Accreditation Public Comment System





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DocumentSectionItemFirst NameLast NameGroup NameComment 
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency CompetenciesMary JoCoiroDoctoral committee, Psychology department, Loyola University MarylandRegarding the proposed change to C17-D.b.ii (regarding unaccredited internships), please clarify how a doctoral program can demonstrate the *quality* of supervision provided. Is there an expectation that programs would document more than what is described under IR C-14 ("Supervision is characterized as...")
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency CompetenciesWilliam D.Parham 1. Thanks for placing "cultural competency" front and center as a key component of solid professional practice. The call for cultural competence should imply both 'domestic' (e.g., USA) as well as 'global' (other countries/provinces, etc.) competencies and each should be detailed differently as there are important differences between the two, not the least of which are issues/concerns/challenges related to "country of origin", "current/past political climate", "immigration", etc.). 2. Related to #1 above, I feel strongly that demonstrated competencies in "cultural humility" need to be called out in detail for both the student/trainee/young professional as well as for the supervisor/professor/director. 3. The document does a good job of identifying competencies to which students/trainees/young professionals should aspire. What if they do not measure up to the competencies? I would like to see a section of the document that addresses noted deficiencies, trouble spots or areas of c... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency CompetenciesNancyBurkePsychotherapy Action NetworkThe Psychotherapy Action Network wishes to express concern regarding C-9 P and several of the proposed revisions to C-17 D as well. In this section, we will respond to the former, and will submit a separate comment for the latter. Our concerns about C-9 P are far-reaching. We have already offered comment on the narrow conceptualization of evidence-based treatment as it appears in APA’s Guidelines, and the same comments extend to this effort to put the decisions reflected in the Guidelines program more concretely into training practices here. It is clear that APA’s training requirement of a “scientific orientation” on the part of its post-doctoral programs indicates not the need for a respect for science in general, but only refers to the restricted view of science that has been at work in its Guidelines program’s general trend to favor RCTs over other sorts of research. to the neglect of the other two legs of the evidence-based care stool. This document reflects far more the req... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency CompetenciesBradleyBoivin The IR C-9 P expects that “training and attention to diversity” be incorporated into post-doctoral training programs, yet APA’s clinical practice guidelines fail to value the diversity of patients’ unique treatment needs by recommending one-size-fits-all treatments based on weak RCTs that do not translate well to real-life practice. The IR C-9 P expects postdoctoral training programs to be grounded in the “existing empirical literature,” yet the field of psychology has a serious credibility issue when it comes to research as more and more studies have been called into question in recent years. Maybe we should demonstrate our research is valid before requiring it to be the foundation upon which training programs are built.
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency CompetenciesScottPytluk I would like to strongly endorse the comments posted by the Psychotherapy Action Network (Psi-An) with respect to this passage.
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency CompetenciesDr. FreddieTaborda I had the opportunity to read the proposals, and I concur with the opinion of the Psychotherapy Action Network.
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency CompetenciesDavidCastro-Blanco  As the Director of Clinical Training in a doctoral program in Clinical Psychology, I endorse the advanced competency recommendations advanced in IR-C-9 P. Reinforcing the overarching importance of the Level I changes is an essential part of the training trajectory of all HSP students. Integrating science and practice effectively is highly intertwined with an advanced knowledge of ethical and legal standards and an awareness of and respect for individual differences and cultural diversity. The Level 3 Specific Competencies outlined appear clear, relevant and appropriate. As others have noted, the omission of some approaches to training and intervention should be better addressed in the IR.
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency CompetenciesKevinLarkinSpecialty Competency Task Force in Clinical Health PsychologyWe are writing to provide public comment regarding the proposed competencies for accreditation of post-doctoral specialty programs. As members of the Task Force charged by the Clinical Health Psychology Specialty Council to review the literature on clinical health psychology competencies and submit competencies required for clinical health psychology postdoctoral programs, we are uniquely positioned to comment on these proposed guidelines as they pertain to our specialty practice. Further, the proposed competencies were sent out for review to the members of Clinical Health Specialty Council (e.g. Council of Clinical Health Psychology Training Programs) for comment prior to submission to CoS. We are pleased that CoA requested input from recognized postdoctoral specialties in creating the standards for accrediting specialty post-doctoral programs. After all, many specialty practice areas in health service psychology have already done a good bit of work in defining the entry-level... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency CompetenciesRobertGangi I, and many of my colleagues who practice psychodynamically-and constitute a significant portion of the APA membership are quite angry about this, additional attempt to conceptualize psychodynamic models as lacking validity. The PsiAn organization has posted relevant, and more specific comments that I fully endorse.
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency CompetenciesJillSalberg My concerns about C-9 P are far-reaching. It is clear that APA’s training requirement of a “scientific orientation” on the part of its post-doctoral programs indicates not the need for a respect for science in general, but only refers to the restricted view of science that has been at work in its Guidelines program’s trend to favor RCTs over other sorts of research. to the neglect of the other two legs of the evidence-based care stool. This document reflects far more the requirement that students recognize the influence of “science” on practice than the influence of practice on science, despite lip service to their reciprocal relationship. I am dismayed at the decision to conceptualize what will likely be the largest Specialty track as “Behavioral and Cognitive,” reflecting a clear bias towards one modality over others, despite significant research to suggest that such treatments are mostly ineffective in helping actual patients deal with real-world struggles. I have been a lic... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency CompetenciesWayneSiegelAPPIC Postdoctoral CommitteeThe Association of Psychology Postdoctoral and Internship Programs (APPIC) Postdoctoral Committee represents 227 APPIC Member postdoctoral programs as well as the Universal Psychology Postdoctoral Directory (UPPD) which hosts over 1200 program listings. The APPIC Board and the APPIC Postdoctoral Committee welcome the opportunity to comment on the proposed Implementing Regulation on the postdoctoral profession-wide competencies (IR C-9 P). The following pertains to all Level 1, Level 2, and Level 3 specialty competencies addressed in IR C-9 P. Overall, we appreciate CoA’s efforts to provide well-needed clear and specific guidance on training expectation within psychology postdoctoral training (Level 1 & 2 Competencies) and specifically within specialty training (Level 3 Competencies). We applaud the collaboration among CoA and the Behavioral and Cognitive Psychology, Clinical Child Psychology, Clinical Health Psychology, Clinical Neuropsychology, Forensic Psychology, Geropsychology, ... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency CompetenciesRobinHilsabeckClinical Neuropsychology SynarchyDear Members of the COA: I am writing you as Chair of the Clinical Neuropsychology Synarchy (CNS), which represents the specialty of clinical neuropsychology on the Council of Specialties in Professional Psychology (CoS). The following comments are in response to the proposed revision to Implementing Regulation C-9 P. The CNS consists of representatives from the following organizations: Society for Clinical Neuropsychology (APA Division 40), National Academy of Neuropsychology, American Academy of Clinical Neuropsychology, Hispanic Neuropsychological Society, American Board of Professional Neuropsychology, American Board of Clinical Neuropsychology, Association of Post-Doctoral Programs in Clinical Neuropsychology, and Association for Internship Training in Clinical Neuropsychology. This response was primarily authored by a CNS Workgroup comprised of experienced training directors at APA-accredited clinical neuropsychology postdoctoral residency sites. The CNS is grateful to the Co... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency CompetenciesSeimeRichardCouncil of Specialties in Professional Psychology (CoS)Council of Specialties in Professional Psychology (CoS) comments for draft of IR C-9 P, Postdoctoral Residency Competencies At the time each specialty submitted their postdoctoral competencies in 2017, it was with the understanding that CoA would “rework” the submitted competencies so that they could be readily used for accreditation decisions. The specialties in health service psychology provided the competencies that were judged to be necessary for residents to achieve by the completion of a postdoc. CoS, in collaboration with CoA prior to submission, provided guidance to the specialties as to the suggested number of competencies and the essential elements within each to assess attainment of the competencies. The submitted competencies are posted on the CoS website (www.cospp.org ) along with a narrative of the process for the development of each specialty’s competencies. The current draft of IR-C-9 competencies offered for public comment raises some concerns for us that are ... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency CompetenciesJessicaJackson I appreciate the emphasis on culture and diversity, however I have concerns about how it is addressed here. How is "appropriate training and attention" defined? Who determines what is considered appropriate? In addition I discourage the use of the word "conflict" when addressing the ability to work with others who may not have the same social identities as myself. I am also concerned why research competence would not be required at the postdoctoral level.
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency CompetenciesJeffreyAxelbank I want to endorse the comments submitted by the Psychotherapy Action Network. I am once again outraged that APA is proposing standards that completely ignore psychodynamic/psychoanalytic training and therapy. How can anyone take APA's request for comments seriously when this keeps happening, despite attempts by members of the psychoanalytic psychology community to point it out? So once again, I vehemently object to these proposed standards which lists standards for a number of specialty training areas, but omits any standards for post-doctoral training in psychoanalytic therapy. Furthermore, despite continuing feedback from various constituent communities that APA has unwisely narrowed the focus on science to a small part of the scientific literature (e.g., RCTs and purely empirical methods), leaving out the other parts of what APA policy says constitute evidence-based practice, here again we see standards that perpetuate this same distortion of what constitutes science. I... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency CompetenciesDavidGoldberg I endorse the comments of PSIAN, the Pscyhotherapy Action Network; and the comments of Jeffrey Axelbank, Psy.D.
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency CompetenciesDavidGoldberg I endorse the comments of the Psychotherapy Action Network, and of Jeffrey Axelbank, Psy.D.
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency CompetenciesBetsyNettleton I endorse the comments of the Psychotherapy Action Network, and of Jeffrey Axelbank, Psy.D. I remain grateful that my graduate education had a psychodynamic track, and that my internship and post-doc both specialized in the understanding and application of psychodynamic therapy.
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency CompetenciesAmySilberbogenVA Psychology Training Council The VA Psychology Training Council appreciates the efforts of the Commission in developing the postdoctoral profession-wide competencies. There are several areas in which we wanted to highlight our thoughts: 1) There appears to be a shift within the Research competency such that postdocs will be required to “formulate and test empirical questions” under the new IR. While we applaud the inclusion of increased science within postdoctoral training, we recognize that this shift may be a challenge for some programs; 2) We took note that several specialty practice areas highlighted “new” competency areas (e.g., Advocacy, Leadership) that were distinct and only appeared in a few specialty areas. These areas seem to be critical for all psychologists in training, regardless of specialty area, and wondered about the necessity of these being distinct areas, versus subsumed under Professional Values and Attitudes; 3) Level 1 competency areas have been separated from Level 3 competency areas... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency CompetenciesEddyAmeenAPAGS Committee (Amer. Psych. Assoc. of Graduate Students)The American Psychological Association of Graduate Students (APAGS) Committee is pleased to comment on the proposed revisions to IR C-9P. We have one recommendation as follows. Please feel free to contact the committee if you have any clarifying questions or specific responses. We recommend IR C-9P include a requirement for postdoctoral training sites to use consistent and universal language to describe their education and training experiences. Doing so will help increase the adoption of the Taxonomy and thereby promote a uniform way of describing training experiences, which will help advance the practice of professional psychology. This language should be derived from APA Policy, specifically the 2012 Education and Training Guidelines: A Taxonomy for Education and Training in Professional Psychology Health Service Specialties. (The CoA, according to the Standards of Accreditation in Health Service Psychology, under “Guiding Principles of Accreditation,” can refer to and adopt ... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency CompetenciesLuciaGutierrezAPA Committee on Early Career PsychologistsThe APA Committee on Early Career Psychologists (CECP) greatly appreciates the chance to weigh in on drafted IR C-9P. The goal of the proposed revisions to C-9P is to provide greater detail regarding the specific competencies required to prepare postdoctoral residents for future practice as health service psychologists. The proposed changes bring C-9P into alignment with existing Standards of Accreditation and emphasize several important themes: (1) integrating individual and cultural diversity throughout all existing competencies (as opposed to considering it a stand-alone competency); (2) grounding of competencies in empirical evidence; (3) provision of level-appropriate training; (4) communication of level-appropriate expectations; and (5) formal evaluation of competence. Overall, CECP supports these revisions; however, additional clarification would be appreciated with regard to items 2 and 5, and through two other recommendations that follow. RECOMMENDATION 1: Under item 2, ground... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency CompetenciesRenePuliattiCalifornia Psychology Internship Council (CAPIC)The California Psychology Internship Council (CAPIC) has concerns regarding C-9 P and several of the proposed revisions to C-17 D. We discuss each of these concerns in turn. CAPIC also has overall concerns that the Commission on Accreditation (CoA) does not properly consider the actual impact of its implementing regulations (IR’s) and administrative rules on stakeholders, including the public. This impact is not theoretical, but is demonstrable in CoA’s implementation of IR D-4(7)b, which flags doctoral programs that utilize non-accredited but structured internships such as those offered by CAPIC, despite the lack of strong evidence that APA-accredited internships are substantially better. The actual impact of IR D-4(7)b has been for APA-accredited doctoral programs to almost exclusively use APA-accredited internships, since heightened scrutiny from CoA, APA’s accrediting and enforcement arm, is very distressing for doctoral programs. As a result, placements at CAPIC internship... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Behavioral and Cognitive Psychology)JoanSarnat Given that I was recently invited to make a training video and write a book on psychodynamic supervision for the APA series, Supervision Essentials, it comes as a shock to see that psychodynamic clinical and supervisory models have been completely eliminated from these guidelines. This must be an oversite and would hope that the problem will be corrected ASAP. I have informed Hanna Levenson and Arpana Inman, co-editors of the Supervision Essentials series, of this omission as well.
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Behavioral and Cognitive Psychology)BradleyBoivin The IR C-9 P expects the Behavioral and Cognitive Psychology (BCP) Specialty Competency to incorporate “values and attitudes” that, ironically, seem more consistent with psychodynamic and humanistic approaches to psychotherapy than the brief, manual-based treatments currently promoted by APA. Values and attitudes such as, “identity,” “self-reflection,” “lifelong learning,” “openness to feedback” in a bidirectional (supervisor/supervisee) relationship, “ability to manage difficult communication well,” and the ability to respond to “increasingly complex situations with substantial independence.” What evidence does APA have to support the integration of these values and attitudes into postdoctoral training programs? How will this be measured? Is there a body of evidence that demonstrates these values and attitudes lead to increased clinical competency? And if these values and attitudes are viewed by APA to be of value for psychology residents, why aren’t they better represented in APA’s c... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Behavioral and Cognitive Psychology)EnricoGnaulati As a psychodynamic/humanistically-oriented psychologist I have strong reservations regarding the overarching category "Behavioral and Cognitive Psychology," which overtly excludes other traditions with solid empirical support in our field!
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Behavioral and Cognitive Psychology)EricSherman I support the position promulgated by Psi-an.
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Behavioral and Cognitive Psychology)KirkSchneider I am in agreement with the Psychotherapy Action Network and others' concerns that much evidence indicating the effectiveness of psychodynamic and humanistic oriented treatments is being left out of the IR's for both pre and post-doctoral clinical studies requirements. The emphasis on the "behavioral-cognitive" domain as distinct from other bona fide approaches such as those cited above is simply not upheld by the vast majority of meta-analyses on psychotherapy process and outcome. It is of urgency that the CoA revisit this major omission and discrepancy in its formulation and evaluation of clinical guidelines. Or to put it another way, the current emphasis on RCT backed modalities, to the neglect of meta-analytic effectiveness research is simply not tenable either ethically or scientifically.
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Behavioral and Cognitive Psychology)VirginiaShiller I am deeply chagrined at the decision to only identify “Behavioral and Cognitive Psychology” as the main, or perhaps single, approach to treatment to be mastered by post-doctoral residents. This emphasis ignores the data collected for the Depression Clinical Guidelines just published, where for adults, there was sufficient evidence for recommendation for the following therapies: Behavioral therapy, cognitive, cognitive-behavioral therapy, and mindfulness-based cognitive-therapy, interpersonal therapy, psychodynamic therapies, and supportive therapy. Given that all of these modalities have been shown to be effective, shouldn’t postdoctoral residentss have a choice of specializing in one or more of these modalities? Further, the guidelines assert that postdoctoral residents are expected to engage in self-reflection regarding one’s personal and professional functioning. Psychodynamic psychotherapy specifically encourages self-reflection, and when I was trained many years ago (I am a Life... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Behavioral and Cognitive Psychology)PatriciaMcMahon Dear APA Office of Program Consultation and Accreditation, I wish to express concern regarding C-9 P and several of the proposed revisions to C-17 D. My concerns about C-9 P are far-reaching. The narrow conceptualization of “evidence-based” treatment as it appears in APA’s Guidelines disregards research on treatments of depth and relationship, and the same comments extend to this effort to put the decisions reflected in the Guidelines program more concretely into training practices here. It is clear that APA’s training requirement of a “scientific orientation” on the part of its graduate programs indicates not the need for a respect for science in general, but only refers to the restricted view of science that has been at work in its Guidelines program’s trend to favor RCTs over other sorts of research. to the neglect of the other two legs of the evidence-based care stool. This document reflects far more the requirement that students recognize the influence of “science” on... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Behavioral and Cognitive Psychology)RenePuliattiCalifornia Psychology Internship Council (CAPIC)The California Psychology Internship Council (CAPIC) has concerns regarding C-9 P and several of the proposed revisions to C-17 D. We discuss each of these concerns in turn. CAPIC also has overall concerns that the Commission on Accreditation (CoA) does not properly consider the actual impact of its implementing regulations (IR’s) and administrative rules on stakeholders, including the public. This impact is not theoretical, but is demonstrable in CoA’s implementation of IR D-4(7)b, which flags doctoral programs that utilize non-accredited but structured internships such as those offered by CAPIC, despite the lack of strong evidence that APA-accredited internships are substantially better. The actual impact of IR D-4(7)b has been for APA-accredited doctoral programs to almost exclusively use APA-accredited internships, since heightened scrutiny from CoA, APA’s accrediting and enforcement arm, is very distressing for doctoral programs. As a result, placements at CAPIC internship... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Clinical Child Psychology)CynthiaBaum-Baicker I want to express my dismay and disappointment with the APA with the decision to conceptualize what will likely be the largest Specialty track as “Behavioral and Cognitive.” This reflects a clear bias towards one modality over others, despite significant research which suggests that such treatments are limited and at times, ineffective. A lack of a Specialty Competency in Psychodynamic Psychotherapy reinforces this clear bias towards formulaic Behavioral and Cognitive treatments. Clinical Psychology, founded on the Boulder Model, was once a field that embraced the intersection of research and practice. Given the bias of the current proposal, it appears that the Boulder Model no longer applies to our field. That's a sad state of affairs for Clinical Psychology.
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Clinical Child Psychology)RenePuliattiCalifornia Psychology Internship Council (CAPIC)The California Psychology Internship Council (CAPIC) has concerns regarding C-9 P and several of the proposed revisions to C-17 D. We discuss each of these concerns in turn. CAPIC also has overall concerns that the Commission on Accreditation (CoA) does not properly consider the actual impact of its implementing regulations (IR’s) and administrative rules on stakeholders, including the public. This impact is not theoretical, but is demonstrable in CoA’s implementation of IR D-4(7)b, which flags doctoral programs that utilize non-accredited but structured internships such as those offered by CAPIC, despite the lack of strong evidence that APA-accredited internships are substantially better. The actual impact of IR D-4(7)b has been for APA-accredited doctoral programs to almost exclusively use APA-accredited internships, since heightened scrutiny from CoA, APA’s accrediting and enforcement arm, is very distressing for doctoral programs. As a result, placements at CAPIC internship... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Clinical Health Psychology)KevinLarkinSpecialty Competency Task Force in Clinical Health PsychologySee our comment regarding clinical health psychology specialty competencies under C-9 P above.
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Clinical Health Psychology)DanielHill I wish to endorse the following statement The Psychotherapy Action Network wishes to express concern regarding C-9 P and several of the proposed revisions to C-17 D. We will discuss each of these concerns in turn. Our concerns about C-9 P are far-reaching. We have already offered comment on the narrow conceptualization of evidence-based treatment as it appears in APA’s Guidelines, and the same comments extend to this effort to put the decisions reflected in the Guidelines program more concretely into training practices here. It is clear that APA’s training requirement of a “scientific orientation” on the part of its post-doctoral programs indicates not the need for a respect for science in general, but only refers to the restricted view of science that has been at work in its Guidelines program’s trend to favor RCTs over other sorts of research. to the neglect of the other two legs of the evidence-based care stool. This document reflects far more the requirement that studen... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Clinical Health Psychology)SharonBerry I fully support the comments provided by the Specialty Competency Task Force in Clinical Health Psychology. I concur with their conclusions as they reflect the beliefs of those in the clinical health education and training community. Thank you!
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Clinical Health Psychology)AnnHryshko-Mullen I would like to strongly endorse the comments posted by the Specialty Competency Task Force in Clinical Health Psychology. As the group identified as most knowledgeable regarding requirements for quality training in this specialty, I believe they represent most accurately the beliefs of those in the clinical health education and training community.
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Clinical Health Psychology)JeffreyGoodieAmerican Board of Clinical Health PsychologyWe concur with the comments submitted by the Specialty Competency Task Force in Clinical Health Psychology
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Clinical Health Psychology)RenePuliattiCalifornia Psychology Internship Council (CAPIC)The California Psychology Internship Council (CAPIC) has concerns regarding C-9 P and several of the proposed revisions to C-17 D. We discuss each of these concerns in turn. CAPIC also has overall concerns that the Commission on Accreditation (CoA) does not properly consider the actual impact of its implementing regulations (IR’s) and administrative rules on stakeholders, including the public. This impact is not theoretical, but is demonstrable in CoA’s implementation of IR D-4(7)b, which flags doctoral programs that utilize non-accredited but structured internships such as those offered by CAPIC, despite the lack of strong evidence that APA-accredited internships are substantially better. The actual impact of IR D-4(7)b has been for APA-accredited doctoral programs to almost exclusively use APA-accredited internships, since heightened scrutiny from CoA, APA’s accrediting and enforcement arm, is very distressing for doctoral programs. As a result, placements at CAPIC internship... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Clinical Neuropsychology)AmyHeffelfingerMedical College of WisconsinThis letter is the response of the Medical College of Wisconsin (MCW)’s Clinical Neuropsychology Postdoctoral Training Program to the draft IR proposing specialty-specific competencies for the specialty of Clinical Neuropsychology. MCW was one of the first programs to be accredited as a specialty program in 2003, we have trained over 100 postdoctoral fellows, and we pride ourselves in our innovative leadership around competency-based assessment of training at the post-doctoral level. MCW embraces the Houston Conference Guidelines as the model for training in clinical neuropsychology, and we have encouraged the alignment of our training competencies with the Clinical Neuropsychology Synarchy’s (CNS) proposed Level 3 Competencies for APA accredited programs. In fact, our training directors are involved in an Association of Postdoctoral Programs in Clinical Neuropsychology (APPCN) work group that is completing submission of a paper on a model of competency-based assessment which employ... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Clinical Neuropsychology)AmyHeffelfingerAssociation of PostDoctoral Programs in Clinical NeuropsychologyThis letter is the response of the Association of Postdoctoral Programs in Clinical Neuropsychology (APPCN) to the draft IR proposing specialty-specific competencies for the specialty of Clinical Neuropsychology. APPCN leadership has been involved in writing the response letter from CNS regarding acceptable, concerning, and unacceptable wording of the CoA’s draft IR competencies and their elements. As an organization, we are in agreement with all of CNS’s opinions and suggestions. This letter will highlight a few components of the CNS letter that reflect the mission of APPCN to guide our training programs on our specialty’s specific competencies. The mission of the Association of Postdoctoral Programs in Clinical Neuropsychology (APPCN) is to offer the highest quality competency-based postdoctoral fellowship training in clinical neuropsychology. As an organization, APPCN has been awaiting the CoA Level 3 Competencies for postdoctoral training in Clinical Neuropsychology, as we ... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Clinical Neuropsychology)MaryHaines I agree with APPCN's comments. Thank you.
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Clinical Neuropsychology)McDonaldBrenna I agree with the concerns raised by APPCN, and request these be taken into consideration in the final version of the Level 3 Specialty Competencies.
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Clinical Neuropsychology)KellyKing I agree with the concerns expressed by APPCN.
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Clinical Neuropsychology)SobleJason While I applaud the effort to established core competencies for postdoctoral training in clinical neuropsychology, I am deeply concerned that the 5 proposed competencies are incomplete and omit a critical competency necessary for the practice of evidence-based neuropsychological practice; namely, research and integration of science and practice. As a practicing neuropsychologist who trains postdoctoral fellows, sound research competency constitutes a fundamental professional skill that competently trained fellows must master in order to provide effective and competent services in when practicing independently. Omitting a research competency from the standard specialty competency essentially functions to devalue this critical competency.
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Clinical Neuropsychology)DavidMarcus As a training director for a postdoctoral fellowship in pediatric neuropsychology who works in an academic medical center, I firmly believe that research competency should be viewed as a core competency in fellowship training in neuropsychology. Although not all fellows will go on to have careers as academic researchers, the critical thinking skills from analyzing research literature, as well as the solid knowledge base of empirical findings in the field are crucial for both clinical practitioners and researchers as they conclude their formal training in the field and move towards independent practice. Viewing research as a core competency for a fellowship will help emphasize that point.
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Clinical Neuropsychology)KenealyLaura I agree with the concerns in APPCN's comment.
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Clinical Neuropsychology)LeslieGuidotti Breting I agree with the concerns expressed by APPCN
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Clinical Neuropsychology)PetyaDemireva As a practicing neuropsychologist involved in the training of neuropsychology fellows, I concur with the concerns expressed by APPCN regarding the omission of research as a key competency for postdoctoral residency programs in clinical neuropsychology.
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Clinical Neuropsychology)RenePuliattiCalifornia Psychology Internship Council (CAPIC)The California Psychology Internship Council (CAPIC) has concerns regarding C-9 P and several of the proposed revisions to C-17 D. We discuss each of these concerns in turn. CAPIC also has overall concerns that the Commission on Accreditation (CoA) does not properly consider the actual impact of its implementing regulations (IR’s) and administrative rules on stakeholders, including the public. This impact is not theoretical, but is demonstrable in CoA’s implementation of IR D-4(7)b, which flags doctoral programs that utilize non-accredited but structured internships such as those offered by CAPIC, despite the lack of strong evidence that APA-accredited internships are substantially better. The actual impact of IR D-4(7)b has been for APA-accredited doctoral programs to almost exclusively use APA-accredited internships, since heightened scrutiny from CoA, APA’s accrediting and enforcement arm, is very distressing for doctoral programs. As a result, placements at CAPIC internship... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Forensic Psychology)RenePuliattiCalifornia Psychology Internship Council (CAPIC)The California Psychology Internship Council (CAPIC) has concerns regarding C-9 P and several of the proposed revisions to C-17 D. We discuss each of these concerns in turn. CAPIC also has overall concerns that the Commission on Accreditation (CoA) does not properly consider the actual impact of its implementing regulations (IR’s) and administrative rules on stakeholders, including the public. This impact is not theoretical, but is demonstrable in CoA’s implementation of IR D-4(7)b, which flags doctoral programs that utilize non-accredited but structured internships such as those offered by CAPIC, despite the lack of strong evidence that APA-accredited internships are substantially better. The actual impact of IR D-4(7)b has been for APA-accredited doctoral programs to almost exclusively use APA-accredited internships, since heightened scrutiny from CoA, APA’s accrediting and enforcement arm, is very distressing for doctoral programs. As a result, placements at CAPIC internship... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Geropsychology)Mary LindseyJacobsCouncil of Professional Geropsychology Training ProgramsBoard members of the Council of Professional Geropsychology Training Programs appreciate the opportunity to provide input. Our comments on the proposed geropsychology competencies in IR C-9 P are as follows: 1. Awareness of ageism and its negative impact, heterogeneity in aging, and the intersection of age and other diversity factors are important competencies in professional geropsychology practice. Therefore, we suggest adding the following to 6-I (Professional Values, Attitudes, and Behaviors): "Recognize the negative impact of ageism in self, others, institutions, and society; appreciate heterogeneity in aging, the intersection of aging and diversity, and how age and diversity factors impact older adults’ well-being and care" 2. There are unique ethical issues that can arise when working with older adults, caregivers, and their families. Geropsychologists should be familiar with common ethical dilemmas in professional geropsychology practice and address them. Therefore, we su... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Geropsychology)RenePuliattiCalifornia Psychology Internship Council (CAPIC)The California Psychology Internship Council (CAPIC) has concerns regarding C-9 P and several of the proposed revisions to C-17 D. We discuss each of these concerns in turn. CAPIC also has overall concerns that the Commission on Accreditation (CoA) does not properly consider the actual impact of its implementing regulations (IR’s) and administrative rules on stakeholders, including the public. This impact is not theoretical, but is demonstrable in CoA’s implementation of IR D-4(7)b, which flags doctoral programs that utilize non-accredited but structured internships such as those offered by CAPIC, despite the lack of strong evidence that APA-accredited internships are substantially better. The actual impact of IR D-4(7)b has been for APA-accredited doctoral programs to almost exclusively use APA-accredited internships, since heightened scrutiny from CoA, APA’s accrediting and enforcement arm, is very distressing for doctoral programs. As a result, placements at CAPIC internship... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Rehabilititation Psychology)RenePuliattiCalifornia Psychology Internship Council (CAPIC)The California Psychology Internship Council (CAPIC) has concerns regarding C-9 P and several of the proposed revisions to C-17 D. We discuss each of these concerns in turn. CAPIC also has overall concerns that the Commission on Accreditation (CoA) does not properly consider the actual impact of its implementing regulations (IR’s) and administrative rules on stakeholders, including the public. This impact is not theoretical, but is demonstrable in CoA’s implementation of IR D-4(7)b, which flags doctoral programs that utilize non-accredited but structured internships such as those offered by CAPIC, despite the lack of strong evidence that APA-accredited internships are substantially better. The actual impact of IR D-4(7)b has been for APA-accredited doctoral programs to almost exclusively use APA-accredited internships, since heightened scrutiny from CoA, APA’s accrediting and enforcement arm, is very distressing for doctoral programs. As a result, placements at CAPIC internship... See Full Comment
Public Comment IRs C-9 P and C-17 D C-9 P. Postdoctoral Residency Competencies cont. (Couples and Family Psychology)RenePuliattiCalifornia Psychology Internship Council (CAPIC)The California Psychology Internship Council (CAPIC) has concerns regarding C-9 P and several of the proposed revisions to C-17 D. We discuss each of these concerns in turn. CAPIC also has overall concerns that the Commission on Accreditation (CoA) does not properly consider the actual impact of its implementing regulations (IR’s) and administrative rules on stakeholders, including the public. This impact is not theoretical, but is demonstrable in CoA’s implementation of IR D-4(7)b, which flags doctoral programs that utilize non-accredited but structured internships such as those offered by CAPIC, despite the lack of strong evidence that APA-accredited internships are substantially better. The actual impact of IR D-4(7)b has been for APA-accredited doctoral programs to almost exclusively use APA-accredited internships, since heightened scrutiny from CoA, APA’s accrediting and enforcement arm, is very distressing for doctoral programs. As a result, placements at CAPIC internship... See Full Comment
Public Comment IRs C-9 P and C-17 D C-17 D. Expected Internship Placements for Students in Accredited Doctoral ProgramsRuthRoa-Navarrete Concur.
Public Comment IRs C-9 P and C-17 D C-17 D. Expected Internship Placements for Students in Accredited Doctoral ProgramsLynnNorthrop Looks good. Thank you for your work.
Public Comment IRs C-9 P and C-17 D C-17 D. Expected Internship Placements for Students in Accredited Doctoral ProgramsNancyBurkePsychotherapy Action NetworkWhile on the surface the proposed changes to C-17 D can simply appear to add specificity so that they are easier to implement and monitor, in fact, they will likely function to make it prohibitively difficult for accredited Clinical Psychology programs to send their students to unaccredited internships, regardless of the preferences of students, the shortages of internship slots, the needs of community service organizations and their clients, the lack of diversity in the types of training offered, and the scarcity of half-time accredited sites that can accommodate students who face familial and financial obligations. In fact, it is striking that this document stresses the need for cultural sensitivity on the one hand while on the other, its proposed policies will likely restrict the potential betterment of both students without means and the under-resourced populations they might otherwise serve. Further, while the parameters for demonstrating the equivalence of accredited and un... See Full Comment
Public Comment IRs C-9 P and C-17 D C-17 D. Expected Internship Placements for Students in Accredited Doctoral ProgramsScottPytluk I would like to strongly endorse the comments posted by the Psychotherapy Action Network (Psi-An) with respect to this passage.
Public Comment IRs C-9 P and C-17 D C-17 D. Expected Internship Placements for Students in Accredited Doctoral ProgramsDr. FreddieTaborda I had the opportunity to read the proposals, and I concur with the opinion of the Psychotherapy Action Network in this matter too.
Public Comment IRs C-9 P and C-17 D C-17 D. Expected Internship Placements for Students in Accredited Doctoral ProgramsGregoryStevens I endorse the comments of the Psychotherapy Action Network.
Public Comment IRs C-9 P and C-17 D C-17 D. Expected Internship Placements for Students in Accredited Doctoral ProgramsKarenFraley Our concerns about C-9 P are far-reaching. We have already offered comment on the narrow conceptualization of evidence-based treatment as it appears in APA’s Guidelines, and the same comments extend to this effort to put the decisions reflected in the Guidelines program more concretely into training practices here. It is clear that APA’s training requirement of a “scientific orientation” on the part of its post-doctoral programs indicates not the need for a respect for science in general, but only refers to the restricted view of science that has been at work in its Guidelines program’s trend to favor RCTs over other sorts of research. to the neglect of the other two legs of the evidence-based care stool. This document reflects far more the requirement that students recognize the influence of “science” on practice than the influence of practice on science, despite lip service to their reciprocal relationship. While we appreciate the effort to emphasize the need to cultivate a sensi... See Full Comment
Public Comment IRs C-9 P and C-17 D C-17 D. Expected Internship Placements for Students in Accredited Doctoral ProgramsKarenFraley Our concerns about C-9 P are far-reaching. We have already offered comment on the narrow conceptualization of evidence-based treatment as it appears in APA’s Guidelines, and the same comments extend to this effort to put the decisions reflected in the Guidelines program more concretely into training practices here. It is clear that APA’s training requirement of a “scientific orientation” on the part of its post-doctoral programs indicates not the need for a respect for science in general, but only refers to the restricted view of science that has been at work in its Guidelines program’s trend to favor RCTs over other sorts of research. to the neglect of the other two legs of the evidence-based care stool. This document reflects far more the requirement that students recognize the influence of “science” on practice than the influence of practice on science, despite lip service to their reciprocal relationship. While we appreciate the effort to emphasize the need to cultivate a sensi... See Full Comment
Public Comment IRs C-9 P and C-17 D C-17 D. Expected Internship Placements for Students in Accredited Doctoral ProgramsRobertGangi I, and many of my colleagues who practice psychodynamically-and constitute a significant portion of the APA membership are quite angry about this, additional attempt to conceptualize psychodynamic models as lacking validity. The PsiAn organization has posted relevant, and more specific comments that I fully endorse.
Public Comment IRs C-9 P and C-17 D C-17 D. Expected Internship Placements for Students in Accredited Doctoral ProgramsEricSherman I support the position promulgated by Psi-an.
Public Comment IRs C-9 P and C-17 D C-17 D. Expected Internship Placements for Students in Accredited Doctoral ProgramsJillSalberg While on the surface the proposed changes to C-17 D can simply appear to add specificity so that they are easier to implement and monitor, in fact, they will likely function to make it prohibitively difficult for accredited Clinical Psychology programs to send their students to unaccredited internships, regardless of the preferences of students, the shortages of internship slots, the needs of community service organizations and their clients, the lack of diversity in the types of training offered, and the scarcity of half-time accredited sites that can accommodate students who face familial and financial obligations. In fact, it is striking that this document stresses the need for cultural sensitivity on the one hand while on the other, its proposed policies will likely restrict the potential betterment of both students without means and the under-resourced populations they might otherwise serve. Further, while the parameters for demonstrating the equivalence of accredited and un... See Full Comment
Public Comment IRs C-9 P and C-17 D C-17 D. Expected Internship Placements for Students in Accredited Doctoral ProgramsDanielHill I endorse the following statement The Psychotherapy Action Network wishes to express concern regarding C-9 P and several of the proposed revisions to C-17 D. We will discuss each of these concerns in turn. Our concerns about C-9 P are far-reaching. We have already offered comment on the narrow conceptualization of evidence-based treatment as it appears in APA’s Guidelines, and the same comments extend to this effort to put the decisions reflected in the Guidelines program more concretely into training practices here. It is clear that APA’s training requirement of a “scientific orientation” on the part of its post-doctoral programs indicates not the need for a respect for science in general, but only refers to the restricted view of science that has been at work in its Guidelines program’s trend to favor RCTs over other sorts of research. to the neglect of the other two legs of the evidence-based care stool. This document reflects far more the requirement that students recogn... See Full Comment
Public Comment IRs C-9 P and C-17 D C-17 D. Expected Internship Placements for Students in Accredited Doctoral ProgramsAllisonRothman I endorse the comments made by the Psychotherapy Action Network.
Public Comment IRs C-9 P and C-17 D C-17 D. Expected Internship Placements for Students in Accredited Doctoral ProgramsMaryDougherty I wished to express my concern regarding the APA guidelines expressed in C-9P and proposed revisions to C-17D. I feel these guidelines are based on a very narrow interpretation of "scientific evidenced based care" that serves the political agenda's of insurance companies. And further, C-17 guidelines constrict student's choices for seeking training to those training programs that are APA approved - eliminating training opportunities in depth psychotherapies.
Public Comment IRs C-9 P and C-17 D C-17 D. Expected Internship Placements for Students in Accredited Doctoral ProgramsEddyAmeenAPAGS Committee (Amer. Psych. Assoc. of Graduate Students)The American Psychological Association of Graduate Students (APAGS) Committee is pleased to comment on the proposed revisions of Implementation Regulations (IRs) regarding programs at the doctoral, doctoral internship, and postdoctoral levels. Please feel free to contact the committee if you have any clarifying questions or specific responses. (A) We recommend IR C-17D include a requirement of doctoral programs that allow their trainees to apply to nonaccredited internships to independently verify that the specific nonaccredited internship site(s) where prospective applicants may be applying meet the licensure requirements concerning internship in the state where the site is located. (B) We request that IR C-17D also require doctoral programs to counsel their trainees on the implications of attending a site that is not accredited and/or does not meet state licensure requirements concerning internship (if such is the case). (C0 To ensure that internship applicants can make... See Full Comment
Public Comment IRs C-9 P and C-17 D C-17 D. Expected Internship Placements for Students in Accredited Doctoral ProgramsPatriciaMcMahon Dear APA Office of Program Consultation and Accreditation, I wish to express concern regarding several of the proposed revisions to C-17 D. While on the surface the proposed changes to C-17 D can simply appear to add specificity so that they are easier to implement and monitor, in fact, they will likely function to make it prohibitively difficult for accredited Clinical Psychology programs to send their students to unaccredited internships, regardless of the preferences of students, the shortages of internship slots, the needs of community service organizations and their clients, the lack of diversity in the types of training offered, and the scarcity of half-time accredited sites that can accommodate students who face familial and financial obligations. In fact, it is striking that this document stresses the need for cultural sensitivity on the one hand while on the other, its proposed policies will likely restrict the potential betterment of both students without means and ... See Full Comment
Public Comment IRs C-9 P and C-17 D C-17 D. Expected Internship Placements for Students in Accredited Doctoral ProgramsLuciaGutierrezAPA Committee on Early Career PsychologistsThe APA Committee on Early Career Psychologists (CECP) greatly appreciates the chance to weigh in on drafted IR C-17D. The goal of this revision is to require doctoral programs to provide clearer information to trainees about accredited versus unaccredited internship sites and about internship training quality. CECP is committed to promoting financial and professional wellness among ECPs, which includes promoting transparency throughout training, especially concerning issues that may affect doctoral students' ability to secure future residencies, licensure, and board certification. Unaccredited internships - especially those that are not actively working directly with APA to obtain accreditation - present numerous risks to the professional and financial security of trainees. CECP agrees that doctoral programs should be held accountable for educating trainees about unaccredited internships. However, education may not go far enough. We suggest that if doctoral programs choose to allow th... See Full Comment
Public Comment IRs C-9 P and C-17 D C-17 D. Expected Internship Placements for Students in Accredited Doctoral ProgramsRenePuliattiCalifornia Psychology Internship Council (CAPIC)The California Psychology Internship Council (CAPIC) has concerns regarding C-9 P and several of the proposed revisions to C-17 D. We discuss each of these concerns in turn. CAPIC also has overall concerns that the Commission on Accreditation (CoA) does not properly consider the actual impact of its implementing regulations (IR’s) and administrative rules on stakeholders, including the public. This impact is not theoretical, but is demonstrable in CoA’s implementation of IR D-4(7)b, which flags doctoral programs that utilize non-accredited but structured internships such as those offered by CAPIC, despite the lack of strong evidence that APA-accredited internships are substantially better. The actual impact of IR D-4(7)b has been for APA-accredited doctoral programs to almost exclusively use APA-accredited internships, since heightened scrutiny from CoA, APA’s accrediting and enforcement arm, is very distressing for doctoral programs. As a result, placements at CAPIC internship... See Full Comment