Accreditation Public Comment System

Document	Section	Item	First Name	Last Name	Comment
Standards of Accreditation in Health Service Psychology (SoA) Revisions (Round 2)	I. Scope of Accreditation	C. Scope of Accreditation for Postdoctoral Residency Programs	kevinkevin	zhangzhang	test from developer
Standards of Accreditation in Health Service Psychology (SoA) Revisions (Round 2)	II. Guiding Principles of Accreditation	B. Professional Values	Sarah	Getch	I take issue with the following: These definitions should be construed consistently with applicable federal, state, and local laws and may be adapted by programs to be consistent with their institutional missions and applicable laws. This language insists that lawmakers can force their values on our profession, and they cannot. Adding this language also means that APA has not made their professional values clear and that they have not made their stance in opposition to state and local laws that discriminate against people from diverse backgrounds. I suggest softer language than "should be construed" and instead the use of, "may be considered." Do better!!
Standards of Accreditation in Health Service Psychology (SoA) Revisions (Round 2)	II. Guiding Principles of Accreditation	B. Professional Values	Lauren	O'Reilly	I take issue with the language proposed regarding the definitions of diversity, such that they "should be construed consistently with applicable federal, state, and local laws..." This language is more strongly phrased and suggests that accredited programs defer to the most restrictive laws (rather than most inclusive) regarding diversity language, discussions, and education. This is especially jarring when the following clause of the sentence states that programs "may" follow adapt to institutional missions and laws. With recent state-level legislation, which universities are implementing, that have eliminated positions dedicated to DEI efforts, I worry that this could have an adverse effect on the research, clinical efforts, and education around diversity in accredited programs. The implementation of such language in congruence with restrictive legislation is directly antithetical to our ethical obligation as scientists, clinicians, and educators to promote equity of those we serve. ...	See Full Comment
Standards of Accreditation in Health Service Psychology (SoA) Revisions (Round 2)	II. Guiding Principles of Accreditation	B. Professional Values	Christina	Rodriguez	As noted by others, the language of "law" appears to suggest that law is more critical than ethics. In the current climate, we must stand firm in valuing EDI and embedding them in our curriculum. Indeed, accreditation is currently one of the few ways programs have to argue for why we must be able to teach and train students appropriately. Language here must take care that we do not weaken our commitment. (please note the presence of several typographical errors in the corrections throughout)
Standards of Accreditation in Health Service Psychology (SoA) Revisions (Round 2)	II. Guiding Principles of Accreditation	B. Professional Values	Jeffrey	Bedwell	I object to the changed in this sentence: "These definitions should be construed consistently with applicable federal, state, and local laws and may be adapted by programs to be consistent with their institutional missions and applicable laws." APA should be a leader on this as an important ethical issue for the field and not explicitly defer to state and local laws in particular.
Standards of Accreditation in Health Service Psychology (SoA) Revisions (Round 2)	II. Guiding Principles of Accreditation	B. Professional Values	Ke Anne	Zhang	Dear members of the Office of Program Consultation and Accreditation, I am writing to highlight the ethical quandary that a portion of the proposed revisions would leave many psychologists in across a number of states. Specifically, I am referring to Part II, B, 2, A, wherein it reads, "These definitions should be construed consistently with applicable federal, state, and local laws and may be adapted by programs to be consistent with their institutional missions and applicable laws." Please note that there are laws which are antithetical to psychologists' core professional competencies and ethics. This proposed revision does nothing to uphold the profession's long-standing ethical values and only serves to weaken the profession's ability to meet our core competencies and serve the public. As an accreditation body, the APA CoA's role is not the same as the role of individual psychologists. We as individuals may acquiesce to laws that are antithetical to our professional ethical m...	See Full Comment
Standards of Accreditation in Health Service Psychology (SoA) Revisions (Round 2)	II. Guiding Principles of Accreditation	B. Professional Values	Melissa	Hunt	I strongly object to the capitulation to anti DEI legislative efforts currently underway that is implicit in the new sentence "These definitions should be construed consistently with applicable federal, state, and local laws and may be adapted by programs to be consistent with their institutional missions and applicable laws.." It USED to be legal for psychologists to engage in torture when the law allowed it. That was egregious and horrific and against our deepest core values. This capitulation feels similar. The "applicable law" does NOT get to define any of these terms for us. That's ludicrous. Alabama and Texas state legislatures should have no sway whatsoever on the definitions of terms like diversity and multicultural competence. We need APA and CoA to stand absolutely firm on this issue to provide us with institutional back up as we resist these reactionary legislative efforts.
Standards of Accreditation in Health Service Psychology (SoA) Revisions (Round 2)	II. Guiding Principles of Accreditation	B. Professional Values	Paula	Shear	Thank you to the Commission for the hard work on the proposed modifications to the SoA. I am writing to support the several modifications related to diversity. If I understand the edits correctly, there is a suggestion to copy already existing language that requires programs to adhere to local, state, and federal statutes to the diversity section. Although this does not seem to reflect a policy change, placing this language near the diversity requirements in my mind has the positive impact of reminding programs that they are not expected to pursue initiatives that conflict with existing laws. I would be very concerned about accreditation standards that require or appear to require programs to violate state or federal law, because this would make it impossible to operate accredited programs in certain states, could put us at odds with the rules in our own institutions, and could make both our programs and the CoA targets of hostile outside groups. The SCOTUS decision and some of ou...	See Full Comment
Standards of Accreditation in Health Service Psychology (SoA) Revisions (Round 2)	I. Institutional and Program Context	A. Type of Program	Sarah	Getch	Modifying this language puts us in conflict with the APA Ethics code. The code states: "If this Ethics Code establishes a higher standard of conduct than is required by law, psychologists must meet the higher ethical standard. If psychologists' ethical responsibilities conflict with law, regulations, or other governing legal authority, psychologists make known their commitment to this Ethics Code and take steps to resolve the conflict in a responsible manner in keeping with basic principles of human rights." The psychological science is undeniable. We cannot simply understand the significance of equity, diversity, and inclusion. We must understand, implement, and live out these values. We must engage in action to promote equity, diversity, and inclusion. Understanding is not enough. Make no change to the current language.
Standards of Accreditation in Health Service Psychology (SoA) Revisions (Round 2)	III. Students	A. Student Selection Processes and Criteria	Sarah	Getch	Modifying this language puts us in conflict with the APA Ethics code. The code states: "If this Ethics Code establishes a higher standard of conduct than is required by law, psychologists must meet the higher ethical standard. If psychologists' ethical responsibilities conflict with law, regulations, or other governing legal authority, psychologists make known their commitment to this Ethics Code and take steps to resolve the conflict in a responsible manner in keeping with basic principles of human rights." The preamble states: "Psychologists are committed to increasing scientific and professional knowledge of behavior and people's understanding of themselves and others and to the use of such knowledge to improve the condition of individuals, organizations, and society. Psychologists respect and protect civil and human rights and the central importance of freedom of inquiry and expression in research, teaching, and publication. They strive to help the public in developing informed...	See Full Comment
Standards of Accreditation in Health Service Psychology (SoA) Revisions (Round 2)	II. Aims, Training, Competencies, and Outcomes	B. Program-Specific Aims and Competencies	Spencer	Dawson	Regarding II-B-2-a: The proposed modifications of the text include explicit acquiescence to federal, state, and local laws in how definitions of diversity are to be construed. This is very concerning in the current political context where lawmakers are prohibiting the teaching of EDI and/or redefining EDI for political purposes that are inconsistent with the values and purposes of health service psychologists. While the proposed language would allow programs to avoid conflict between APA requirements and code of ethics vs. laws, these conflicts would be resolved only by sacrificing our professional ethics and capitulating to the whims of politicians. This brings back memories of psychologists participating in torture and the subsequent controversy surrounding the APA code of ethics. We should strive to align our professional behavior with both ethical and legal obligations, but in my opinion, this is not the way to do it.