Accreditation Public Comment System





This project is now closed for new comments.
DocumentSectionItemFirst NameLast NameGroup NameComment 
D.3-8_Access_Conf_Files-D.6-1(b)_Complaints_Procedures D.3-8, Access to Confidential Files by the CoA/Site VisitorsSharonHorne I appreciate the clarification of the accessibility of site visitors to confidential files within HIPAA and FERPA privacy laws. The procedures for managing complaints and review of programs also seems to be much clearer. These changes will be helpful to both site visitors and training directors.
D.3-8_Access_Conf_Files-D.6-1(b)_Complaints_Procedures D.3-8, Access to Confidential Files by the CoA/Site VisitorsJeffreyBatesVA Psychology Training CouncilThe VA Psychology Training Council appreciates the opportunity to respond to these two IRs. Both proposed IRs are clear and will be helpful for training programs and site visitors. We have no concerns with the proposed IRs and support their implementation.
D.3-8_Access_Conf_Files-D.6-1(b)_Complaints_Procedures D.3-8, Access to Confidential Files by the CoA/Site VisitorsKennethBohm I am a site visitor of long standing. I believe that the inability of site visitors to review trainee work products will be detrimental to the review process. On occasion, diagnostic assessments are being performed poorly and the site visit may be the only time that the issue is raised with the program.
D.3-8_Access_Conf_Files-D.6-1(b)_Complaints_Procedures D.3-8, Access to Confidential Files by the CoA/Site VisitorsRobertRuchinskas As a site visitor I find that the review of work products in patient files can be crucial in determining the accuracy of a program's self-report regarding training and supervision. Examining records has, on occasion, revealed note's that have not been reviewed or co-signed by supervisors and this finding can change the direction of the remaining site visit. While I certainly am a strong advocate of privacy rights, seeing a cherry-picked de-identified note or report will not ensure that the interns are receiving appropriate supervision on a daily basis.
D.3-8_Access_Conf_Files-D.6-1(b)_Complaints_Procedures D.3-8, Access to Confidential Files by the CoA/Site VisitorsNabilEl-GhorouryAPAGSAPAGS thanks the CoA for the opportunity to provide a comment on their proposed Implementing Regulations. In terms of Access to Confidential Files by the CoA/Site Visitors, APAGS wants to ensure that the confidentiality of all student records are protected to the greatest degree possible. APAGS believes it would be worth adding to the IR a process of declaring conflicts of interest – and potentially limiting access to records – for site visitors that may have personal or professional relationships with students from a program (e.g., serve on a committee with a student, close colleagues with a student’s supervisor). Considering that a student’s medical information can be found in educational records, which site visitors can access under FERPA, there should be a policy in place through which site visitors should declare conflicts of interest when reviewing the confidential records of students within a program. In keeping with the APA Ethics Code (6.02), graduate program staff and facul... See Full Comment
D.3-8_Access_Conf_Files-D.6-1(b)_Complaints_Procedures D.3-8, Access to Confidential Files by the CoA/Site VisitorsMatthewFeldner As the director of a training clinic in an APA-accredited program, I strong support this proposed change.