Accreditation Public Comment System





This project is now closed for new comments.
DocumentSectionItemFirst NameLast NameGroup NameComment 
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Public disclosure IRsMeganO'BanionThe National Council of Schools and Programs of Professional Psychology (NCSPP)NCSPP endorses the proposed revisions to IRs C-27 I and C-23 P (Trainee Admissions, Support, and Outcome Data), IRs C-28 I and 24 P (Consortium), and IRs D.4-8 (a), (b), and (c)(Interim Reporting). In each, the CoA has worked to streamline redundancies and offer clarifications in a manner that NCSPP appreciates and applauds.
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Public disclosure IRsDianaConcannon I endorse the position of NCSPP.
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Public disclosure IRsRadhikaKrishnamurthy I endorse NCSPP's response for all sections.
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Public disclosure IRsGenevieveArnaut  I endorse NCSPP's response for all sections.
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Public disclosure IRsJillonVander Wal I endorse CUDCP's response.
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Public disclosure IRsKurtFreeman Thank you for the opportunity to comment on the proposed revisions to IR C-27 I. I do wonder if there is a typographical error in the Table titled "Initial Post-internship Positions". Specifically, the second row of the table states "Total # of interns who remain in the residency program". While this is not listed as a change from the existing IR, in fact the current IR has the following text in row 2: "Total # of interns who did not seek employment because they returned to their doctoral program/are completing doctoral degree". I recommend keeping the original language. Also, as a former program director, I would have no idea how to classify whether a former intern's current position is "Consortium". It's not clear what that means and I suggest the CoA consider deleting that option. Further, I don't understand the option "Health Maintenance Organization". According to many definitions, this would be a health insurance organization. Certainly psychologists can work for insurance o... See Full Comment
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Public disclosure IRsJeffreyBatesOffice of Academic AffiliationsWe appreciate the opportunity to provide public comment on the proposed changes to Implementing Regulations C-27 I and C-23 P. In these proposed changes, categories for Initial Post-Internship Positions and Initial Post-Residency Positions are modified – including the consolidation of multiple types of health centers (e.g., VA, Academic, Military, and Other) into one category “Hospital/Medical Center.” We would like to request consideration of retaining the different types of medical centers as programs collect data on initial placements. Though we understand a potential need for streamlining data collection processes, the variance in placement that will be lost in collapsing these categories is significant. This variance may not be important to track from a CoA perspective, but the initial placement data can add to the ways in which we assess how our collective training programs are assisting in the recruitment and retention of psychologists in the VA. Providing training to the n... See Full Comment
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Public disclosure IRsDanaHolohanVA Psychology Training Council Executive CommitteeThe VAPTC appreciates the opportunity to provide public comment on the proposed changes for Implementing Regulations C-27 I and C-23 P. Although streamlining the data collection process is ideal, we would like for APA to consider retaining several distinct categories as these are helpful distinctions for trainees considering VA internships and fellowships. In particular, maintaining Veterans Affairs Medical Center, Military Health Center, and Academic Health Center are important distinctions for applicants. In addition, as the table is intended to provide information about a program’s success in achieving its intended outcomes for its trainees, we believe it is important that applicants are able to determine specifically how likely a trainee is to successfully pursue a career with the VA or Military and this information would be lost based on the proposed changes. Finally, the deletion of the categories “Not currently employed,” “changed to another field,” and “unknown” would result i... See Full Comment
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Public disclosure IRsJoshuaWolffAPA Division 44; APAGS; Division 17; Division 27; NLPA; Orgullo Latinx; Division 7; CCPTP; Division 6; Division 16; CECP; Division 51; Division 35; AAPA; Division 1; Division 45; Division 39Submitted on behalf of the Society for the Psychology of Sexual Orientation and Gender Diversity (Division 44); American Psychological Association of Graduate Students (APAGS); Society of Counseling Psychology (Division 17); Society for Community Research and Action; Division of Community Psychology (Division 27); National Latinx Psychological Association (NLPA) and Orgullo Latinx; Developmental Psychology (Division 7); Council of Counseling Psychology Training Programs (CCPTP); Society for Behavioral Neuroscience and Comparative Psychology (Division 6); School Psychology (Division 16); Committee on Early Career Psychologists (CECP); Society for the Psychological Study of Men and Masculinities (Division 51); Society for the Psychology of Women (Division 35); Society for General Psychology (Division 1); Asian American Psychological Association (AAPA): Society for the Psychological Study of Culture, Ethnicity, and Race (Division 45); and Society for Psychoanalysis and Psychoanalytic Psyc... See Full Comment
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Public disclosure IRsLuciaGutierrezCECP The Committee on Early Career Psychologists (CECP) appreciates the Commission on Accreditation’s (CoA) work in continuing efforts to revise the Public Disclosure, Consortium, and Interim Reporting Implementing Regulations (IRs). CECP appreciates the detail provided for programs interested in developing or dissolving a consortium. CECP also appreciates the requirement of programs to complete the proximal data tables, as doing so will provide clear, consistent, and critically important data for prospective students and trainees. Although we appreciate the effort to reduce the number of options in the proximal data tables in order to improve manageability, we are concerned that significantly valuable information will be lost if the categories remained collapsed in the way presented in the current IRs. Having information about the specific setting that students/trainees work in immediately following their internship or fellowship is valuable in that it provides “real world” data that... See Full Comment
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Public disclosure IRsJoshuaWolffAPA Division 44; APAGS; Division 17; Division 27; NLPA; Orgullo Latinx; Division 7; CCPTP; Division 6; Division 16; CECP; Division 51; Division 35; AAPA; Division 1; Division 45; Division 39We wish to add the following name to the comment we submitted earlier: G. Nic Rider, Ph.D. Co-Chair, Asian American Psychological Association Division of LGBTQQ
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Public disclosure IRsRoseannGetchellAmerican Psychological Association of Graduate StudentsThe Public Comment to the APA Commission on Accreditation The American Psychological Association of Graduate Students (APAGS) appreciates the opportunity to respond to the Commission on Accreditation (CoA)’s recently proposed revisions to the Implementing Regulations (IR’s) related to APA-Accredited Internship and Postdoctoral Training Program Disclosures. Thousands of present and future APAGS members are subject to the respective IRs and changes to sites. As such, with this comment, we aim for prospective students and postdoctoral fellows to have essential information about training opportunities and factors that may impact decision making during the application and interview processes. APAGS further appreciates the review of our comment and will make ourselves available to respond to questions or inquiries about the recommendations we have provided. C-27 I Trainee Admissions, Support, and Outcome Data & C-23 P. Trainees Admissions, Support, and Outcome Data Re: I... See Full Comment
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Public disclosure IRsJodTaywaditepAssociation of Counseling Center Training Agencies• We noticed that there are different terms used for the IR’s label versus the webpage title? For the IR’s title, it is “Trainee Admissions, Support, and Outcome Data,” while the webpage is supposed to be titled “Internship Admissions, Support, and Initial Placement Data.” To avoid confusion, we recommend that the CoA use the same terminology for both the IR’s title and the webpage title. The term “outcome data” seems over-inclusive, and may suggest to some that it is about learning outcomes, such as competencies. • The requirement of putting “0” (zero) in every cell is problematic to some sites. TDs have commented that having zeros make it difficult to visually identify the non-zero numbers, and may be even more challenging for visually impaired readers. • Both the tables for Initial Post-Internship Positions and Post-Residency Positions contain columns marked PD and EP, where PD stands for Post-doctoral residency positions in both. This makes sense for the internship table, ... See Full Comment
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Consortium IRsMeganO'BanionThe National Council of Schools and Programs of Professional Psychology (NCSPP)NCSPP endorses the proposed revisions to IRs C-27 I and C-23 P (Trainee Admissions, Support, and Outcome Data), IRs C-28 I and 24 P (Consortium), and IRs D.4-8 (a), (b), and (c)(Interim Reporting). In each, the CoA has worked to streamline redundancies and offer clarifications in a manner that NCSPP appreciates and applauds.
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Consortium IRsDianaConcannon I endorse the position of NCSPP.
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Consortium IRsGenevieveArnaut  I endorse NCSPP's response for all sections.
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Consortium IRsCheryllRothery I endorse the position of NCSPP.
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Consortium IRsCheryllRothery I endorse the position of NCSPP.
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Consortium IRsLuciaGutierrezCECP The Committee on Early Career Psychologists (CECP) appreciates the Commission on Accreditation’s (CoA) work in continuing efforts to revise the Public Disclosure, Consortium, and Interim Reporting Implementing Regulations (IRs). CECP appreciates the detail provided for programs interested in developing or dissolving a consortium. CECP also appreciates the requirement of programs to complete the proximal data tables, as doing so will provide clear, consistent, and critically important data for prospective students and trainees. Although we appreciate the effort to reduce the number of options in the proximal data tables in order to improve manageability, we are concerned that significantly valuable information will be lost if the categories remained collapsed in the way presented in the current IRs. Having information about the specific setting that students/trainees work in immediately following their internship or fellowship is valuable in that it provides “real world” data that... See Full Comment
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Consortium IRsRoseannGetchellAmerican Psychological Association of Graduate StudentsIRs C-28 I and 24 P: Partnership/Consortium Under section II, General Information for a Currently Accredited Consortium Undergoing Dissolution or the Development of New Consortium When One or More Member Entities is Currently Accredited (IRs C-28) 1. The number of available positions, including changes in the figure, are not identified. Losses or gains of posts serve as helpful pieces of information for applicants to consider. 2. The training sites statement on the availability of site “tracks” were not included. Track or training availability is critical to applicants. 3. Additionally, what, if any, changes to the consortiums non-profit status were not included in the demarcation of the site? 4. We suggest including public materials for current/prospective interns to cover any increase/decrease of available internship positions. Such information is vital for interns as they rank locations and anticipate ranking by the number of open positions. 5. Training experienc... See Full Comment
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Consortium IRsJodTaywaditepAssociation of Counseling Center Training Agencies• In IR C-24 P, the serialization in the first section should be from a) to h), not i) to p).
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Interim reporting IRsMeganO'BanionThe National Council of Schools and Programs of Professional Psychology (NCSPP)NCSPP endorses the proposed revisions to IRs C-27 I and C-23 P (Trainee Admissions, Support, and Outcome Data), IRs C-28 I and 24 P (Consortium), and IRs D.4-8 (a), (b), and (c)(Interim Reporting). In each, the CoA has worked to streamline redundancies and offer clarifications in a manner that NCSPP appreciates and applauds.
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Interim reporting IRsDianaConcannon I endorse the position of NCSPP.
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Interim reporting IRsLoringIngraham I endorse the NCSPP response for IRs D.4-8 (a), (b), and (c): Interim Reporting.
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Interim reporting IRsGenevieveArnaut  I endorse NCSPP's response for all sections.
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Interim reporting IRsRyanSharma The calculation offered in the Proximal Data table seems confusing. If we are listing the attempts by year, this would be cross-sectional data and is our preferred method of aggregation. However, the last column asking for the % meeting the MLA by the end of the program is longitudinal data. Because MLAs are offered at different times throughout the program, the number (or percentage) completing each by year will not inform the total number of students achieving the MLAs by their graduation. I recommend omitting the final column and just focus on the outcome indicators by year. Since that last column will (should) be 100% for all items, it's really just a policing column. I don't understand why the CoA doesn't trust that programs won't graduate a student who doesn't pass their statistics course.
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Interim reporting IRsDeboraBellCUDCP (Council of University Directors of Clinical PsychologyThe Council of University Directors of Clinical Psychology (CUDCP) welcomes the opportunity to comment on this Implementing Regulations on Interim Reporting (IR D4-8). The CUDCP Board of Directors, which serves as the elected representatives of our 180+ member programs, drafted these comments. CUDCP appreciates the CoA's efforts to facilitate programs' ongoing compliance with accreditation standards and supports this IR on interim reporting. In particular, CUDCP applauds the CoA's clear articulation of the types of data to be reported and the format in which they should be reported. The table templates will be useful in not only for interim reporting, but also for programs' ongoing tracking of program-level DSK and PWC outcomes. We respectfully make two recommendations intended to help make the IR's instructions as clear and explicit as possible. 1. When does the CoA intend for programs to submit these data? We assume this will be part of the ARO submission, but suggest this be spe... See Full Comment
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Interim reporting IRsKurtFreeman Thank you for the opportunity to comment on proposed IR D-8(b). My comment is specific to the section about substantive changes. The current IR asks programs to briefly summarize any substantive changes PREVIOUSLY report (including the CoA response) and any NEW/ADDITIONAL changes not yet reported. The rationale for expecting programs to report substantive changes twice (when the first report was made, and then again in brief summary as part of the interim report) is unclear. I appreciate that the CoA won't look through all documents regarding substantive changes previously reported at the time of this interim report. However, if the issues have already been vetted and approved by CoA, why ask for the information again? Not a huge burden to programs, just unclear why necessary.
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Interim reporting IRsMatthewJarrett I endorse CUDCP's response.
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Interim reporting IRsJenniferCallahanUniversity of North Texas: Clinical PsychologyThe 10 faculty of the accredited program in clinical psychology at the University of North Texas endorse the CUDCP comment.
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Interim reporting IRsDanaHolohanVA Psychology Training Council Executive CommitteeThe VAPTC appreciates the change enabling quality programs to obtain 10 years between periodic reviews. Although we can appreciate the desire for interim reporting during this time, we believe the benefit of the 10 year accreditation is minimized by requiring programs provide both proximal and distal data, in addition to substantive change history and complaint/grievance reporting at 5 years.
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Interim reporting IRsLuciaGutierrezCECP The Committee on Early Career Psychologists (CECP) appreciates the Commission on Accreditation’s (CoA) work in continuing efforts to revise the Public Disclosure, Consortium, and Interim Reporting Implementing Regulations (IRs). CECP appreciates the detail provided for programs interested in developing or dissolving a consortium. CECP also appreciates the requirement of programs to complete the proximal data tables, as doing so will provide clear, consistent, and critically important data for prospective students and trainees. Although we appreciate the effort to reduce the number of options in the proximal data tables in order to improve manageability, we are concerned that significantly valuable information will be lost if the categories remained collapsed in the way presented in the current IRs. Having information about the specific setting that students/trainees work in immediately following their internship or fellowship is valuable in that it provides “real world” data that... See Full Comment
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Interim reporting IRsRoseannGetchellAmerican Psychological Association of Graduate StudentsD.4-8 (a, b, c). Doctoral Interim, Doctoral Internship, and Post-Doctoral Residency Reporting To demonstrate ongoing consistency with the Standards of Accreditation (SoA), programs receiving 10 years between periodic reviews must provide an interim report 5 years after the beginning of the 10-year accreditation term. 1. Regarding reporting of substantive changes to all doctoral interim, doctoral internship, and post-doctoral residency programs, the current requirement exists on a 5-year mark. We propose that these substantive changes should be made publicly available to trainees at all stages of their learning in real-time (within the month a change occurs), not just at the 5-year mark. This information can greatly impact future professional development and trajectory of trainees, especially when deciding where to apply, who to interview with, and what positions to accept.
Public_Disclosure_Consortium_Interim_Reporting_IRs_for_Public_Comment_FINAL Interim reporting IRsJodTaywaditepAssociation of Counseling Center Training Agencies• This is a good idea to encourage TDs to collect outcome data along the way rather than only in the year of the self-study. However, internship programs are already expected to report to CoA all the substantive changes through the CoA portal in an ongoing manner. Would there be some redundancy in reporting Why are they expected to report substantive changes here again in the Interim Report using the Substantive Change History table? Would the Does the CoA not already have that information? This procedure seems redundant. • Some clarification is needed in the IR D.4-8 (b) Proximal Data Table. What is supposed to go into the second column from the left (labeled “Outcome measure”)? Do we put in references to pages or items in attached evaluation forms? Or do we put the whole list of items and their wording in the cells? • In the section of 1. Proximal Data, there is a typographical error “revisions5.”