling or clinical psychology students over school psychology students or may not accept applications... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (a). Use of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(a))NabilEl-GhorouryAPAGS• In explaining the thresholds as indicators, the first ‘success indicator’ is mentioned first as “Number of years to complete program” and then later as “Time to degree.” We propose that one indicator is chosen to alleviate confusion (e.g., call this “Number of years to complete program” consistently).
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (a). Use of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(a))TimCavellCUDCPThe Council of University Directors of Clinical Psychology (CUDCP) would like to thank CoA for their continued hard work on the Standards of Accreditation and accompanying Implementing Regulations. We welcome the opportunity to comment on this IR. WE ARE GENERALLY PLEASED WITH THIS DRAFT AND HAVE NO ADDITIONAL COMMENTS. This response represents the views of the CUDCP membership as discussed at our recent Midwinter Meeting and compiled by our Board of Directors. We have encouraged individual CUDCP member programs to review the IR and make their own comments, as well as to endorse or otherwise comment on this response.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (a). Use of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(a))HidekoSeraNCSPPI support and endorse Dr. Lavita Nadkarni's comments from NCSPP.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (a). Use of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(a))BarryTammyWashington State University Clinical Psychology Doctoral ProgramI fully support the Council of University Directors of Clinical Psychology (CUDCP) comment on this IR.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (a). Use of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(a))GaryHowell I support and endorse comments from NCSPP.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (a). Use of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(a))DeboraBell I fully support the Council of University Directors of Clinical Psychology (CUDCP) comment on this IR.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (a). Use of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(a))KarenFondacaroAPTC- Association of Psychology Training ClinicsIn general, APTC supports annual reporting as is currently required. Failing to meet a threshold appears to result in further discussion and review - not immediate action. We advocate for APA to make these thresholds publically available on their website. Programs should be able to self-monitor to determine if they are failing to meet thresholds based on data across the nation rather than solely relying on being flagged by APA.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (a). Use of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(a))PuliattiReneCalifornia Psychology Internship Council (CAPIC)CAPIC strongly supports the comments of NCSPP in this matter on the need to include qualitative factors, and not exclusively rely on quantitative ones, in order to properly evaluate a program's success, particularly its ability to address the individual needs of diverse and non-traditional students. CAPIC also has similar concerns with the CoA exercise of "professional judgment" to determine the adequacy of a program's response. As stated in previous Public Comments and other forums, CAPIC strongly opposes CoA's use of numerical quotas as an accreditation standard (i.e. the 50% threshold rule of IR D 4-7(b)), particularly absent strong evidence of the superiority of APA-accredited internships. CAPIC has directly responded to the contention of APA superiority: (Morrison, A., Schaefer, M., Ribner, N., & Puliatti, R. (January 2015). Training healthcare psychologists: Outcomes from multiple models.). Subsequent studies, both pending publication, have also found no significant diffe... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (a). Use of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(a))MiltonFuentes I support NCSPP comments.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (a). Use of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(a))DavidKahn The four success indicators used to evaluate a program on an annual basis (Number of years to complete program; Percent of students leaving a program for any reason; Proportion of students accepted into an accredited (APA or CPA-accredited) internship; and Changes in faculty-student ratios) are all fair and valid indicators. In addition to these indicators, the Commission should require programs to provide a list of the agencies being used for practicum sites and to indicate whether or not the agency has a doctoral level licensed psychologist on site to supervise students. Programs that do not have agencies with a doctoral level licensed psychologist available to provide supervision should be "flagged." Since APA recognizes the doctoral degree and doctoral level licensure as a psychologist as the entry level for independent practice, this is the standard that many internship programs, post-doctoral training programs, and full-time positions recognize when determining the appropriaten... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (a). Use of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(a))RadhikaKrishnamurthy I endorse the NCSPP response for D.4-7, Use of Annual Reports.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (a). Use of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(a))DavidPantaloneUniversity of Massachusetts, BostonThe Clinical Psychology Doctoral Program at UMass Boston fully supports the CUDCP comment on this IR.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (a). Use of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(a))LavitaNadkarniNational Council of Schools and Programs of Professional PsychologyNCSPP acknowledges and appreciates the enhanced transparency and detail reflected in the proposed revisions to IR D.4-7, particularly in relation to the process by which CoA will seek additional information from programs which might initially appear, based upon the success indicators, to be experiencing changes that might compromise compliance with accreditation standards. NCSPP further appreciates CoA’s formalization of a process by which programs can provide additional explanatory information that can support avoidance of adverse action. Two significant and inter-related concerns remain: The exclusive use of quantitative examples when describing factors that the Commission might deem mitigating when evaluating programs’ with sub-threshold success indicators, and the use of the phrase “professional judgment” to characterize the process by which the Commission will ultimately determine whether a program is required to show cause as to why it should not be placed on probation. T... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (a). Use of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(a))CallahanJenniferOn behalf of the 9 faculty in the APA-accredited Clinical Psychology Program at the University of North TexasWe fully support the Council of University Directors of Clinical Psychology (CUDCP) comment on this IR.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (a). Use of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(a))CrystalCollier I support and endorse Dr. Lavita Nadkarni's comments from NCSPP.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (c). Use of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(c))NabilEl-GhorouryAPAGS• We suggest providing clarification regarding what the narrative report offers above and beyond from the standard report. Also, we wonder if there is a way to combine these two in order to reduce the workload on the graduate program. APAGS thanks the CoA for the opportunity to comment on the proposed IRs. We appreciate the concern that CoA has for the voice of students and look forward to seeing the new standards implemented.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (c). Use of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(c))TimCavellCUDCPThe Council of University Directors of Clinical Psychology (CUDCP) would like to thank CoA for their continued hard work on the Standards of Accreditation and accompanying Implementing Regulations. We welcome the opportunity to comment on this IR. WE ARE GENERALLY PLEASED WITH THIS DRAFT AND HAVE NO ADDITIONAL COMMENTS. This response represents the views of the CUDCP membership as discussed at our recent Midwinter Meeting and compiled by our Board of Directors. We have encouraged individual CUDCP member programs to review the IR and make their own comments, as well as to endorse or otherwise comment on this response.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (c). Use of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(c))HidekoSeraNCSPPI support and endorse Dr. Lavita Nadkarni's comments from NCSPP.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (c). Use of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(c))BarryTammyWashington State University Clinical Psychology Doctoral ProgramI fully support the Council of University Directors of Clinical Psychology (CUDCP) comment on this IR.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (c). Use of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(c))JessicaAndradeBoard of Educational AffairsThe Board of Educational Affairs (BEA) thanks the Commission on Accreditation for the opportunity to provide comment on the draft Use of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs Implementing Regulation (IR). BEA reviewed this draft IR and supports the editorial changes.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (c). Use of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(c))DeboraBell I fully support the Council of University Directors of Clinical Psychology (CUDCP) comment on this IR.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (c). Use of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(c))KarenFondacaroAPTC- Association of Psychology Training ClinicsIn addition to the annual reporting required, it seems important to provide a narrative for any substantial changes in the program. However, requiring substantive narrative beyond what is already provided by the annual reporting system seems unnecessary.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (c). Use of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(c))RenePuliattiCalifornia Psychology Internship Council (CAPIC)Regardless whether an item is termed a “policy” or a “guideline” or an “outline,” its impact on members, and therefore the profession and the public is often profound, and must be reviewed with that impact in mind. CAPIC appreciates the inclusion of narratives to supplement quantitative monitoring of a program, particularly its ability to address the individual needs of diverse and non-traditional students. However, CAPIC has concerns with the CoA exercise of "professional judgment" to determine the adequacy of a program's response. As stated in previous Public Comments and other forums, CAPIC strongly opposes CoA's use of numerical quotas as an accreditation standard (i.e. the 50% threshold rule of IR D 4-7(b)), particularly absent strong evidence of the superiority of APA-accredited internships. CAPIC has directly responded to the contention of APA superiority: (Morrison, A., Schaefer, M., Ribner, N., & Puliatti, R. (January 2015). Training healthcare psychologists: Outco... See Full Comment
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (c). Use of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(c))PatriciaDixon I support the comments of NCSPP
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (c). Use of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(c))MiltonFuentes I support NCSPP comments.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (c). Use of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(c))DavidPantaloneUniversity of Massachusetts, BostonThe Clinical Psychology Doctoral Program at UMass Boston fully supports the CUDCP comment on this IR.
Implementing Regulations (DSK, Direct Observation, PWC, D.4-7(a) and D.4-7(c))D.4-7 (c). Use of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual ProgramsUse of Narrative Annual Reports for Reaffirmation of Accredited Status and Monitoring of Individual Programs (D.4-7(c))CrystalCollier I support and endorse Dr. Lavita Nadkarni's comments from NCSPP.