Accreditation Public Comment System

This project is now closed for new comments.

Document	Item	First Name	Last Name	Group Name	Comment
IR (PWC, D.4-7(b)) and AOP (Section 8.6) Revisions	Profession-wide Competencies	William	Strein		The changed wording, though stylistic, to bring "context" more to the foreground is an important change. Given the huge controversy around the DSM-5 I am surprised to see "diagnostic systems" gain so much more prominence. Given that the third bullet item reads "...to the assessment and/or diagnostic process", it would seem reasonable to use the same language for the first bullet point, i.e., some phrasing of "and/or" rather than making "diagnostic classification systems" mandatory.
IR (PWC, D.4-7(b)) and AOP (Section 8.6) Revisions	Profession-wide Competencies	Natasha	Maynard-Pemba	Association of Counseling Center Training Agencies	The Association of Counseling Center Training Agencies is in support of the increased focus on contextualizing (e.g., family, social, societal and cultural)the presentation of mental distress within the assessment competency.
IR (PWC, D.4-7(b)) and AOP (Section 8.6) Revisions	AOP Section 8.6	Myron	Hays	Central Bay Consortium	I understand that this is not a change that the CoA is implementing on its own, but it is the responsibility of the CoA to deal with the implications of it. This is a change which has the potential to have a huge impact on the students and public that accreditation is supposed to serve. Because psychology does not have any kind of “provisional accreditation” status, anyone entering a program is left wondering if the program will achieve accreditation prior to graduation/completion of the training. Since it is now APA policy that anyone working in health service psychology will complete an APA accredited degree program and (in a few years, an APA accredited internship), AND since the programs are not permitted to apply until they have someone in each cohort of a program, a program is stuck not being able to apply until (at the best) the first day of the first year of the internship/ residency (or first day of the internship year for a doctoral program). Anyone who has been throug...	See Full Comment
IR (PWC, D.4-7(b)) and AOP (Section 8.6) Revisions	AOP Section 8.6	Kathryn	Wortz		I would discourage the change to effective date of a decision, as the last day of the site visit appears to be a more equitable choice. For one, keeping the effective date of accreditation at the site visit marker encourages programs to schedule the site visit sooner rather than later. This is important so that site visits don't get delayed until the cut-off before a CoA meeting, leading to a "stacking up" of site visits near the deadline, which would pressure the schedules of the already limited number of available site visitors. Second, dating the decision to the CoA meeting will reduce the opportunities for interns to come from an accredited program if they have matched with a new program, as the site visit date may come before that cohort completes internship, but the CoA may not meet until afterward. I would encourage that, if the date of decision is to change, that it would move earlier in time (i.e. when the Self Study is submitted), rather than later, to allow for the inclu...	See Full Comment
IR (PWC, D.4-7(b)) and AOP (Section 8.6) Revisions	AOP Section 8.6	Jaquess	David		The change in 8.6 is a positive change from the perspective of programs. There is often substantial delay--sometimes nearly a year--between the site visit and the final CoA decision. When a program has had a difficult period that led to 3 or fewer years of approval, even though the program is striving to respond to feedback, linking the approval date to the site visit may not allow sufficient time to actually enact the finally approved changes to program P&P. For example, it might be possible to apply changes to evaluation processes to only one class of interns before the next site visit. Then the program ends up reporting 5 years of meaningless evaluation data (from the time prior to an approved revised process) and one year of new data. Thus the old timeline does not promote positive changes for the programs that need it most.
IR (PWC, D.4-7(b)) and AOP (Section 8.6) Revisions	AOP Section 8.6	Neil	Stafford		I would agree with a previous comment as to not change the effective accreditation date to when the decision is made by CoA. The self study and site visit are prepared based on the current program. If the CoA decision is made in the next training year that penalizes the current trainees as they were receiving accredited level of training. Since the self-study and site visit were prepared based on the current training then the accreditation effective date should occur within the training year the self-study and site visit occurred.
IR (PWC, D.4-7(b)) and AOP (Section 8.6) Revisions	AOP Section 8.6	Christoph	Leonhard		This proposed change to the effective date of a decision has the effect of accreditation decisions no longer being retroactive to the date of the site visit but instead effective the day the CoA made the decision. This extends the time a new program will be unaccredited for many months or longer. This change will have a very negative impact on advanced program students who have proven themselves to be competent (otherwise accreditation would not have been granted) but who now run a much greater risk of graduating from an unaccredited program. This is almost inevitable since site visits often occur months before the CoA makes an accreditation decision. This new policy will also have the undesirable effect of forcing advanced students to delay graduation for many months to avoid graduating prior to the accreditation decision having been made. Since student competencies are such a big factor in awarding accreditation, to be fair to students who have demonstrated themselves to be competen...	See Full Comment
IR (PWC, D.4-7(b)) and AOP (Section 8.6) Revisions	AOP Section 8.6	Bernadette	Pasquale	VA Psychology Training Council	Although we understand that this proposed change is required for compliance with USDE criteria, delaying the accreditation date could result in a substantial impact for new programs and the interns in those programs. If a new program that undergoes a site visit during a training year is not reviewed during a CoA meeting during that same training year, the interns in that new training program will not have completed an APA-accredited internship program, despite having trained in the program which was eventually accredited. This has implications for employment, licensure, and certifications for the interns as well as possible recruitment implications for the program for the next training year if not yet accredited. Similarly, it may have implications for currently accredited programs if there is a delay to the site visit, such as difficulty obtaining site visitors, that would extend the re-accreditation decision beyond the date of the program's accreditation. Should this change to th...	See Full Comment