Accreditation Public Comment System

This project is now closed for new comments.

Document	Item	First Name	Last Name	Group Name	Comment
Implementing Regulations (IRs) C-18 D, C-30 I, and C-9(I) P	Implementing Regulations (IR) C-18 D. Outcome Data for Doctoral Programs	Allison	Gillens	APA Committee on Early Career Psychologists	Thank you for the opportunity to review the proposed Resolution on Outcome Data for Doctoral Programs on behalf of the Committee on Early Career Psychologists (CECP). We appreciate the efforts to modify the resolution for greater specificity. The clarifications are well-written, and we anticipate it will be impactful in the standardization of reported outcome data. Regarding aggregation of reported data, we appreciate the emphasis on basic descriptive statistics and avoiding over aggregation of data. However, we believe it is important to support programs and students in identifying equity, diversity, and inclusion-based challenges in meeting specific-competencies based on the program’s method of evaluation. Given this, it may be prudent to include the requirement that in the event a clinically significant proportion of students (e.g., 5%) have not met a specific competency, relevant demographic data is provided, as well as a plan to support the identified students in meeting the...	See Full Comment
Implementing Regulations (IRs) C-18 D, C-30 I, and C-9(I) P	Implementing Regulations (IR) C-18 D. Outcome Data for Doctoral Programs	Laura	Dilly	Committee of Children, Youth, and Families	The Committee on Children, Youth, and Families thanks you for the opportunity to review the Implementing Regulations (IRs)C-30 I. We appreciate the continued inclusion of "developmental aspects of behavior" as required discipline specific knowledge and have no specific recommendations.
Implementing Regulations (IRs) C-18 D, C-30 I, and C-9(I) P	Implementing Regulations (IR) C-18 D. Outcome Data for Doctoral Programs	Ryan	Sharma	National Council of Schools and Programs of Professional Psychology	We appreciate the greater specification and clarification regarding the manner of assessing outcomes for the DSK and recognize that it is consistent with current practice. Additionally, we believe it is useful to clearly articulate the need for multiple outcome measures to assess PWCs. While a multi-method evaluation of each PWC seems warranted, a multi-method evaluation of each element seems unnecessary and unsupported. This approach implies that there was a factor analysis that determined that these elements are individual constructs with enough sensitivity/specificity to warrant stand-alone identification, assessment, and measurement of outcomes. It seems to elevate what we believe was likely a more "intuitive" consensus process that resulted in their development and burdens programs unduly with multiple measurements for items that can reasonably be evaluated by single measures. We do not see the justification for the dimensionality for every element and think programs can be trus...	See Full Comment
Implementing Regulations (IRs) C-18 D, C-30 I, and C-9(I) P	Implementing Regulations (IR) C-30 I. Intern Sufficiency	Allison	Gillens	APA Committee on Early Career Psychologists	Thank you for the opportunity to review the proposed Resolution on Intern Sufficiency on behalf of the Committee on Early Career Psychologists (CECP). We appreciate the efforts to ensure appropriate peer interaction, support, and socialization for psychology interns. In the rare and extenuating circumstances in which only one trainee is present at the site, we would suggest the following. The site is required to inform the intern in writing with as much notice as possible, of their unaccompanied status. Additionally, the site is accountable for ensuring the remaining intern’s training is minimally impacted and appropriate modifications are made to any internship requirements intended to be completed by a group rather than individual. Thank you to those involved in this important work.
Implementing Regulations (IRs) C-18 D, C-30 I, and C-9(I) P	Implementing Regulations (IR) C-30 I. Intern Sufficiency	Ryan	Sharma	National Council of Schools and Programs of Professional Psychology	NCSPP appreciates the CoA ensuring that there is sufficient support and socialization for students in internship training.
Implementing Regulations (IRs) C-18 D, C-30 I, and C-9(I) P	Implementing Regulations (IR) C-9(l) P. Postdoctoral Residency Level 3 – Specialty Competencies Psychoanalytic/Psychodynamic Psychology	Bhupin	Butaney	Education and Training Committee, APA Division 39	We appreciate the work CoA and its committees have done in preparing clear and appropriate Level 3 Specialty Competencies for Psychoanalytic and Psychodynamic Psychology programs through IR C-9(I) P. We strongly agree that the proposed specialty competencies and associated elements are consistent with specialty-level practice in Psychoanalytic and Psychodynamic Psychology and meet the requirements of Postdoctoral Standard II.B.3 of the SoA. The Level 3 competencies are aligned with the CoS-approved Postdoctoral Residency Guidelines for Psychoanalytic and Psychodynamic Psychology. IR C-9(I) P, as proposed, will provide clarity and support to APA-accredited postdoctoral residency programs that offer postdoctoral training opportunities in this specialty area. By having clear competencies at the postdoctoral level that align with professional practice standards and advanced board certification in Psychoanalytic and Psychodynamic Psychology (PA/PD), students at the graduate level will h...	See Full Comment
Implementing Regulations (IRs) C-18 D, C-30 I, and C-9(I) P	Implementing Regulations (IR) C-9(l) P. Postdoctoral Residency Level 3 – Specialty Competencies Psychoanalytic/Psychodynamic Psychology	Julie	Wolter	Division 42 Executive Committee and Advocacy Committee	Several members of Division 42, Psychologists in Independent Practice, acquired informal specialty training in psychodynamic psychology and practice. We believe the competencies presented in IR C-9(I) P are useful and helpful for postdoctoral residency training programs to prepare students formally in the functional areas of practice within this specialty area. We support CoA providing these clear competencies in this specialty area of practice for postdoctoral residency training programs. We also believe these competencies may help guide training for ECP’s who seek additional training to advance their areas of specialty in PA/PD.
Implementing Regulations (IRs) C-18 D, C-30 I, and C-9(I) P	Implementing Regulations (IR) C-9(l) P. Postdoctoral Residency Level 3 – Specialty Competencies Psychoanalytic/Psychodynamic Psychology	Allison	Gillens	APA Committee on Early Career Psychologists	Thank you for the opportunity to review the proposed Resolution on Postdoctoral Residency Level 3 – Specialty Competencies for Psychoanalytic/Psychodynamic Psychology programs on behalf of the Committee on Early Career Psychologists (CECP). The resolution appears to cover necessary and appropriate criteria for a training program in a specialty orientation. The broad-based language and coverage allow for program flexibility in meeting the various competencies. While many behavioral health providers use the term “psychoanalysis” and “psychodynamic” interchangeably, their distinction becomes more relevant when applied to intervention (Novotney, A. 2017 & Shafti S., 2016). Given this difference and the advanced nature of a postdoctoral residency, it would be prudent for programs to be required to identify if they provide specialty training in one or both theoretical orientations. Additionally, research has demonstrated contraindications and limitations of psychoanalytic and psychodynami...	See Full Comment
Implementing Regulations (IRs) C-18 D, C-30 I, and C-9(I) P	Implementing Regulations (IR) C-9(l) P. Postdoctoral Residency Level 3 – Specialty Competencies Psychoanalytic/Psychodynamic Psychology	Laura	Dilly	Committee of Children, Youth, and Families	The Committee on Children, Youth, and Families thanks you for the opportunity to review the Implementing Regulations C-9(I) P. With regard to the Specialty Competencies Psychoanalytic/Psychodynamic Psychology, our committee wondered if under the section on Individual and Cultural Diversity it might be appropriate to include a reference to developmental considerations within the competency that reads, "demonstrate an appreciation of the ways in which cultural, [developmental, and internal factors are codeterminative of personality structure and functioning." Similarly, under the Intervention Section, 4th bullet, an additional phrase could be added: “demonstrate skill in the application of psychoanalytic/psychodynamic interventions across developmental stages.”