Accreditation Public Comment System

This project is now closed for new comments.

Document	Item	First Name	Last Name	Group Name	Comment
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-6 M. Record of Student Complaints in CoA Periodic Review	Nathan	Victoria	Education and Training Interest Group of the Society for Personality Assessment	To: The American Psychological Association Commission on Accreditation The Society for Personality Assessment (SPA) has prepared the following comment on the first set of Section C Implementing Regulations for the Standards of Accreditation for Health Service Psychology, Master’s Degree Programs. SPA, established in 1938, has over 1,000 members from across the globe and is the largest in the world focused on the practice, science, impact, and advancement of personality assessment. Given the strong psychological assessment expertise of our membership, as well as SPA’s mission, we have prepared the following statement. This comment was prepared by SPA’s Education and Training Interest Group and was officially endorsed by the SPA Board of Trustees on September 23rd, 2021. The proposed Implementing Regulations (IRs) concerning aspects of a program’s curriculum or training relevant to acquisition and demonstration of the Assessment Profession-Wide Competencies (PWCs) are practically i...	See Full Comment
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-6 M. Record of Student Complaints in CoA Periodic Review	Kimberly	Howard	Society of Counseling Psychology - Division 17	1. Will masters level students be under the umbrella of "psychologist"? I assume not .. and if this assumption is correct will there be confusion being that these students will be expected to abide by the APA Ethical Principles of Psychologists? 2. This is clear and aligns with other doctoral training programs to offer due process, protect program members from harm, and grievance procedures 3. I agree with BF that this is clear and in alignment.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-6 M. Record of Student Complaints in CoA Periodic Review	Ritu	Verma	APAGS	Considering the power imbalances that exist between students and faculty and staff in graduate programs, language should be included that protects the privacy and anonymity of students wanting to explore and/or pursue formal complaints and grievances. For transparency between program leadership and students they serve, it is recommended that there be added language or suggested instructions relating to programs directly addressing any formal student complaints/grievances with their student body. Additionally, inclusive language should be included that defines what is meant by “productive interactions” since what may be considered “productive” for a faculty or staff member in a position of power may not be so for the student. It is recommended that noting for how long the program should maintain records (i.e., indefinitely) be included, as well as developing plans for record maintenance for any major program changes (i.e., programs moving departments, colleges, etc.). A formal policy...	See Full Comment
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-6 M. Record of Student Complaints in CoA Periodic Review	Nancy	Burke	Psychotherapy Action Network	The Master’s Accreditation Section C IRs emphasize two core concepts, science on the one hand and diversity on the other. Yet we have concern that the rigid conceptualization the APA has perpetuated of the former appears to undermine success in achieving the latter. Without an assurance that a true diversity of approaches to psychological distress is taught in graduate programs, the efforts at diversity assurance that are proposed here will be unlikely to yield clinicians who are best suited to serving diverse communities. In fact, by embracing a definition of science more rigid even than that adopted by the so-called hard sciences, APA limits its instructional mandate to a severely constricted range of clinical approaches that does not reflect the way psychology is practiced in the real world, that will not truly accommodate patient diversity, and for which the evidence of long-term or substantive usefulness is far more questionable than is often acknowledged. At the heart o...	See Full Comment
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-7 M. Program Aims and Program-Specific Competencies	Carolynn	Kohn		This seems like an excellent fit with the training some students receive in applied behavior analysis, with an emphasis on behavior change in the area of health behaviors. I can see this having a very positive impact, especially in the area of primary care.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-7 M. Program Aims and Program-Specific Competencies	James	Mikesell		Section I.A.2 states, "Health service psychology includes several practice areas in which an accredited program may focus, including but not limited to the areas of clinical psychology, counseling psychology, school psychology, combinations of these areas, and other practice areas (e.g., addiction, forensic, marriage and family therapy, rehabilitation). Section I.A.1 states, in part, "Some areas of specialization, such as school psychology, may require education beyond the master’s degree (e.g., specialist-level) to qualify for entry-level practice in the specialized area. Comment: It appears that APA is leaving it up to each educational institution and/or potential employment sites to decide whether to offer areas of specialization. Yet Section I.A.2 would not, per se, preclude a graduate HSP with no specialization training from practicing in any or all specialization areas. Given the substantial concerns already existing with the development of an abbreviated professional de...	See Full Comment
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-7 M. Program Aims and Program-Specific Competencies	Rebecca	Allen	Comments from Society of Clinical Geropsychology (APA Division 12 Section II)	Please add “geropsychology” as a practice area (e.g., addiction, forensic, geropsychology, marriage and family therapy, rehabilitation, etc”.)
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-7 M. Program Aims and Program-Specific Competencies	Eric	Rossen	National Association of School Psychologists	There is general concern about the lack of an operational definition of a master’s degree (e.g., by minimum credit hours, experiences, time) particularly given the significant variability in programs that issue a Master’s degree, and potential for confusion both from the public as well as prospective students.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-7 M. Program Aims and Program-Specific Competencies	Robert	Walsh	APA Board of Educational Affairs	Overall Comments: BEA greatly appreciates CoA’s effort on this important issue. BEA noted some inconsistency in the usage of terms and formatting of the document and suggests that the format of the IRs be standardized to provide clarity for end-users. Specifically, BEA suggests that preamble language for each section be used to clarify and define terms included in each section with the expectations for each section outlined in the bulleted lists. For example, Section C8M. III includes reference to ‘cultural humility’ and other skills trainees “must demonstrate” but these are not included in the bulleted list below. BEA also notes that the draft IRs use the terms Evidence Based Practice (EBP) and Empirically Supported Treatments interchangeably. BEA suggests that the draft IRs be updated to clearly distinguish the terms and suggests that the document reference the August 2005 APA policy statement on Evidence Based Practice (https://www.apa.org/practice/guidelines/evidence-based-stat...	See Full Comment
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-7 M. Program Aims and Program-Specific Competencies	Robert	Walsh	APA Board of Educational Affairs	C-8 M. Profession-Wide Competencies • Suggest refocuses the language on the expected scope of practice by graduates at the Masters level rather than explicitly focus on level of training • Noted that Doctoral IRs include language on increasing complexity and independence that is missing from the draft Masters IRs. This implies that practitioners at Masters level would not be independent. Also fails to acknowledge that Masters trained professionals do gain increasing complex knowledge while limited by the extent and period of training. • The language re: individual and cultural diversity should be updated. There are a few spots in these proposed IRs that do a nice job of expanding; at the very least, we should similarly expand re: oppression, systems, etc, in every instance of addressing individual and cultural diversity. But this language is very outdated. • do not understand what is meant by: “Utilize research methods to support quality improvement of individual treatment outcomes...	See Full Comment
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-7 M. Program Aims and Program-Specific Competencies	Kimberly	Howard	Society of Counseling Psychology - Division 17	1. It seems like we need to define how the role/description of "Health Service Psychology" at the Masters level differs from the Doc level. 2. Will there be benchmarks for "Minimal Level of Achievement" on Profession Wide Competencies like there are for doctoral programs? 3. I wonder if it might make more sense for master's level training to place a HIGHER focus on the more applied competencies, in anticipation that they will be MA level clinical practitioners?
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-7 M. Program Aims and Program-Specific Competencies	Ritu	Verma	APAGS	Add a word in Standard II.C.1.a: Original: “how they are consistent with the program’s aims, and the process by which students attain each competency (i.e., curriculum). Proposed: “how they are consistent with the program’s aims, and the process by which students attain each competency (i.e., curriculum and activities).
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-7 M. Program Aims and Program-Specific Competencies	Gillens	Allison	APA Committee on Early Career Psychologists	Introduction The Committee on Early Career Psychologists (CECP) supports and agrees with the intent of the American Psychological Association (APA) to provide standards of accreditation for Master’s programs in Health Service Psychology. The CECP appreciates the opportunity to review the implementing regulations approved by the APA Commission on Accreditation in February 2021. Background The standards of accreditation for Master’s programs in Health Service Psychology discuss the required institutional and program context; aims, competencies, curriculum, and outcomes; students; faculty, and communication practices. The CECP appreciates the structure of the document, emphasis on the wellbeing and success of students, and focus on diversity, equity, and inclusion. Section I: Institutional and Program Context The CECP appreciates the clear and concise definition of Health Service Psychology, with emphasis on the integration of science and practice. In addition, CECP would welcom...	See Full Comment
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-7 M. Program Aims and Program-Specific Competencies	Gillens	Allison	APA Committee on Early Career Psychologists	Section IV: Faculty The CECP would like to see more clarity concerning the stable program leadership and how would that be assessed. The CECP commends the authors on the required characteristics of the core faculty and associated and adjunct faculty, ensuring the richness of perspectives and expertise, as well as self-identification with the program and understanding of one’s role and impact. The section on cultural and individual differences and diversity includes recruitment and retention of diverse faculty; it could be enriched by adding a subsection on the engagement of diverse faculty and specific opportunities for growth for this faculty, such as mentoring and other programs. Section V: Communication Practices The CECP recognizes the importance of efficient, clear, and transparent communication practices in regards to the public disclosure, communication with the students and accrediting body. No edits are recommended here. Resolution The CECP commends the Commissio...	See Full Comment
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-7 M. Program Aims and Program-Specific Competencies	Amanda	Fanniff	Division 41 American Psychology-Law Society Executive Committee and Teaching, Training, and Careers Committee	The Teaching, Training, and Careers Committee (TTC) of Division 41 American Psychology-Law Society (AP-LS) reviewed the IRs with a focus on: (a) possible unique concerns regarding licensed Master’s level practitioners engaging in clinical forensic practice; and (b) how those concerns could be addressed through modifications to the IRs. These considerations and recommendations were reviewed by the AP-LS Executive Committee and were approved for submission in the public comment period. The TTC raises the following general considerations: 1. Forensic psychological practice requires unique competencies beyond those required for general clinical practice (e.g., APA Specialty Guidelines for Forensic Psychology; ABFP Core Competencies in Forensic Psychology). 2. Specialized training is required in those competencies to acquire the skills necessary for independent forensic practice (e.g., DeMatteo et al., 2009; Krauss & Sales, 2013; Packer & Borum, 2003; Sadoff & Dattilio, 2012; ibid. Sp...	See Full Comment
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-7 M. Program Aims and Program-Specific Competencies	Loveless	Loveless	Middle Tennessee State University Clinical Psychology Faculty	The clinical psychology faculty at Middle Tennessee State University thanks the Commission for the opportunity to participate in this process. We applaud the Commission on Accreditation’s (CoA’s) efforts at drafting a set implementing regulations (IRs) that frame how master’s level accreditation is to be achieved and maintained. For the most part, we found the proposed IRs to be thoughtfully conceived; however, there are some points that could use further clarification. Beyond these, we would like to remind the Commission that some jurisdictions are more restrictive than others with respect to the professional opportunities that are allowed at the master’s level. Our program exists within a state where master’s degree holders in clinical and counseling psychology may only practice as psychometricians. This restricted scope of practice has had implications for the types of field practica that our students have been able to pursue. Notably, our master’s students have only been able to tr...	See Full Comment
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-8 M. Profession-Wide Competencies	Rebecca	Meacham		Some state legislatures are "outlawing" these very teachings (e.g. privilege) for state funded programs.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-8 M. Profession-Wide Competencies	Scott	Young		As I also note elsewhere, I believe it should be clarified that the "relevant supervision requirements for one's practice level" should include substantial emphasis on supervision of master's level HSP by doctoral licensed psychologists. This should be emphasized both pre-degree and post-degree.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-8 M. Profession-Wide Competencies	Scott	Young		I would also add that I find section VI: Assessment an unclear section. I'm not sure what level of focus or training is being applied to psychometrics, psychological testing, neuropsychological testing, etc. I would encourage clarification of how much a competence focus this area includes, and a description of how those from this program would interact in testing with doctoral level psychologists.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-8 M. Profession-Wide Competencies	Shannon	Bader		I have concern about the broad language in the assessment section. For master's level practitioners, it is necessary to specifically identify that they are not qualified to use certain kinds of tests. For example, neuropsychological assessment and forensic assessment tools are two kinds of assessments that require training and education beyond what would be provided in a master's level training program.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-8 M. Profession-Wide Competencies	Rebecca	Allen	Comments from Society of Clinical Geropsychology (APA Division 12 Section II)	C-8 M, VI. Assessment In this section, we would suggest a bit more clarity on differentiating between the expectation that general competencies for all MA-level students would be training in brief standardized measures (e.g., for depression, anxiety, PTSD, cognitive screens). We also recommend noting that more extensive cognitive testing involves extensive training and supervised practice that may not be a general competency for all programs.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-8 M. Profession-Wide Competencies	Rebecca	Allen	Comments from Society of Clinical Geropsychology (APA Division 12 Section II)	C-8 M, Consultation and interprofessional/interdisciplinary skills: Our suggested revisions are: “demonstrate the ability to work as part of integrative teams with members from diverse backgrounds, such as other types of health and mental health professionals, service recipient family members, or others from different backgrounds (e.g., home, community, school, or facility-based staff or caregivers).”
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-8 M. Profession-Wide Competencies	Eric	Rossen	National Association of School Psychologists	Under "Level-appropriate training. The CoA expects that training in profession-wide competencies at the master’s level will provide preparation for entry level practice and licensure (or appropriate credential to practice at the master’s level) consistent with the program’s aims." We recommend it saying in the parentheses "or appropriate credential to practice without supervision at the master's level"
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-8 M. Profession-Wide Competencies	Eric	Rossen	National Association of School Psychologists	Under VI. Assessment - this is missing any reference to assessment and evaluation at the systems-level.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-8 M. Profession-Wide Competencies	Eric	Rossen	National Association of School Psychologists	Under Intervention (VII) - the inclusion of psychotherapy as the only example in the first paragraph implies a focus on those engaging in a very specific scope of practice. We suggest adding “and other direct and indirect services”; including a broader range of services that includes services provided across all HSP areas, or eliminating that single example of psychotherapy. This section should also include reference to culturally responsive interventions.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-8 M. Profession-Wide Competencies	Eric	Rossen	National Association of School Psychologists	Under IX. Consultation and interprofessional/interdisciplinary skills - The document seems to conflate “consultation” with “collaboration” – consultation represents a type of indirect service, whereas the content is focused more on collaboration with colleagues. We recommend using the term collaboration rather than consultation.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-8 M. Profession-Wide Competencies	Adam	Natoli	Society of Clinical Psychology’s (APA Division 12) Section on Assessment Psychology	This comment is from the Society of Clinical Psychology’s (APA Division 12) Section on Assessment Psychology and are a consensus statement on the first set of Section C Implementing Regulations for the Standards of Accreditation for Health Service Psychology, Master’s Degree Programs. The proposed Implementing Regulations (IRs) concerning aspects of a program’s curriculum or training relevant to acquisition and demonstration of the Assessment Profession-Wide Competencies (PWCs) are practically identical for Master’s and Doctoral accreditation. There is a crucial need for explicit differentiation between these education levels in the practice of psychological assessment. Below, several specific issues related to the IRs are highlighted. One fundamental perspective of the Section of Assessment Psychology about the proposed regulations of standards is that the length and breadth of training (e.g., doctoral-level training typically spans 5 years+ in comparison to 2-to-3-year master’...	See Full Comment
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-8 M. Profession-Wide Competencies	Sally	Edman		I suggest we offer more specificity on the issue of psychological assessments. Assessment using brief, standardized measures for a limited number of common diagnoses, such as anxiety or depression, seems appropriate for psychological associates with an MA degree, while more extensive and complex assessments or those for less common diagnoses would be expected to require more training and supervised practice than an M.A. program can reasonably be expected to be able to provide.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-8 M. Profession-Wide Competencies	Kimberly	Howard	Society of Counseling Psychology - Division 17	1. I'd recommend adding a bullet under supervision "Ability to participate effectively in supervision" 2. The requirement that students can "utilize research methods to support quality improvement of individual treatment outcomes" could be reworded, would the intent be the same if the word "methods" was removed? I wonder if this is an expectation that master's level students would engage in research in some way? 3. Under "Level Appropriate Training": Are we only interested in accrediting Masters programs that prepare for licensure and practice? What about students interested in a research or advocacy based position, or in preparation for Doctoral studies? Meeting licensure (as I'm noticing in my program) requires more credit hours than you might have in a typical 2 year MA program 4. Reword III to be "Equity, Diversity, Inclusion, and Social Justice" to align with the language in the revised Master's SOA 5. The assessment competency still seems a bit advanced for Masters studen...	See Full Comment
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-8 M. Profession-Wide Competencies	Ritu	Verma	APAGS	Section I: Add bullet point with the following: Be able to describe what constitutes evidence-based practice and know how to evaluate scholarly evidence for evidence-based practices. Section III Language should be included that speaks to the need for trainees to identify and evaluate interventions and best-practices that are appropriate for the diverse individuals and communities they are working with. Section IV Language should be included that addresses the necessity of selecting culturally-appropriate assessment measures for individuals and communities worked with. General Comments It is recommended adding language that reflects programs being required to offer equitable opportunities for students to achieve profession-wide competencies (e.g., “Programs must provide ‘equitable’ opportunities for all their students…”; Bell et al., 2020). Because individual and cultural diversity is listed as a desired training competency, it is recommended that “‘science’ is at the core of h...	See Full Comment
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-8 M. Profession-Wide Competencies	Amanda	Fanniff	Division 41 American Psychology-Law Society Executive Committee and Teaching, Training, and Careers Committee	As noted in a previous comment, the Teaching, Training, and Careers Committee (TTC) of Division 41 American Psychology-Law Society (AP-LS) reviewed the IRs and submitted considerations and recommendations to the AP-LS Executive Committee. These considerations and recommendations were approved for submission in the public comment period. Regarding the following: “Trainees are expected to: … demonstrate knowledge and respect for the roles and perspectives of other professionals” (Section IX. Consultation and interprofessional/interdisciplinary skills). 1. APLS requests explicit categories of “other professionals” in Section IX to support their potential roles within consolidated licensing boards; for example, adding the language “regardless of substantive practice area, degree type, or level of training” taken from earlier in C-8M.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-8 M. Profession-Wide Competencies	Loveless	Loveless	Middle Tennessee State University Clinical Psychology Faculty	With respect to evaluation of trainee competence, the Commission writes that evaluations of student performance should be consistent with the standards of accreditation. They then provide an elaboration that for clinical competencies, evaluation of student performance should be based in part on direct observation as well as other, “best practices in student competency evaluation.” This may be beyond the scope of the current document, but would the Commission be willing to elaborate on what is meant by other best practices in student competency evaluation?
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-8 M. Profession-Wide Competencies	Loveless	Loveless	Middle Tennessee State University Clinical Psychology Faculty	The Commission states, “[t]rainees are expected to demonstrate competence in evidence-based interventions consistent with the scope of the program aims within HSP practice areas.” If the scope of training in a program is limited by state law such that no direct training in the delivery of intervention is allowed, how would the Commission accommodate such a program in the accrediting process? We would encourage the Commission to consider the degree of heterogeneity that exists with respect to the laws and regulations which govern how programs in different jurisdictions may conduct master’s level training and create training standards and implementing regulations which can accommodate that heterogeneity.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-8 M. Profession-Wide Competencies	Loveless	Loveless	Middle Tennessee State University Clinical Psychology Faculty	Our state laws would make the training of clinical psychology students at the master’s level in the delivery of psychotherapy very difficult. Unless our state law changes, it is unclear how we could easily satisfy any training requirements related to the competent delivery of interventions. We would encourage the Commission to consider the degree of heterogeneity that exists with respect to the laws and regulations which govern how programs in different jurisdictions may conduct master’s level training and create training standards and implementing regulations which can accommodate that heterogeneity.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-8 M. Profession-Wide Competencies	Jason	Washburn	Council of University Directors of Clinical Psychology	The CUDCP Board supports the comments made by the Board of Educational Affairs as it relates to the Master's level IRs (both for this specific PWC IR, and all other IRs). The CUDCP Board also strongly supports the centering of science in these IRs. Although the CUDCP Board understands that the scope of practice for Master's level psychological practitioners does not rest in the hands of CoA and therefore cannot be adequately addressed in these IRs, the CUDCP Board understands many of the comments made by the Assessment Psychology Section of Division 12 related to the need to clearly identify scope of practice. As such, the CUDCP Board supports continued efforts by APA, BPA, and ASPPB to address scope of practice in a multi-tiered education and training environment within HSP.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-8 M. Profession-Wide Competencies	Andrew	Bland	Society for Humanistic Psychology (Division 32 of APA)	We appreciate the opportunity to offer feedback on the proposed APA accreditation standards for master’s training programs in health service psychology. To begin, we are heartened that, since the public comment period around this time last year, qualitative methods have been restored in the description of research that is included in the section pertaining to Discipline-Specific Knowledge and Profession-Wide Competencies (p. 4 of the SoA-M). From here, we have a few recommendations to further enhance the Discipline-Specific Knowledge and Profession-Wide Competencies presented on p. 4 of the SoA-M in conjunction with the material presented in C-8 M: Profession-Wide Competencies to more adequately prepare trainees to deliver effective, evidence-based, and sustainable therapeutic services… First, we find the scope of the 5 knowledge domains (in the SoA-M) limited in its overemphasis on observable, measurable “behavior.” We recommend expanding the language to also include “...	See Full Comment
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-9 M. Diversity Education and Training	Tammy	McClain		"Programs are expected to train students to be competent not only for serving diverse individuals present in their local community and training setting, but also for working with diverse individuals they may encounter when they move to other locations after completion of their training." Can students demonstrate competence if their didactic training has covered a broad range of diversity factors, but their training setting has fewer opportunities for applying their knowledge of diversity? While I wholeheartedly agree with this competency, I am concerned about rural areas that may have fewer opportunities for students to encounter certain aspects of diversity.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-9 M. Diversity Education and Training	Patrick	Quinn		I read the standards with great interest. I concur with everything proposed. I live in North Carolina, where master's trained "psychologists" practice as Licensed Psychological Associates, who require supervision at some level throughout their careers. The system works really well in providing well trained providers for state funded programs, Medicaid and some BC/BS insured, but the big problem is some other insurances, take the supervision requirement to mean "not fully licensed yet". If there is not a resolution to this issue, the good work of this project will not meet the public's need for increasing the availability of well trained and qualified master's trained psychologists.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-9 M. Diversity Education and Training	Rebecca	Allen	Comments from Society of Clinical Geropsychology (APA Division 12 Section II)	Please include the concept of lifespan/generational differences: “This training should be based on the multicultural conceptual and theoretical frameworks of worldview, identity, and acculturation, rooted in the diverse social, cultural, generational, and political contexts of society, and integrated into the science and practice of psychology.”
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-9 M. Diversity Education and Training	Robert	Walsh	APA Board of Educational Affairs	C-9 M. Diversity Education and Training • Same feedback re: updating language “cultural and individual diversity.” • The word “culture” is listed in the list of “cultural and individual diversity examples” – this is both vague and redundant. (realize it is the same for doctoral IR too, but should be changed.) • It is socioeconomic status (and social class should be included, i.e. “socioeconomic status and social class”), not “social economic status.” • The statement “The training should be based on the multicultural conceptual and theoretical frameworks of worldview, identify, and culturation, rooted in the diverse social, cultural, and political contexts of society…” is a little confusing, and most importantly, outdated. • This whole IR requires substantial updating.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-9 M. Diversity Education and Training	Kimberly	Howard	Society of Counseling Psychology - Division 17	1. Reword throughout this section to incorporate diversity and social justice, or "Equity, diversity, inclusion and social justice" as written in the revised SOA . Also missing an advocacy component into this competency 2. An accredited program needs to provide training opportunities for social justice practice so that students learn how to actually provide treatment to individuals of diverse backgrounds 3. Use of the term "diverse individuals" centers whiteness and all other majority language. Better to use minoritized individuals that define the conditions they experience.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-9 M. Diversity Education and Training	Ritu	Verma	APAGS	May want to consider adding language specific to how programs demonstrate effectiveness of education and training efforts in the area of diversity. As currently written it is too broad. While there is mention of requiring programs to include supervised experience providing direct services to diverse individuals, there does not appear to be clear language or requirements for implementing training relating to multicultural concerns within health psychology training. Additionally, some programs may not be able to offer training working with diverse individuals because of program location and homogeneous social identities within the program’s populations that the programs serve. Therefore, it is recommended, in addition to this previously mentioned requirement listed out in the SoA, that there also be requirements for programs to require coursework specifically focused on multicultural concerns within health psychology. Additionally, it is recommended that instructors, professors, and fac...	See Full Comment
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-9 M. Diversity Education and Training	Loveless	Loveless	Middle Tennessee State University Clinical Psychology Faculty	The Commission states that programs must examine the effectiveness of its education and training efforts in the area of diversity education and training. Could the Commission expand this section to discuss what types of data would satisfy this requirement?
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-12 M. Clinical Experiences Guidelines for Master’s Programs	Heather	Noble		Among the guidelines to clarify the CoA's expectations, the second and third bullet points appear to indicate supervision must include a licensed psychologist? Does this mean that other licensed professionals (e.g., licensed professional counselors) could not be supervisors for master's programs' clinical experiences?
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-12 M. Clinical Experiences Guidelines for Master’s Programs	Michael	Reed		Under this section it is not explicitly clear that an independent Master's level practitioner (i.e., Lic. Psychological Associate) could be a supervisor. Bullet point 3 makes mention of "on-site psychologists..." Many rural states such as mine, struggle to find clinicians willing to be supervisors. LPAs for example are under the same ethics code and licensing board as psychologists. They have had 2-yrs of supervision by a psychologist before being independently licensed. I also think those who achieved a doctorate in clinical, counseling, and/or school psychology who maintain another type of license, could be appropriate supervisors (e.g., PsyD with an LPC). I don't think a person who person who has an LPC and was never socialized in psychology would be an appropriate overall supervisor. Some masters programs posit that "counseling and psychology" are essentially different fields and an additional issue is counselors have usually only studied the ACA code of ethics and not the APA.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-12 M. Clinical Experiences Guidelines for Master’s Programs	Scott	Young		I agree that it makes sense for these master's trainees to be able to be supervised by psychology predoc interns (themselves under supervision), psychology postdocs (themselves under supervision), and licensed psychologists. I do not believe that more than 20% of their supervision should occur with "master's level practitioners in HSP". In this regard, I must respectfully disagree with colleagues who believe that psychologist supervision excessively limits to availability of supervision for these trainees. That is part of the reason why I feel telesupervision should be more permissible than the 50% restriction current suggeted. The following are concerns raised by opening the supervision door too widely: 1). At some point, if we allow master's level supervision too broadly, what is the difference between a master's HSP and a mental health counselor? Having psychologist supervision becomes critical in providing the breadth and depth of supervision needed to practice psychology a...	See Full Comment
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-12 M. Clinical Experiences Guidelines for Master’s Programs	Eric	Rossen	National Association of School Psychologists	This section lacks sufficient specificity related to supervision hours, types of supervisors, practicum vs. internship, etc. The information as presented appears vague enough to allow for practica, field experiences, OR internship. That would be highly inconsistent with current accreditation requirements for master's and specialist level counseling and school psychologists.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-12 M. Clinical Experiences Guidelines for Master’s Programs	Eric	Rossen	National Association of School Psychologists	We have concerns about the appropriateness of doctoral interns providing supervision (even if the interns are under supervision themselves).
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-12 M. Clinical Experiences Guidelines for Master’s Programs	Eric	Rossen	National Association of School Psychologists	the following statement is concerning: “When students are not being supervised on-site by licensed psychologists, the program must provide on-going weekly opportunities for students to….” – It SHOULD say “When students are not being supervised on-site by an HSP practitioner appropriately credentialed for the particular setting…” – given the potential for school psychologists to provide supervision in school settings. Licensed psychologists often do not hold the appropriate credential to provide supervision when working in a school setting.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-12 M. Clinical Experiences Guidelines for Master’s Programs	Robert	Walsh	APA Board of Educational Affairs	C-12 M. Clinical Experiences Guidelines for Master’s Programs • In the enumerated section, #2 should be split into #s 2 and 3 (which is actually how the doctoral IR is delineated), with #3 beginning with what currently reads as “…and specify how clinical experience is clearly integrated…” • First bullet point: why is psychotherapy not in this list? • This happens in a few places in the IRs if I recall right, but here in particular, EST is consistently and problematically conflated with IR. APA has official policy re: the difference between the two, and which emphasizes the adoption of EBPP (which is much more broad and much more consistent with the psychotherapy research than ESTs). Remove references to EST and focus on EBPP. May even be helpful to provide APA’s definition of EBPP when referencing it in important places. • I realize that “fora” is most technically the plural of forum, but is rarely used; is confusing. Please fix.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-12 M. Clinical Experiences Guidelines for Master’s Programs	Sally	Edman		I agree with my colleagues who have stated that master’s degree trainees should be supervised by licensed psychologists and psychology post-docs. In addition to the reasons already listed by others, this resource will be a benefit to having the M.A. in psychology which mental health counselors and those with other types of master’s degrees don’t have.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-12 M. Clinical Experiences Guidelines for Master’s Programs	Kimberly	Howard	Society of Counseling Psychology - Division 17	1. For number 2, the statement: "integrated with practical experience through fora led by psychologists for the discussion of the clinical experience." ... does this mean that psychologist must teach courses / or be part of the clinical placement? For many masters level programs the students are in clinical placements supervised and led by other masters level clinicians, e.g. Marriage and Family Therapists, these are not psychologist, but does allow for discipline specific socialization into the profession 2. What is the justification for " When students are not being supervised on-site by licensed psychologists, the program must provide on-going weekly opportunities for students to discuss their clinical work with a psychologist licensed to practice in the jurisdiction where the program is located" Why aren't master's level clinicians enough oversight for supervision? Particularly for specialty areas like marriage and family therapy or co-occuring disorders where psychologists ...	See Full Comment
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-12 M. Clinical Experiences Guidelines for Master’s Programs	Ritu	Verma	APAGS	Approved as written.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-12 M. Clinical Experiences Guidelines for Master’s Programs	Amanda	Fanniff	Division 41 American Psychology-Law Society Executive Committee and Teaching, Training, and Careers Committee	As noted in a previous comment, the Teaching, Training, and Careers Committee (TTC) of Division 41 American Psychology-Law Society (AP-LS) reviewed the IRs and submitted considerations and recommendations to the AP-LS Executive Committee. These considerations and recommendations were approved for submission in the public comment period. Regarding the following: “Include a clear statement of how clinical experience training provides opportunities for students to achieve and demonstrate profession-wide competencies, as well any program-specific competencies for which clinical experience is a relevant curricular element”; “The program must identify how the minimum acceptable level of achievement is defined and assessed, and identify policies for remediation or dismissal from a clinical experience site when this level of achievement is not met”; and, “The program must identify how the required clinical experiences are sufficient to prepare the students for entry-level practice.” AP-...	See Full Comment
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-12 M. Clinical Experiences Guidelines for Master’s Programs	Loveless	Loveless	Middle Tennessee State University Clinical Psychology Faculty	The Commission states that training programs should conduct regular site reviews of practicum sites to determine training quality at those sites. Could the Commission specify the minimum frequency of these site reviews should be (i.e., semesterly, annually, biannually, etc.)?
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-12 M. Clinical Experiences Guidelines for Master’s Programs	Loveless	Loveless	Middle Tennessee State University Clinical Psychology Faculty	The Commission states that there must be a process to evaluate the quality of clinical experiences/training at practicum sites. Could the Commission expand this bullet point to provide further guidance as to how this should be accomplished beyond the site reviews?
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-12 M. Clinical Experiences Guidelines for Master’s Programs	Loveless	Loveless	Middle Tennessee State University Clinical Psychology Faculty	The Commission states that the, “program’s curriculum plan must provide clear evidence that clinical experience is integrated with other elements of the program.” Could the commission expand this bullet point to include an example so that the meaning of this requirement is clear?
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-12 M. Clinical Experiences Guidelines for Master’s Programs	Loveless	Loveless	Middle Tennessee State University Clinical Psychology Faculty	The Commission states that the, “program must discuss how it regularly evaluates the fora for the discussion of the clinical experience.” Could the commission expand on this bullet point further? It is unclear what this means.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-13 M. Telesupervision	Michael	Reed		I would strongly urge CoA to eliminate the requirement of only "50% of total supervision" be allowed for tele-supervision or restrict its use in anyway. We have discovered in the last year that as psychologists we can deliver high-quality psychological services and education via a tele-delivery means without a reduction in outcome. Again by allowing tele-supervision it creates access for more rural programs to expand their practicum/internship opportunities. From this supervisor's perspective there is no good reason to limit the access of this medium. I don't need to be physically in a room anymore to offer good supervision or for the trainee to meaningfully benefit from this supervision. However, all other requirements of this IR are appropriate.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-13 M. Telesupervision	Maria	Okon		I would urge CoA to eliminate or modify the requirement of only "50 % of total supervision" be allowed for tele-supervision. In this last year, psychologists have been able to continue to provide high quality psychological services and education/supervision via tele-delivery outlets. By allowing tele-supervision, it creates increased access to services by students, thus allowing more flexibility to ensure and to provide quality patient care.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-13 M. Telesupervision	Eduardo	Bunge		I agree with most colleagues. Please remove the 50% requirement. We have seen how we can provide good quality supervision via teletherapy. If clients will want to have teletherapy it makes no sense to consider telesupervision as something worse than in-person.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-13 M. Telesupervision	Scott	Young		I tend to agree with my colleagues. While I acknowledge, and agree, that in-person supervision is desirable with unique benefits, I do not believe it is defensible to require ANY amount during public health emergencies. So I believe an exception should be added for that if an in-person percentage is to be required. I would also support a lower percentage (maybe around 20-30%) with the aforementioned exception. Rural areas would benefit from allowing a psychologist to provide supervision via telesupervision, and I believe that to be a higher priority (doctoral psychologist supervision) than the medium.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-13 M. Telesupervision	Eric	Rossen	National Association of School Psychologists	The note about limiting 50% of supervision at a given clinical experience site should clarify that it is referring specifically to on-site field supervision rather than concurrent university-based supervision/seminar.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-13 M. Telesupervision	Charmaine	Higa McMillan		Thank you for the opportunity to comment on these IRs. I concur with statements made by others that limiting telesupervision creates an unnecessary access problem for our rural areas. This requirement will decrease access to training sites and qualified supervisors for students in our program. Additionally, I am unaware of any research that demonstrates this format of supervision is non-equivalent to in-person supervision. As others have pointed out, many were forced to move supervision online during the pandemic without losing the benefits noted in the preamble to this regulation. I respectfully request that you reconsider this regulation.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-13 M. Telesupervision	Sally	Edman		Because it is important for master’s students to be supervised by those with a Ph.D. in psychology, it may be necessary to lift the cap on telesupervision. In rural areas the choice will often be between having a supervisor who is physically present, or having a highly trained doctoral level supervisor. We know therapy and supervision can be provided effectively via teletherapy, so it is unclear as to why we need such a limit.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-13 M. Telesupervision	Kimberly	Howard	Society of Counseling Psychology - Division 17	- This looks good - I am glad there's a limit to how much telesupervision will count
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-13 M. Telesupervision	Ritu	Verma	APAGS	Given the ongoing pandemic, how might the current maximum 50% telesupervision be modified to remain equitable for trainees and training sites who are required, due to regional, personal, or institutional circumstances and policies, to conduct only/primarily telesupervision?
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-13 M. Telesupervision	Loveless	Loveless	Middle Tennessee State University Clinical Psychology Faculty	The Commission implies without citation that live telesupervision is of poorer quality relative to live face-to-face supervision. The degree to which this is supported by the training literature is questionable, and it is unclear to us why the Commission felt compelled to create a specific IR related to this topic. Technological advancements, like synchronous online video services, allows training to be more flexible and innovative.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-14 M. Direct Observation	Charmaine	Higa McMillan		Thank you for the opportunity to provide a comment on these IRs. I agree with this regulation except for this statement: “the direct observation requirement may only be met by having the appropriately credentialed supervisor(s), legally responsible for the direct service provided, conduct the observation and evaluation.” Some of our program site supervisors are not licensed but provide high-quality supervision (who are themselves supervised, typically by a clinical director). This regulation will limit the field placement sites for our students, particularly in rural areas where there is a shortage of licensed behavioral health providers. In C-12 M. Clinical Experiences Guidelines for Master's Programs the guidelines note that in the event "students are not being supervised on-site by licensed psychologists, the program must provide on-going weekly opportunities for students to discuss their clinical work with a psychologist licensed to practice in the jurisdiction." However, program f...	See Full Comment
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-14 M. Direct Observation	Kimberly	Howard	Society of Counseling Psychology - Division 17	1. The following statement is unclear: "Per IR C-12 M, CoA recognizes that supervision on-site can be provided by a master’s level health service psychology professional appropriately credentialed in the jurisdiction, doctoral interns or postdoctoral residents in HSP under the supervision of a psychologist appropriately credentialed in the jurisdiction. In these situations, the direct observation requirement may only be met by having the appropriately credentialed supervisor(s), legally responsible for the direct service provided, and conduct the observation and evaluation. This does not preclude doctoral interns or postdoctoral residents from contributing to the direct observation or evaluation process." - Does this mean that "appropriately credentialed" master's level HSP professionals couldn't provide direct observation? If so, I worry this is unnecessarily restrictive given the focus of training master's level clinicians.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-14 M. Direct Observation	Ritu	Verma	APAGS	Approved as written.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-14 M. Direct Observation	Amanda	Fanniff	Division 41 American Psychology-Law Society Executive Committee and Teaching, Training, and Careers Committee	As noted in a previous comment, the Teaching, Training, and Careers Committee (TTC) of Division 41 American Psychology-Law Society (AP-LS) reviewed the IRs and submitted considerations and recommendations to the AP-LS Executive Committee. These considerations and recommendations were approved for submission in the public comment period. This IR states “The CoA does not expect that all individual competencies (profession-wide or program-specific (if any)) would be directly observed during every clinical experience, but rather that the scope of the direct observation would be sufficient to contribute meaningfully to an evaluation of student performance in competencies relevant to that clinical placement.” AP-LS requests specific language addressing the need for direct observation of assessment skills in at least one clinical training experience.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-20 M. Selection and Admissions of Students into Accredited Master’s Programs	Robert	Walsh	APA Board of Educational Affairs	C-20 M. Selection and Admission of Students into Accredited Master’s Programs • strongly recommend updating this IR to emphasize not only preparation but equity/inclusion/justice in program selection and admission criteria and procedures.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-20 M. Selection and Admissions of Students into Accredited Master’s Programs	Kimberly	Howard	Society of Counseling Psychology - Division 17	This is clear - it is good that admissions requirements are open enough for programs to determine processes that meet their needs
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-20 M. Selection and Admissions of Students into Accredited Master’s Programs	Ritu	Verma	APAGS	Approved as written.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-20 M. Selection and Admissions of Students into Accredited Master’s Programs	Gillens	Allison	APA Committee on Early Career Psychologists	Section III: Students The CECP agrees that the students’ selection process and criteria need to be intentional about increasing and maintaining diversity, while allowing meaningful peer interaction and support. Some clarity and examples in relation to the supportive learning environment concerning the statement “the program must avoid any actions that would restrict program access on grounds that are irrelevant to success in graduate training” would be helpful. Plans to maximize student success emphasize documentation of efforts and the importance of feedback, which is crucial for the transparency and fair treatment that allows personal and professional growth.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-21 M. Diversity Recruitment and Retention	Ritu	Verma	APAGS	Retention: language should be added that reflects the ways in which programs are responsible for responding to societal and global crises, such as the pandemic, in ways that consider the unique and diverse experiences and circumstances of each individual student. Language should also be added that reflects the ways in which programs are responsible for providing equitable opportunities for diverse students and students with diverse needs. When a policy is unable to adequately meet individual student needs, the program is responsible for developing a retention plan that actively includes the voice of the student and their self-determined capacities.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-21 M. Diversity Recruitment and Retention	Loveless	Loveless	Middle Tennessee State University Clinical Psychology Faculty	We respect and value the Commission’s stated goal of advancing equity and inclusion for diverse peoples within our profession. Furthermore, we agree that training programs should be inclusive places that foster an atmosphere of respect for the rights and dignity of all peoples. With that said, we find the requirement that training programs should make concrete efforts to be affirming of people’s different individual identities somewhat problematic as it does not provide a remedy for when the affirmation of one set of identifies might be perceived as discriminative to others. For example, active affirmation of all identities would include those already well-represented in the majority culture. It would seem that the affirmation of these well-represented identifies might make those from minority communities feel, at best, less affirmed. We would encourage the Commission to either consider rewording this IR, or perhaps to better operationalize what is meant by, “affirming.”
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-21 M. Diversity Recruitment and Retention	Loveless	Loveless	Middle Tennessee State University Clinical Psychology Faculty	Increasing the diversity of the profession is laudable goal, and we can appreciate why the Commission would have a keen interest in addressing this shortcoming via requiring that reasonable efforts are made by graduate programs to recruit and retain qualified diverse individuals. With that said, there were a few critical issues that we would like the Commission to address. The drafted IR places a lot of emphasis on the need for programs to have a regularly updated plan for the recruitment and retention of diverse faculty and students. The IR goes on to discuss the need for this plan to be regularly evaluated for its effectiveness. We would ask the Commission to comment on how we are to evaluate the effectiveness of such a plan when we are prohibited by federal law to ask students and faculty about many of the diverse identities that they have used to operationalize diversity. Beyond this issue, we would ask the Commission to clarify how success in diversity recruitment and retention wi...	See Full Comment
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-24 M. Program Names, Labels, and Other Public Descriptors	Krissie	Smith		There are numerous statutes that only allow doctoral level psychologists to provide forensic assessments to the court. Having additional programs that are accredited and allow for assessment at the masters level is going to be confusing for the public and other consumers of our work. In addition, there are several areas of forensic work that require additional years of training beyond forensic work. It is important that we protect the quality of work within our field in the completion of specialized psychological assessments.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-24 M. Program Names, Labels, and Other Public Descriptors	Eric	Rossen	National Association of School Psychologists	The examples of accurate accreditation status are confusing.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-24 M. Program Names, Labels, and Other Public Descriptors	Eric	Rossen	National Association of School Psychologists	We suggest adding in this section: “Nothing in these Implementation Regulations shall prevent a program from accurately portraying concurrent accreditation from another accrediting agency.”
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-24 M. Program Names, Labels, and Other Public Descriptors	Robert	Walsh	APA Board of Educational Affairs	C-24 M. Program Names, Labels, and Other Public Descriptors • The doctoral IR outlines preferred labels. Will we not have these at the Master’s level?
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-24 M. Program Names, Labels, and Other Public Descriptors	Ritu	Verma	APAGS	Approved as written.
Master's Accreditation IRs (Section C)	Implementing Regulation (IR) C-25 M. Accreditation Status and CoA Contact Information	Ritu	Verma	APAGS	Approved as written.