Accreditation Public Comment System

This project is now closed for new comments.

Document	Section	Item	First Name	Last Name	Group Name	Comment
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	John	Romano		I was surprised to see that this looks much like APA accreditation standards for doctoral programs, but on the "light" side. I also quesation why the profession needs another Master's program since CACREP and Master Program in Psychology and Counseling (MPCAP) by the Accreditation Council already exist. If APA wants to embark on another Master's program, I suggest one that is more innovative. For example, one that has a strong prevention science component (which is relevant to couns, clinical, and school) and a program that includes coursework related to working across disciplines, e. g. public health medicine,etc.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Corinne	Datchi	APA Division 43 Board of Directors	There appears to be substantial overlap between the proposed accreditation standards for master’s level training in health service psychology and existing accreditation standards for doctoral level training with the exception of the doctoral dissertation. It will be critical to clearly articulate the distinction between Master’s level training and doctoral training and to inform the profession and the broader public about these differences. · It will also be important to emphasize the unique aspects of Master’s programs in health service psychology that differentiate them from Master’s programs in other mental health professions and professional counseling in particular. · The proposed standards for master’s level training include many domains that may be difficult to cover adequately in two years. In particular, research is a core and critical dimension of our identity as psychologists, and it will be important to clarify/emphasize the role of research in the develo...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Alan	Groveman		Why another Master's program? As a past Chair of the NJ Board of Psychological Examiners, I can confidently predict that this will be a logistical nightmare. Issues of licensing, public confusion, further dilution of our professional identity will ensue. Courses in Health Service Psychology can be integrated into doctoral programs. I believe that a Master's in HSP is a solution in search of a problem. Don't psychologists have enough to deal with in terms of recognition and integrative care?
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Alan	Groveman		Every 2-3 years, in NJ, the Legislature attempts to eliminate the MFT (which includes LPC, and Drug and Alcohol Counselors), Social Work and Psychology Boards, and incorporate them into the Medical Board, with a representative of each eliminated Board to serve on the Medical Board. The more license required “Allied Health Profession” Boards, the more pressure to reduce costs and have one large Medical and Allied Health Professionals Board. APA’s endorsement of a Master’s in Health Service Psychology will only serve to further erode our identity.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Tammy	McClain		I think an accreditation process for the master's level health service psychology is long overdue, and it will have to compete with other disciplines (counseling & social work) that are more established and allow for reciprocity between states. While I agree with the integration of empirical evidence & practice, there should be a clearer, more narrow focus at the master's level. The rigor and depth of knowledge in areas directly related to practice should be similar, but the scope of knowledge may be more limited. The focus should be on practice competencies rather than research and the generation of new knowledge. Rather than just trying to limit the scope of the master's training, it might be equally important to expand the scope of doctoral training to include master's training plus identified specialty practice area(s) or proficiency area(s)as recognized by CRSPPP. Master's training should be focused on generalist training for assessment and intervention that integrates empiri...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Lee	Cooper	Association for Behavioral and Cognitive Therapies	We wholeheartedly support the proposed standards for ML-HSP that focus on integrating of science and practice, preparing trainees for practice, and prioritizing cultural and individual differences and diversity. Simultaneously, we have some reservations about the proposed standards. Overall, we believe the current ML-HSP proposed standards are too similar to the APA’s CoA standards for doctoral programs (at times almost verbatim). Consequentially, we are concerned that these standards may be unrealistic for a terminal master’s degree in terms of length, focus, and depth, which would reduce dissemination and adoption of the standards. Specifically, the breadth and depth of coverage of the discipline-specific knowledge (DSK) and profession-wide competencies (PWC) standards may be unrealistic. Importantly, we recognize that the Implementing Regulations (IRs), which have not yet been developed, will address the specifics of each standard. In other words, the devil here is in the IR details...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Jason	Washburn	Council of University Directors of Clinical Psychology	The CUDCP Board appreciates that the standards focus on preparing Master’s level HSP practitioners for the integration of empirical evidence and practice (IA1a). The CUDCP Board encourages CoA to consider changing Standard IA1a to include the integration of "science" and practice, rather than "empirical evidence" and practice. The CUDCP Board believes it is critical for master’s level HSP practitioners to not only understand the efficacy/effectiveness of psychological services, but also the scientific plausibility of psychological services (Lilienfeld, Lynn, & Bowden, 2018).
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Kari	Oyen		As a Licensed Psychologist as well as a trainer of School Psychology, it is unethical to allow Master's level Health Service Psychology programs the option of practicing in the area of School Psychology without additional training. I commend APA for recognizing the need to be creative in finding multiple levels of trained practitioners to meet public need, but we need to ensure that those who are meeting the need are adequately trained to be providing practice in the areas highlighted. To be able to practice at the entry-level in the area of school psychology with competency, one must be trained at the specialist level with training that aligns with the NASP Graduate Educator Standards. Further, one must have an internship that is at least 1,200 hours with 600 of those hours being clocked in a school setting. Allowing a HSP to be able to practice in the area of school psychology without this minimum level of training would be unethical and potentially harmful for some of our most vuln...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	S. Kathleen	Krach		APA should be applauded for considering the mental health needs of individuals throughout the United States. By broadening the number of individuals who could potentially become practitioners, this also expands the possibility of greater accessibility to services. However, this expansion should be built as a generalist HSP degree instead of attempting to allow for differentiated practice areas. As a school psychologist, I cannot imagine anything other than confusion for K-12 schools and graduates of these future Master's level "school psychology" programs. Therefore, we would be encouraging students to take a faster route towards completion of training (Masters over Educational Specialist) but without the standards set forth by NASP. I note that I/O is not included in these sub-specialties. Please reconsider School Psychology for exclusion as well.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Liliana	Lengua		I am a clinical psychologist and Professor at the University of Washington, and have over 30 years of experience conducting research, teaching and doing clinical work. I have supervised many PhD students across my career, and have been involved in multiple APA site visits for accreditation of our department’s clinical psychology program. I also recently helped to developed the University of Washington’s Master's degree in Applied Child and Adolescent Psychology: Prevention and Treatment. The goal of our program is to train clinicians and those working in areas of prevention in the use of evidence-based approaches with children, adolescents and their families. In making these comments, I bring my academic experience and expertise in the clinical scientist model, and the perspective of having developed just the kind of Master’s program you seek to accredit. I think APA accreditation of a Masters degree program in Health Services Psychology is valuable. It fills a need not fil...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Lynn	Fainsilber Katz		Sequential” nature of clinical training: The Standards stipulate that clinical training must be “sequential.” It is unclear what is meant by “sequential,” and I am concerned that the Standards may place an undue burden on both students and the program to provide a certain sequence of clinical training experiences. If a program is hand selecting high quality, evidence-based clinical training experiences in the community, as ours is, would that be considered “sequential”? Do students need to have multiple different clinical training experiences in a particular order before they graduate to have received a high quality education? Not only does this requirement presuppose that all programs that confer Master’s degrees are integrated into existing PhD programs that have their own clinic infrastructure, but also neglects the fact that licensing boards require thousands of additional supervised post-graduate clinical hours before licensure is granted. Students graduating with Master’s de...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Shawna	Rader Kelly	National Association of School Psychologists	The reference to “other practice areas” is unclear and implies that a subspecialty (e.g., “addiction counseling”) within a Master’s level clinical, counseling, or school psychology program could receive accreditation. We recommend specifying clearly the practice areas that could be included in the areas of clinical and/or counseling psychology, but maintain that there is not a subspecialty or “other practice area” in school psychology.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Laurie	Klose		Please remove school psychology from this list. School psychology training programs are not Master's programs. They require a minimum of 60 credit hours- equalling a Specialist Degree or including a Certificate of Advanced Graduate Studies. As such, these Accreditation standards are not relevant to the training of school psychologists.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Leo	Herrman	Kansas Association Of Masters In Psychology	The Kansas Association of Masters Psychologists applaud the APA's efforts to recognize and credential masters level psychologists. Kansas, like many rural and under served areas, relies upon masters level clinicians to help deliver mental health services to individuals who are traditionally under served by medical and behavioral specialists. Masters Level Psychologists have been recognized and credentialed by our State Behavioral Sciences Regulator Board and have served in a competent and professional manner for the last three decades. Our education, training, examination for license (EPPP) and credentialing is equivalent to or exceeds those of other professional groups who enjoy the recognition and privileges of practice and service. Psychologists at the masters level are an integral part of Kansas' behavioral health care system and provide those skills unique Psychologist's in assessment, diagnosis and treatment. It is time to legitimize this group at the national level and gi...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Kelley	Fillion		For section 2: The reference to “other practice areas” is unclear. You could specify clearly the practice areas that could be included in the areas of clinical and/or counseling psychology, but maintain that there is not a subspecialty or “other practice area” in school psychology.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Daniel	Miller		A2 - Offering a Health Service Psychology degree with a school psychology focus makes no sense. A specialist level of training in school psychology is required in the majority of the US state with a minimum of 60 graduate hours, which meet NASP training standards.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Jana	Aupperlee		Thank you for the focus on diversity in the new standards. I appreciate your awareness of this key competency.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Ashlee	Taylor		School psychologists are uniquely qualified specialized instructional support personnel (SISP), who are members of school teams that support students' ability to learn and teachers' ability to teach. They receive specialized advanced graduate preparation that includes coursework and field experiences relevant to both psychology and education. The HSP program does not seem specialized enough to meet that standard for school psychology.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Pamela	August	Missouri Association of School Psychologists	In terms of focus/subspecialty, this is not something that applies well to school psychology. While it may be applicable to clinical and counseling psychology, the Missouri Association of School Psychologists consider school psychology to be a practice area that does not need a designated focus area.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Kirstin	Wilson	Indiana Association of School Psychologists	Having a master level school psychology program is troublesome for licensing within the states. Our state, for example, requires 60 hours of training in order to be licensed to practice in a school which most likely will not occur with a master's level program. Also, the school psychology program should be aligned with the National Association of School Psychologists (NASP) practice model. This practice model guides the practice of school psychologists within the school setting and many personnel evaluation tools are based on this model. The NASP practice model calls for a minimum of 60 hours of graduate courses.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Charles	Archer	Ohio School Psychologists Association	OSPA's Response to APA Health Services Psychology at Master’s Level The Ohio School Psychologists Association (OSPA), made up of practitioners, students, and university trainers in the field of School Psychology, admires the proposal of the American Psychological Association (APA) to recognize the value and importance of master’s level Health Service Psychologists (HSP). Nationwide, there is a tremendous need for more and better mental health service delivery to students, families, and school staff in addition to the larger community in which we reside. Hopefully, this initiative will also make sure to strike a balance between the need to expand services while maintaining both accountability and high standards for the practice of School Psychology. In an effort to do both, our association recommends actions and areas of concern noted in specific areas of the content sections which follow.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Holly	Yoke	West Virginia School Psychologists	A.2. Practice Area: This should be more well-defined. It is unclear whether this will allow for subspecialties within the HSP program areas or if more than counseling, clinical, and school will be permitted to be considered as HSPs. WVSPA holds that there should not be subspecialties permitted under school psychology, and that these subspecialties be clearly defined under counseling and clinical psychology.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Jacqueline	Horn	Association of State and Provincial Psychology Boards	ASPPB applauds the efforts APA/CoA is making toward developing accreditation standards for master's programs in HSP. Clearly much thought and effort have gone into considering what is essential at the master’s level, and we assume that the level of specificity required by psychology licensing boards will continue at the IR level. As you know, the current landscape in psychology regulation is licensure at the doctoral level only for the vast majority of states and provinces, and master's-level licensing is generally the purview of other regulatory boards in both the U.S. and Canada. That said, there are some states and provinces that do allow independent licensure at the master's level under their psychology boards, but in the States, except for West Virginia and Vermont, they practice under titles such as Psychological Examiner, Psychological Associate, or Psychological Assistant - Texas, Alaska, Arkansas, Kansas, Kentucky, Oklahoma, Oregon, Tennessee, Maine, and Maryland are the st...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Carol	Williams	North Carolina Association of Professional Psychologists	Does this draft SoA support Independent Practice for master’s degreed professionals? Is this draft SoA consistent with the scientific model? If not, what provides the foundation for these SoA? As evidenced by APA’s Division of Health Psychology, Health Psychology is already a defined practice area of Psychology. Is Health Psychology included in Health Service Psychology? Clinical Psychology, Counseling Psychology, and School Psychology all have very different skill sets, client populations and responsibilities. There is little benefit to each of those practice areas or to the profession by including them under one title.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Donald	Mott		I am a Licensed Psychological Associate in NC, licensed since 1979. I served on the North Carolina Psychology Board from 1981 to 1983, including a term as Vice Chairperson and a term as Chairperson. I was Chief Clinical Officer and am currently Senior Advisor at Catawba Valley Behavioral Healthcare, a comprehensive behavioral health provider in western NC. The professional experiences described above shaped my professional identity and my beliefs about the practice of psychology. Most important, they convinced me that American citizens benefit tremendously from the services provided by master’s level psychologists. I believe strongly that the most important driving force behind any changes that are made to accreditation standards for master’s level psychologists must be the welfare of our citizens. Given that master’s level counselors, master’s level social workers, and master’s level marriage and family therapists have substantially similar training compared to master’s level psychol...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Karah	Chapman		Within the practice of school psychology subspecialties are not deemed applicable rather school psychologists apply their skills to all practice domains within the profession. School psychology is of itself a subspecialty of psychology practice.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Hurley	Daniel		I want to start by expressing appreciation of the efforts of those creating these Standards given the enormous task that is at hand. At the same time, after reviewing these proposed Standards, I come away with a sense that this is trying to make the doctoral Standards fit a master’s program and I believe this could be a disservice to the students and the programs. Instead of trying to make master’s graduates competent in all the areas of a doctorally trained psychologist, perhaps focus on the core areas of health service psychology that are most likely to occur at this level of training in the workplace. Perhaps a strong focus on just some of the PWCs would be a better use of this very limited timeline of training. Supervision and assessment may be ones that could be reduced to facilitate a stronger focus on the other core components. Furthermore, if doctoral and master’s level training have essentially the same PWCs, how are we differentiating these degrees? Why would someon...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Francine	Conway	NCSPP	The general concern is how this new MA fits into the healthcare system and its relationship to accredited doctoral programs, many of which offer a MA degree in route. In particular, it is not clear what is the scope of practice and how this is different from other MA mental health professions (e.g., LPCCs). The current standards parallel the doctoral standards, but the relationship to accredited doctoral programs is unclear. Distal outcomes for these programs do not list enrollment in an accredited doctoral program, so is it expected that graduates would not potentially go onto a doctoral program? If not, what is the career path, as currently there is not unique licensure for this degree. For currently accredited doctoral programs that grant an MA, would they need to obtain separate independent accreditation for their MA degree. This also raises the issue of how would faculty be defined and counted. Would a a faculty member be able to be core to both the accredited doctoral program a...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Francine	Conway	NCSPP	NCSPP appreciates the work of the Committee to explore possibilities related to an APA-accredited MA degree in psychology. In reviewing the attached, we find several specific and one general concern that we respectfully submit for consideration. An overall challenge with this degree: What is the scope of service that these individuals will provide that is different than LPCCs? To say, "we'll be scientifically-based" implies our peers are not and we are not sure this is accurate or the intended meaning.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Candice	Hargons		As director of training for an MS in counseling psychology, I am excited to see APA develop master's accreditation standards. The field has been engaging in this training for a long time, and yet the options for accreditation that is widely recognized by state boards has been limited. I do agree with aligning more with MPCAC, so that they are integrated into this process.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	stephanie	sokolosky	Texas Association of Psychological Associates	There are many areas for psychology in addition to clinical, counseling, and school. Other areas that are directly related to Health Service Psychology include working with individuals with developmental disabilities (autism spectrum disorder) and their families. Since autism is a lifelong condition, this work includes adults who are no longer school age.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Marsha	Spencer		I think that it is important to acknowledge that the field of school psychology has been working to establish the Educational Specialist (EdS) degree or its equivalent, as the minimal training credential. This degree typical requires a minimum of 60 graduate training hours, rather than many master's programs that require approximately 30. The National Association of School Psychologists (NASP) has well-developed standards for high quality training of school psychologist practitioners. I encourage APA, of which I am also a member, to consider reciprocity with the existing NASP approval, soon to be accreditation, process. Both organizations do wonderful work to advance the fields of psychology and collaboration bewteen APA and NASP would benefit all.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Amy	Balmanno	California Association of School Psychologists	In California, our Commission on Teacher Credentialing, which issues the credential required to practice school psychology, states clearly in the School Psychology Program standards that a candidate must "complete post baccalaureate degree study consisting of a minimum of 60 semester units in a CA Commission-approved professional preparation program specializing in School Psychology." There is not a sub-specialty or "other practice area" in school psychology, so clarification on this topic would benefit potential candidates.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Jackie	Tyson	Board of Educational Affairs	1. Regarding Standard I.A.1 Health Service Psychology, it may be prudent to note that these programs are firmly rooted in psychological principles (psychological empirical evidence, psychological theory, psychological practice) to distinguish specifically from other, similar types of programs.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Jackie	Tyson	Board of Educational Affairs	2. You may want to consider inclusion of “forensic” in the examples in Standard I.A.2 as a type of specialty, as those students often wind up in more general HSP work.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Dawson	Betty		Clinical, Counseling and School Psychology have very different client populations and require very different skills. If these areas of distinct practice are included then it seems appropriate to include other practice areas which also relate to Health Service Psychology, such as Health, Pediatric, Rehabilitation, Addiction, Group Psychotherapy, etc.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Julene	Robbins		As a former Lead Psychologist for a large school district with hiring and evaluation responsibilities to staff a 40 psychologist department, I would not consider applications from Master's Level school psychology candidates when entry level of Ed.S. is what is most appropriate. The NASP Practice Standards delineates those skills needed to practice school psychology ethically and an abbreviated training model is not appropriate in any way. For this reason, I would not consider interviewing nor hiring a master's level individual to serve our students.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	M.G.	Hardiman	Board of Professional Affairs	Note: Below, please find comments relevant to the entire document. (Embargoed and subject to edit until 6pm Eastern on 6/15/2020) Recently, the APA Commission on Accreditation (CoA) invited public comment on the proposed Standards of Accreditation for Master’s degree Health Service Psychology Programs. The Board of Professional Affairs (BPA) appreciates the opportunity to review and provide input on these proposed standards and hereby offers the following comments and considerations: 1. There is concern expressed about the title. 2. There is discussion of using “appropriately trained” personnel for clinical supervision. Suggest this be spelled out as either doctoral psychologists or those with masters in psychology depending on intent (i.e., not psychiatrists, counselors, etc.) 3. There is not a description of a thesis, exam, or other measure of master’s level attainment in the document. As such, BPA would like to know if there is a minimum level of research experience bein...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Jim	Deni	North Carolina School Psychology Association (NCSPA)	On behalf of the North Carolina School Psychology Association (NCSPA) we wish to express our significant concerns about the APA M-HSP which specifically names school psychology as one of three practice areas under health service psychology. In NC there is no Masters level entry into school psychology. All specialist-level programs in NC have a nonterminal master's degree due to state education policies related to practice, salaries, and internship requirements. Graduates of a HSP program would not be employable in NC as a school psychologists.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Pamela	Fenning	Trainers of School Psychologists (TSP) and Trainers of School Psychologists New York (TSP-NY)	The Trainers of School Psychologists (TSP) is not prepared to make a full statement at this time, yet are preparing to make a more complete statement at a later date. However, we want to take this opportunity to respond during the public comment period. Specifically, we seek assurance that the proposed APA Standards of Accreditation for Master’s Programs in Health Service Psychology are not intended to be a method of entry for credentialing of school psychologists within state departments of education. (Submitted on behalf of Trainers of School Psychologists and Trainers of School Psychologists-New York).
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Laura	Quinn	Laura Quinn and Thomas J. Thompson	Again, the program should prepare Masters level to meet standards to practice independently. This lack of advocacy for Masters' independent practice has consistently prevented our interest in joining APA and NCPA. Full advocacy for independent practice of masters level psychologists would bring more students into psychology programs and more members into APA.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Gloria	Miller	School Psychology Faculty, University of Denver	The following is a commentary on the entirety of the SOA: Dear Colleagues: This is a consensus letter from the faculty in the School Psychology program within the Morgridge College of Education at the University of Denver, located in Denver, Colorado. As graduate educators of school psychologists, we seek affirmations that the proposed American Psychological Association (APA) Standards of Accreditation for Master’s Programs in Health Service Psychology (M-HSP SoA) are not intended to be a method of credentialing master’s level graduate students within state departments of education. We believe the current draft proposal insinuates that the M-HSP SoA will accredit master’s HSP programs, including school psychology, as entry level pursuants to school-based mental health services. We have grave reservations about the proposed language, as currently outlined, since it inaccurately reflects the national standards of training expected to be certified or licensed to practice as a non...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	June	Preast	University of Alabama, School Psychology Program	We commend APA for undertaking this effort and recognizing the need for practitioners at multiple levels of training to meet the needs of the public and the focus on diversity throughout the draft standards.Standard I.A.1.a should be more strongly grounded in psychological science.
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	UMMP	Board	Group	UMMP (United Michigan Masters in Psychology) is a non-profit association which provides advocacy for strong, competent, Master’s Degree Psychologist practice. UMMP promotes the Science of Psychology, the removal of barriers that prevent competent psychologists from providing services, and the removal of barriers to public access to much needed psychologist-based services. UMMP promotes the professional identity, competence and strength of the field of psychology as a whole – inclusive of Master’s and Doctorate practice. UMMP is the only independent Association in Michigan specifically representing Master’s Degree Psychologist licensees, of which, there are nearly 4,000 licensees in the State. In addition to commentary in this format, UMMP has emailed a letter to the CoA’s listed email address with further reference and context to these public comments which did not fit this format. We anticipate it will be appended and available for public review as other email documents and letters of...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	A. Type of Program	Samara	Way		While I support APA's efforts to provide additional, non-doctoral pathways for health service providers, I want to echo the concerns expressed by others regarding the proposed HSP Masters level accreditation in the practice area of school psychology. The proposed program of study does not meet the minimum standards outlined by the National Association of School Psychologists in respect to a number of factors, most notably length of program and clinical training requirements.
SoA for Masters Degree	I. Institutional and Program Context	B. Institutional and Administrative Structure	Tammy	McClain		One challenge for states that are struggling with not having sufficient psychological services for rural residence is that it is often difficult to attract faculty from diverse backgrounds, particularly from cultures that are underrepresented in the state within which the program is housed. While it is important for graduates to recognize cultural and individual differences and diversity, I hope that reviewers will recognize the difficulties that programs in less diverse areas of the country may have in attracting candidates, and that providing training to students in the diversity that does exist will be appreciated. I also do not think that production of research is important for master's level HSP and that the goal should be to be consumers of empirical research as it relates to practice. This further differentiates masters and doctoral scope of practice.
SoA for Masters Degree	I. Institutional and Program Context	B. Institutional and Administrative Structure	Jana	Aupperlee		•The faculty credentials, administration, and sufficiency are poorly defined. Please clarify further.
SoA for Masters Degree	I. Institutional and Program Context	B. Institutional and Administrative Structure	Kristen	DeYorio		I agree with the premise of the Institutional and Administrative Structure. Promotion of diversity and understanding how to navigate it professionally, is an important aspect of the field of psychology.
SoA for Masters Degree	I. Institutional and Program Context	B. Institutional and Administrative Structure	Jim	Deni	North Carolina School Psychology Association (NCSPA)	Greater specifically is needed with regarded to faculty credentials, program administration, and faculty sufficiency. Standard I: Institutional and program Context and Standard IV: Faculty. As written there is no requirement the program faculty in the Masters-HSP have any training as a school psychologist. The training faculty in school psychology specialist-level training have unique and specific skill sets in school psychology. And the Masters-HSP should be more grounded in psychological science.
SoA for Masters Degree	I. Institutional and Program Context	B. Institutional and Administrative Structure	Samuel	Song	Council of Directors of School Psychology Programs (CDSPP)	More emphasis could be given to cultural diversity, and specifically adopting the language and understanding of the APA 2017 Multicultural Guidelines. Although this language was likely and understandably adopted from the doctoral SoAs, this language does not reflect APA's shift toward understanding systems, structures, oppression, and social determinants of health disparities. It will be important to shift away from outdated language and understanding.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Amy	Cannava		Many Specialist-level School Psychology graduate programs award the Master's degree after the first year (approx. 35 credits) and a Specialist degree at the culmination of three years of full-time study including a year-long practicum and internship. As the first year does not include sufficient time for clinical application and supervision, not awarding an HSP until after the end of the second year is appropriate, but would require a change in most program structures.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Lee	Cooper	Association for Behavioral and Cognitive Therapies	Section I.C.2. The SoAs can currently be interpreted to allow a fully online training program. The SoAs should be clear whether this is an option for programs, or not.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Jason	Washburn	Council of University Directors of Clinical Psychology	The CUDCP Board understands the desire to allow for the accreditation of master’s level programs in HSP to support fully online programs; indeed, such an allowance is consistent with master’s level accrediting standards in other disciplines. The CUDCP Board, however, believes that in-person education and training provides substantial benefits, particularly in quality assurance. Indeed, a residency requirement may prove to further differentiate the quality of training provided by HSP from training provided in other disciplines. As such, the CUDCP Board strongly encourages CoA to consider including some level of residency requirements in the standards for all programs.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Adams	Kimbelry		I have concerns about the length of training. As a school psychologist, I cannot support a master's level program without a year of internship (resulting in a Specialist degree). Additionally, this level of training does not align with NASP standards, creating confusion regarding the standards for the entry level of practice and creating a 2-tiered school psychology system.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Kari	Oyen		Those HSP programs that want to specialize in school psychology training should require, at a minimum, 60 graduate semester hours for students to be able to engage in the practice of school psychology. The entry level degree for the practice of school psychology is an Ed.S. level degree with a minimum of 1,200 hour internship with 600 of those hours in a school-based setting. This aligns with the NASP Graduate Educator Standards and highlight the distinct competencies required for the unique practice of school psychology. These should be separate and unique from the practice of health service psychology.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Sterling	Stauffer		School psychologists in many states are required to complete at least 60 credit hours of graduate work with an additional 1200 hour internship. I think this could be problematic for individuals looking to go into school psychology as they might complete an HSP program, and yet not meet the criteria to be licensed as a school psychologist. Certainly this wouldn't be the case in all states, but I believe it would be a concern in the majority of states. As a practicing school psychologist, I also think the 60 graduate hour training plus 1200 hour internship should be considered as a base requirement. The variety of services provided in schools I think require a greater level of training than could be provided by a two year program, which could vary widely in the number of credits required and thus the training provided.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Liliana	Lengua		I have concerns with the term “Sequential” nature of clinical training: The Standards stipulate that clinical training must be “sequential.” It is unclear what is meant by “sequential,” and I am concerned that the Standards may place an undue burden on both students and the program to provide a certain sequence of clinical training experiences. If a program is hand selecting high quality, evidence-based clinical training experiences in the community, as ours is, would that be considered “sequential”? Do students need to have multiple different clinical training experiences in a particular order before they graduate to have received a high quality education? Not only does this requirement presuppose that all programs that confer Master’s degrees are integrated into existing PhD programs that have their own clinic infrastructure, but also neglects the fact that licensing boards require thousands of additional supervised post-graduate clinical hours before licensure is granted. Stu...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Jacqueline	Brown	University of Montana School Psychology	Upon review of the M-HSP standards of accreditation, the University of Montana School Psychology faculty have the following comments. We would first like to extend our appreciation to APA for acknowledging that more non-doctoral level practitioners are needed to fulfill needs in multiple contexts. Despite this strength in the proposal, we have the following concerns: 1) Our specialist in school psychology program (SSP) is approximately 69 credits. Because Specialist programs require more credits and additional training than master’s programs, individuals who enroll in HSP programs with their specialty area being school psychology, may not meet the required professional standards set forth by the National Association of School Psychologists (at least 60 credit hours). Our SSP program is accredited by NASP and our PhD program is accredited by both NASP and APA, so taking both accreditation standards into account is important. 2) Along these same lines, SSP programs are usually three...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Shawna	Rader Kelly	National Association of School Psychologists	C.1.a - Program Context and Resources: Program Leadership Program leadership suggests that someone with a degree in clinical psychology can lead a school psychology program, and vice versa. This does not seem appropriate or in the best interests of students and undermines the specialties of these disciplines. Specific guidance around appropriate faculty and program leadership with training and experience in the specialty area should be required.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Shawna	Rader Kelly	National Association of School Psychologists	C.2 - Program Context and Resources: Length of Degree, Delivery Method, and Design As currently written, the standard requires a minimum of 2 years full-time graduate-level study, with one-year full-time residency within the program granting the degree, suggesting the potential for one year of coursework within the specialty area. Identifying minimum semester and quarter hours would be appropriate without a more clearly defined definition of “one academic year.” HSP programs preparing for practice in school psychology should require a minimum of 60 graduate semester hours in the specialty area of school psychology to align with NASP’s professional standards.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Shawna	Rader Kelly	National Association of School Psychologists	C.2.a. - Program Context and Resources: Length of Degree, Delivery Method, and Design Some School Psychology programs offer the option for students to obtain a non-terminal master’s degree after Year 1, often to make them eligible for step pay increases that may be available in school districts. The proposed requirement for “2 years full-time graduate level study” may interfere with the conferral of these non-terminal degrees. We recommend language that explicitly differentiates when there is a non-terminal Master’s degree that students may qualify for.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	John	Garruto	New York Association of School Psychologists	C.1.a - Program Context and Resources: Program Leadership Program leadership suggests that someone with a degree in clinical psychology can lead a school psychology program. This does not seem appropriate or in the best interests of students and undermines the specialties of these disciplines. NYASP recommends specific guidance around appropriate faculty and program leadership, in addition to a requirement of training and experience in the specialty area. C.2 - Program Context and Resources: Length of Degree, Delivery Method, and Design Health Services Psychology programs preparing for practice in school psychology should require a minimum of 60 graduate semester hours in the specialty area of school psychology to align with standards within New York State, as well as NASP’s professional standards. A minimum of three years is necessary to provide for the development of professional competencies learned and refined within the graduate courses, inclusive of the one year (1200 ho...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Peggy	Brady-Amoon	Alliance for Professional Counselors	The Alliance for Professional Counselors (APC; www.apccounseloralliance.org), a membership organization of counselors, counselor educators, and allies, which works to promote “broad and inclusive recognition of highly trained counselors, … remove barriers to care for those seeking services, and…professional counseling services that are empirically-based and informed by cultural competence and a social justice perspective” (APC mission statement), supports APA’s recognition of the master’s degree, the recommendations of the BEA Master’s Task Force, and the proposed SoA for Master’s training in Health Service Psychology (HSP). We also offer the following recommendation for revision that, while necessarily stemming from and referring to our individual and collective experiences, are broadly applicable to HSP. I – Institutional and Program Context C.2. In this section, we support the listed goals for training. However, we have concerns about the provision and assumption that “on...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Suzanne	Botana		Please support a a minimum of 2 years full-time graduate-level study with one-year full-time residency within the program granting the degree, suggesting the potential for one year of coursework within the specialty area. The body of knowledge and skills to be proficient are significant and matching the expectation set by NASP assures high quality preparation and no confusion in preparedness across employers or work environments, parents or licensing boards. Suzanne Botana Ph.D.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Patsy	Brock		The minimum requirements should be at least 60 graduate semester hours in the area of school psychology so that it aligns with NASP standards. This may cause confusion in licensing and hiring because of states requiring NASP standards.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Laurie	Klose		School psychology training programs require more than two years and include one full academic year of supervised internship. This standard as written could allow some programs to create programs that are inadequate in their preparation of school psychologists.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Kelley	Fillion		C.1.a - Program leadership suggests that someone with a degree in clinical psychology can lead a school psychology program, and vice versa. This does not seem appropriate or in the best interests of students and undermines the specialties of these disciplines. Specific guidance around appropriate faculty and program leadership with training and experience in the specialty area should be required. C.2 - Identifying minimum semester and quarter hours would be appropriate. HSP programs preparing for practice in school psychology should require a minimum of 60 graduate semester hours in the specialty area of school psychology to align with NASP’s professional standards. C.2.a. - Some School Psychology programs offer the option for students to obtain a non-terminal master’s degree after Year 1, often to make them eligible for step pay increases that may be available in school districts. The proposed requirement for “2 years full-time graduate level study” may interfere with the confer...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Daniel	Miller		C2 - one year of full-time residency requirement - sounds good but COVID-19 changed all that. Consider changing the language to allow for more distance education delivery options.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Daniel	Miller		C2 - the word "fulfil" is misspelled
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Daniel	Miller		The minimum number of graduate hours is not specified, which will lead to poor practice.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	David	Lillenstein	Association of School Psychologists of Pennsylvania & The Pennsylvania Psychological Association	Together, the Association of School Psychologists of Pennsylvania (ASPP) and the Pennsylvania Psychological Association (PPA) reviewed the HSP standards and compared them with the current NASP standards and the Commonwealth of Pennsylvania regulations (see Chapter 49 of the School Code) for preparing entry-level school psychologists. All of the school psychologist training programs in Pennsylvania follow the NASP Standards for training. The NASP requirement is for at least two full years of coursework and an additional full year of internship. The proposed HSP standards do not require these experiences. The HSP standards also do not align with Pennsylvania Department of Education (PDE) requirements for training programs, or for students completing such programs to obtain Educational Specialist I (School Psychologist) certification in Pennsylvania. Hence, students completing HSP programs that met the proposed standards would not be eligible for the School Psychologist certifi...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Brian	McKevitt	Nebraska School Psychologists Association	The entry level amount of training for a school psychologist is 60 graduate semester hours, which requires more than two years of study. In Nebraska, our graduate training programs in school psychology are 3-4 year programs for the EdS degree. Given the extensive work of school psychologists in our state as academic, mental, and behavioral health service providers, a minimum of 3 years or 60 graduate semester hours is critical for ensuring sufficient training to meet the needs of students, teachers, and families. This minimum is consistent with national standards for school psychology training and we urge you to consider requiring this minimum for HSP programs in school psychology. We understand the need for more professionals available to meet the growing behavioral and mental health needs of children and adolescents. In Nebraska, 2018-19 school year data indicate a ratio of one school psychologist for every 1,080 public school students. The updated NASP recommended ratio is 1:500. ...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Ashley	Arnold		School psychologists must obtain a minimum of 60 graduate semester hours in coursework outlined in the NASP Standards for Graduate Preparation of School Psychologists. It is only after this extensive graduate work do school psychologists develop the competency and skill set necessary to provide comprehensive services in a school setting. Specialist-level training is the entry to practice school psychology.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Jana	Aupperlee		Lowering the standard for the profession of school psychology (from the EdS to the MA level) has the potential to reduce the quality of services provided to youth, families, and educators. It also has the potential to place practitioners in schools without the knowledge and skills to ethically serve this population. School psychology is a complex discipline requiring knowledge of schools, knowledge of education, classroom management, systems, prevention, special education ethics and law, as well as assessment, intervention, and consultation. HSP programs preparing health service psychologists in school psychology should require a minimum of 60 graduate semester hours to align with NASP’s professional standards. A master’s degree is NOT the entry-level for practice as a school psychologist. We cannot lower the training and standards without negatively influencing stakeholder outcomes. Our program offers a non-terminal masters degree. This degree allows students to achieve paid i...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Jana	Aupperlee		• Lowering the standard for the profession of school psychology (from the EdS to the MA level) has the potential to reduce the quality of services provided to youth, families, and educators. It also has the potential to place practitioners in schools without the knowledge and skills to ethically serve this population. School psychology is a complex discipline requiring knowledge of schools, knowledge of education, classroom management, systems, prevention, special education ethics and law, as well as assessment, intervention, and consultation. HSP programs preparing health service psychologists in school psychology should require a minimum of 60 graduate semester hours to align with NASP’s professional standards. •A master’s degree is NOT the entry-level for practice as a school psychologist. We cannot lower the training and standards without negatively influencing stakeholder outcomes. •Our graduate program offers a non-terminal masters degree. This degree allows students to a...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Dickinson	Emma	Nevada Association of School Psychologists	Although Nevada is impacted by shortages of school psychologists as is the rest of the nation, we feel it is imperative to adhere to the National Association of School Psychologists (NASP) national standards of preparation of school psychologists. APA’s proposal for accreditation of Health Service Master’s Degree programs (HSP) calls for a minimum of 2 years of graduate level work and one year full-time residency within the program granting the degree, suggesting that one year of coursework would suffice. This is clearly at odds with NASP standards which calls for specialist-level training of a minimum of 60 hours, with a 1200 full time internship, and 600 hours of which require in-school experience. If programs fall short of this standard, it would detract highly from well-trained and experienced individuals with the title of School Psychologist entering the field. Your proposal does not include a clear delineation between “master’s degree” or “master’s level” and specialist progra...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Nichole	Lakey		NASP accredited school psychology programs require 60 graduate semester hours and a minimum of 1200 hours of internship (with a minimum of 600 hours completed in a school setting) in the specialty area of school psychology. This standard is less than that, and is insufficient for practice in the schools as a school psychologist. A graduate from a program like this would not be eligible to certify as a school psychologist under these standards.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Teresa	Fritsch		I originally put this in the wrong section so am putting it in the correct section now: As a nationally certified school psychologist and a member of the National Association of School Psychologist's Leadership Assembly, I have significant concerns related to the Length of Degree, Delivery Method, and Design section, because it directly conflicts with NASP's Standards for Graduate Programs. I do not believe the number of hours you have listed for this master's level program will adequately prepare students for the work force of school psychology. I've been a practitioner for 27 years and know the amount and complexity of knowledge a school psychologist must have graduating from a program and begin working right out of the starting gate (education, ethics, counseling, assessment, child development, etc.). I would highly recommend 60 graduate semester hours in the specialty area as a school psych in training will need all of those hours; this also matches NASP's Standards.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Jill	Battal	Massachusetts School Psychologists Association	The Massachusetts School Psychologist’s Association (MSPA) strongly encourages specialist level training requirements (60 graduate semester hours, aligned to NASP’s professional standards), which reflect the standard minimum entry into the field. Decreasing this requirement will lead to confusion for several types of consumers, including families, school districts and licensing/credentialing bodies.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Emilie	Ney		As a school psychology graduate educator, I have concerns about the length of the program. When accrediting school psychology degrees, a two year program is inadequate to cover the competencies required of school psychologists and it falls below the standards set by NASP for the training of school psychologists. The specialist level degree is the standard degree requirement in school psychology, which is a 60 credit degree. In order to present consistency, school psychology programs should be required to include a minimum of 60 credits. Similarly, when setting requirements for program length, consider specifying a number of credits that are required rather than a length of time.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Andy	Mogan		The National Association of School Psychologists's professional standards would suggest that for those individuals in HSP programs hoping to practice in school psychology that a minimum of 60 graduate semester hours in the specialty area of school psychology are required. Alignment with NASP's professional standards will help to ensure programs train students similarly and to avoid issues with licensure/credentialing bodies.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Scott	Crooks		Working in a multi-cultural program focusing on non-traditional students has allowed me to see then unless we allow flexibility we will constantly struggle to find and educate professionals from diverse backgrounds. The terminology in “2 years full time” does not specify the credit hours required, and needs clarification. It also does not allow for non-traditional students who may require flexible scheduling. Currently the entry level requirements for school psychology are 60 credit hours plus a 1200 hour internship. To require less would undermine the level of training and professional standards that have already been established.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Margarita	Marnik		As a school psychologist who has experienced firsthand the drawbacks of contracting clinical psychologists to provide school psychological services, I am very concerned with the implications of offering school psychology as an option in a 36 hour program in health psychology. Schools are complex systems with complex and diverse needs that require comprehensive training and supervised, direct experience in schools, as recommended in the NASP guidelines. Despite their extensive doctoral training, the contractees with a solely clinical background were not sensitive to the issues that arise in school and it was not uncommon for me as a specialist level practitioner to be asked to dig deeper to find the missing issues or explain how their findings informed the student’s learning process and interventions. While a masters degree in health psychology could be a good springboard for a specialist degree in school psychology, it will not by itself provide the training necessary to function as a ...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Pamela	August	Missouri Association of School Psychologists	Because of the unique nature of schools, school systems, and special education law, it is essential that school psychologists are trained and led by other school psychologists. It appears that people with clinical or counseling degrees could lead a school psychology program, and we do not believe this would lead to adequate training in our profession. It could seriously undermine the program’s ability to provide adequate training. We would like to see specifics about which degrees are appropriate to lead which programs. The terminology in “2 years full time” does not specify the credit hours required, and needs clarification. It also does not allow for non-traditional students who may require flexible scheduling. Currently the entry level requirements for school psychology are 60 credit hours plus a 1200 hour internship. To require less would undermine the level of training and professional standards that have already been established. In some districts and states, school psych...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Kimberly	Sherman		For school psychologists, the specialist level training (typically 2 years of graduate study plus a one-year internship) should continue to be the minimum standard for entry into practice, consistent with many states' certification criteria. APA's proposed standards merely call for a 2-year master's program. Students who complete such a program would be ineligible for certification in many states and would not be adequately prepared to exhibit the broad range of competencies needed to work as school psychologists. By promoting a reduction in the entry-level practice criteria, these standards risk harming the public (e.g., by failing to ensure that future school psychologists are adequately trained to serve the public and by failing to ensure that training standards are consistent with criteria that will make graduates employable).
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Jared	Dart	Search Results Web Result with Site Links Virginia Academy of School Psychologists	VASP is concerned that the training standards as written are not consistent nor do they align with NASP Graduate Education standards. The entry level degree to practice as a School Psychologist is the EdS specialist degree in which future practitioners are required to earn a minimum of 60 credits hours. In addition, specialist level school psychology students must also complete a 1200 hour internship with at least 600 hours completed in a school based setting. The difference in standards will likely cause confusion. In addition, current Virginia state regulations for the pupil personnel license would prohibit those who completed a program of less than 60 hours from being eligible to become credentialed. Such programs would have difficulty surviving as they would not be recognized as viable for training school psychologists. As such, these programs would not help in addressing shortage issues.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Jared	Dart	Search Results Web Result with SitVirginia Academy of School Psychologists	VASP is concerned that the training standards as written are not consistent nor do they align with NASP Graduate Education standards. The entry level degree to practice as a School Psychologist is the EdS specialist degree in which future practitioners are required to earn a minimum of 60 credits hours. In addition, specialist level school psychology students must also complete a 1200 hour internship with at least 600 hours completed in a school based setting. The difference in standards will likely cause confusion. In addition, current Virginia state regulations for the pupil personnel license would prohibit those who completed a program of less than 60 hours from being eligible to become credentialed. Such programs would have difficulty surviving as they would not be recognized as viable for training school psychologists. As such, these programs would not help in addressing shortage issues.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Charles	Archer	Ohio School Psychologists Association	Section I, C.2 -Program Context and Resources: Length of Degree, Delivery Method, and Design In the absence of collaboration and cooperation with existing organizational standards to train and credential those hoping to work in the field as a School Psychologist such as those established and revised over the course of many years by the National Association of School Psychologists (NASP), this initiative will surely result in confusion for many. Prospective students in the field, stakeholders and parents, credentialing bodies usually organized by each state, and potential employers could be faced with three different tiers of School Psychologists with Master’s from new HSP programs, Specialist Level trained graduates as is currently the norm throughout the country adhering to existing NASP standards, and Doctoral graduates that are currently following either NASP or APA standards (or a combination of both). Such confusion will most likely not result in improved mental health care n...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Jayne	Boulos	Maine Association of School Psychologists	Section 1 C.2 The Maine Association of School Psychologists are in disagreement with the Master’s level program context and length of degree time, delivery method and design that is currently suggested by the APA. As written, the standards require a minimum of two years graduate level study followed by a one-year full-time residency which is far below the 60-credit hour program and 1200 hour internship that the current school psychologists must complete to practice at school. This inconsistency with current NASP standards will be a threat to our practice and our practice model. It will also cause great confusion in schools, to families and licensure and credentialing bodies.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Darcie	Tramp		Particularly in the area of school psychology, it is imperative that school psychologists are trained, led, and supervised by fellow school psychologists. School psychology differs from that of other types of psychology, and it only makes sense that trained and competent school psychologists train and prepare other school psychologists. Just like with any sub-area of a broader field, like-professionals must train and lead their colleagues; why shouldn’t a heart surgeon train and lead a brain surgeon? Obviously, that simply makes no sense, because a heart and a brain are not the same organs; they each have very specific and differing functions--the same with school psychologists and other areas of psychology.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Kimberly	Adams	Minnesota Association of School Psychology	The Minnesota School Psychology Association (MSPA) opposes the recommendation that HSP programs reduce the requirements for entry into the school psychology profession. MSPA advocates for a minimum of an Education Specialist degree (2 years full-time graduate-level study with one-year fulltime residency). Allowing entry to the profession of school psychology at a Master’s level will create confusion for stakeholders (prospective students, licensing bodies, school districts, etc.). Aligning with the NASP Practice Model creates a clear understanding for these stakeholders as to the capacity and breadth of school psychologist’s training and alignment with the NASP Practice Model. Different standards for training will unnecessarily confuse the credentialing process, would mislead stakeholders as to the knowledge, skills, and abilities, and could create a two-tiered system of accreditation.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Holly	Yoke	West Virginia School Psychologists	C.1.a. Program Context and Resources: Program Leadership: This section alludes that a clinical psychologist could lead a program in school psychology, or a school psychologist could lead a program in counseling psychology. WVSPA believes that this would be detrimental to our training programs in all specialty areas of Health Services Psychology. It is important that training program leadership and faculty be clearly defined. C.2. Program Context and Resources: Length of Degree, Delivery Method, and Design: As the standards are currently written this requires a length of 2 years of full time graduate courses, with one year of coursework within the specialty. WVSPA believes that the HSP programs that confer degrees in school psychology should follow the NASP standards of a minimum of 60 graduate semester hours within the area of school psychology C.2.a. Program Context and Resources: Length of Degree, Delivery Method, and Design: At times, school psychology programs offer non-terminal...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Megan	Cutrer		I have concerns for the length of the program time listed as Master's. School Psychologists offer a variety of expertise in many similar areas within the school setting. The minimum is a 60 hour program with many going beyond that. It also requires a 1200 hour supervised internship, with 600 hours required in the school setting. Considering the breadth of what school psychologists do concerning assessment, counseling, academic and behavioral intervention, program evaluation, as well as crisis management, the typical two-year master's degree would not cover the essential course work and practicum work necessary to be competent in this skill-set.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Ginger	Newberg		With regard to the length of degree, delivery method, and design, "a minimum 2 full-time academic years..." is too vague. A minimum of 42 or 45 hours of graduate coursework in addition to internship and practicum should be the standard.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Carol	Williams	North Carolina Association of Professional Psychologists	The SoA includes Program Administration and Structure, that appears to be aspirational as opposed to standards that can be observed and measured. How does this improve on current SoAs already well accepted and integrated into state and provincial licensing boards?
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Carol	Williams	North Carolina Association of Professional Psychologists	Why is there no set or recommended number of required graduate hours or semesters? Why does this draft SoA, section Discipline Specific Knowledge and Profession-Wide Competencies, provide that only a “general knowledge base in the field of psychology” need be acquired? These should be core components and foundational for psychology. How is it that bachelor’s courses could be applied here? These tenets leave open the door for programs that will meet very minimal standards according to this SoA, that may graduate students ill prepared for the practice of psychology. Does it seem to make sense that the APA, an organization that should represent the field of psychology the best, provides vague and undefined SoA for students?
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Karah	Chapman		C.1.a - Program Context and Resources: Program Leadership Because of the unique nature of the education system including the variety of types of schools, school systems, laws and policies, it is essential that school psychologists are trained and led by other school psychologists who have appropriate knowledge and background to instruct appropriately within this unique arena. It appears in this proposal that individuals with clinical or counseling degrees could lead a school psychology program, and we fear this would lead to inadequate training in our profession. More specifics about which degrees are appropriate to lead which programs is sought.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Karah	Chapman		C.2 - Program Context and Resources: Length of Degree, Delivery Method, and Design The statement, “2 years full time” does not specify the credit hours required, and requires clarification to ensure that all required areas of knowledge are able to be provided in the training program. This description of a time limitation causes inflexible programming to non-traditional students. The current entry level requirements for school psychology include 60 credit hours plus a 1200 hour internship. To require less would be insufficient and undermine the level of training and professional standards that have already been established. C.2.a. - Program Context and Resources: Length of Degree, Delivery Method, and Design In some districts and states, school psychologists are able to obtain a Master’s Degree during their studies to make them eligible for pay increases while they continue their training. We would like to see clarification of how this would look under the APA regulations.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Katherine	Chenier		I am concerned that the proposed training standards are less than the minimum requirements for a school psychologist currently required by NASP (60 hours of coursework, 1200 hour internship) and for licensure in many states. As a supervisor of entry-level psychologists and interns, it is clear that the internship is critical for school psychologists to develop requisite skills. Watering down these requirements would be a disservice to children, schools, and practitioners.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Bradley	Petry		This description does not take into account the training scope and sequence as indicated in NASP practice and training standards, given language specifically related to the NASP practice model alignment, the need for training to NOT terminate in a master's degree, but a specialist degree that is awarded following didactic training and a one full year of specially supervised internship, and the national recognition of school psychology training graduate programs by NASP.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	stephanie	sokolosky	Texas Association of Psychological Associates	The standards set forth in this document are unclear. The state psychology board rules and guidelines are much more clear than this document.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	stephanie	sokolosky	Texas Association of Psychological Associates	A minimum of 2 full academic years of graduate level study is non-specific. If this document is intended to provide guidance, these guidelines cannot be evaluated for effectiveness. Semester-hour equivalents seem to be the accepted standard, however, this document is not clearly worded.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	stephanie	sokolosky	Texas Association of Psychological Associates	The term "aims" is confusing. A training "goal" is more clear, and can be identified.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Moery	Teresa		Section I, C.2: This section is inconsistent with the current NASP Standards for training and licensure. Also, reducing the breadth and depth of training will be detrimental to the practitioner's ability to engage in a broad range of abilities, as reflected in the NASP Practice Model. These inconsistencies will cause confusion among all stakeholders, including prospective practitioners, licensing agencies, employers, and trainers.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Janel	Richardson		As a school psychologist who completed a program at the specialist level, I am disappointed to see the minimum standards set forth in this proposal do not conform to the rigor and standards set forth by NASP for entry into the field. Please consider the uniqueness of the field of school psychology and how these inconsistencies pose potential threats to practice, in addition to confusion among prospective stakeholders and licensing bodies.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Kristen	DeYorio		While the idea of a consortium makes sense financially, and allows additional resources to be used within one specific program, there are a number of deficits. Speaking from experience, my undergraduate degree in psychology included two biology classes taken as part of a consortium with the science department at Fordham University. While the coursework was rigorous and demanding, the focus was on cellular development and functioned as a starting point for pre-med students; it did not provide an adequate background in biology from a psychological perspective. Ultimately, I found that the 10 credits I earned as part of this consortium was completely useless in preparing me for further higher education in the field of psychology. If we are not careful, encouraging a partnership between different but related groups could yield the same effect, especially as the professional areas covered by HSP are vastly different themselves and require very specialized training.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Amy	Balmanno	California Association of School Psychologists	In California, the CTC requires that "A program of study for the school psychologist specialization shall be: Equivalent to a minimum of 60 semester units or 90 quarter units; or 900 classroom hours of postgraduate study." In addition to coursework, candidates must also complete 450 hours of supervised practicum with school-aged children; 300 of those hours must be completed within a preschool-grade 12 setting. Finally, candidates must also complete 1200 hours of supervised internship; 1000 of those hours must be completed within a preschool-grade 12 setting. We recommend that HSP programs preparing for the practice of school psychology require the same as our credentialing body, or graduates in CA will not meet eligibility requirements for the credential and ultimately will not be able to practice.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Jackie	Tyson	Board of Educational Affairs	3. There are several places throughout where we believe further clarification is important to understanding the intent of particular standards. For example: a. Standard I.C.2.a. Given the variability in master’s programs, it would be helpful if the Commission indicated a minimum number of graduate credit hours that would be consistent with the equivalent of two full-time academic years of graduate-level study, as “two years” may be interpreted in different ways.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Dawson	Betty		The standards outlined in this Draft would not meet the requirements for licensure in Texas and are below the standards of those university Masters in Psychology programs which lead to licensure.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Dawson	Betty		“Two full academic years” does not indicate the number of hours or courses required. It does not indicate if most of the classes must be from one structured academic program or if this includes a practicum. There should be more specificity in setting this standard.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Erika	Olinger	Oklahoma School Psychological Association	Section I, C.2 The 2-year requirement is inconsistent with the NASP Standards for Graduate Preparation of School Psychologists (2020), which specifies the standard for entry into the field. For HSP programs specific to the practice of School Psychology, a minimum of 60 graduate semester hours should be specified.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Julene	Robbins	Arizona Association of School Psychologists	Arizona Association of School Psychologists: This proposed degree requirement is significantly below the established training standard for school psychologists. This is a significant concern for the field of school psychology because implementation of this training standard would potentially lower the quality of school psychology services to children and adolescents. The entry level standard for school psychology practice is specialist-level training, which requires a minimum of 60 hours at the graduate level. This contrasts with a typical master's level training program requirement of 30 credit hours. Arizona Department of Education Requirements: A-1 Master's or more advanced degree from an accredited institution. Official transcripts required. A-2 One of the following: Completion of a graduate program in school psychology, consisting of at least 60 graduate semester hours OR Completion of a doctoral program in psychology and completion of a re-training program in scho...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Emily	Klein	Delaware Association of School Psychologists	The Delaware Association of School Psychologists (DASP) wishes to thank the Commission on Accreditation (CoA) for all its thoughtful and hard work on behalf of the education and training of professional psychologists who deliver health service psychological services. We appreciate the CoA’s efforts to address the shortage of mental health professionals by considering accreditation of non-doctoral level programs. With all due respect to the high level of professionalism and the hard work evident in the CoA’s draft standards and processes for accrediting Masters’ degree programs in Health Service Psychology, DASP wishes to submit the following comments/recommendations for consideration. All of these comments/recommendations are specific to the School Psychology branch of Health Services Psychology, in keeping with our area of expertise. DASP is concerned that the minimum program length of 2 full-time academic years of graduate study, with 1 of those years consisting of a 1-year full t...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Jim	Deni	North Carolina School Psychology Association (NCSPA)	The M-HSP should require a minimum of 60 graduate semester hours in the specific area of school psychology to align with NASP professional standards approved in 2020 which should include a practicum sequence in a school setting and a minimum of a 1200 hour internship. Thus, the M-HSP should have a minimum of three years of study which would in include practicum and internship requirement consistent with the 2020 NASP Professional Standards. Another concern is only requiring one year of residency of the required two years of full time training. This will likely lead the 1st year of academic training being delivered online with the remaining year of training face to face at the institution of higher learning granting the degree.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Stephanie	Barbre	Texas Association of School Psychologists	School psychologists must obtain a minimum of 60 graduate semester hours in coursework outlined in the NASP Standards for Graduate Preparation of School Psychologists. As mental health professionals with specialist-level training, we possess the expertise, competency, and skill set necessary to provide comprehensive services to students, families, and schools. Further, our state credentialing standards for licensure to practice school psychology align with the NASP Standards for Graduate Preparation of School Psychologists, and therefore individuals with less than 60 graduate semester hours would be ineligible to apply for licensure. We recommend upholding the specialist-level training required as the standard entry to practice school psychology.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Laura	Quinn	Laura Quinn and Thomas J. Thompson	My husband and I are combining our efforts with our feedback regarding the proposed Standards of Accreditation in Health Service Psychology. We have successfully practiced psychology in North Carolina for 70+ years combined. I as a Licensed Psychological Associate, and my husband as a Licensed Psychologist. We have both practiced primarily in the area of developmental disabilities and behavior analysis throughout that time. In addition, Tom served on our state psychology board for 9 years, serving as chair for 3 of those years. We are heartened to see the attention that APA is giving to Master’s level psychologists’ training. However, we are concerned that the Standards should enable the independent practice of Psychology by well-trained Master’s level providers in all states, as has successfully been the case in North Carolina for nearly 40 years. APA’s previous position against the independent practice of Psychology by Master’s level practitioners seems to us foolhardy in the cha...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Mary	Satchwell	Illinois School Psychologists Association	I. C.1.a - Program Context and Resources: Program Leadership The Illinois School Psychologists Association (ISPA) is made up of practitioners, students, and university trainers in the field of School Psychology and advocates for the best interests of students as well as the field of school psychology in our state. While we acknowledge there is a critical shortage of school mental health professionals in our state and across the nation, we do not support changes to credentialing that result in graduates who are inadequately prepared to work in school systems. Because of the unique nature of the education system including the variety of types of schools, school systems, laws and policies, it is essential that school psychologists are trained and led by other school psychologists who have appropriate knowledge and background to instruct appropriately within this unique arena. It appears in this proposal that individuals with clinical or counseling degrees could lead a school psychol...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Mary	Satchwell	Illinois School Psychologists Association	I.C.2. - Program Context and Resources: Program: Length of Degree, Delivery Method, and Design ISPA opposes a reduction in the requirements for entry into the profession of school psychology and strongly encourages specialist level training requirements that align with the National Association of School Psychologists (NASP) model for training and practice; including the standard minimum of 60 graduate semester hours and 1200 hours of supervised internship training (with a minimum of 600 hours in a school setting) prior to entry into the field. Prospective students in the field, stakeholders and parents, state licensing/credentialing bodies, and potential employers could be faced with three different tiers of School Psychologists with Master’s from new HSP programs, Specialist Level trained graduates as is currently the norm throughout the country adhering to existing NASP standards, and Doctoral graduates that are currently following either NASP or APA standards (or a combination ...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Samuel	Song	Council of Directors of School Psychology Programs (CDSPP)	I.C.2.b. There is a wide variability across masters degrees ranging from one-year to three-year degrees (e.g., MSWs and Ed.S. in School Psychology). While the two-year requirement is useful, it may be more clear to indicate a minimum number of graduate credit hours that would be consistent with the equivalent of two full-time academic years of graduate-level study.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Jessica	Carranza	Montana Association of School Psychologists (MASP)	C.1.a - Program Context and Resources: Program Leadership MASP recommends that the standards specify that program leadership should be provided by faculty with training, experience and a state/national credential in the area of specialty. C.2 - Program Context and Resources: Length of Degree, Delivery Method, and Design The Standards, as currently written, are severely discrepant from NASP Standards, on which many state credentialing/licensure standards are predicated. Those HSP programs that are accredited for the preparation of graduate students in the area of school psychology should require a minimum of 60 graduate semester hours in the specialty area of school psychology to align with NASP’s 2020 professional standards. This level of training is critical for adequately preparing individuals to provide a broad range of services, consistent with the NASP Practice Model. A lower standard of training and preparation, such as that outlined in the draft standards, does not provide...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Michelle	Krieger	APAGS	We support the passage of the SoA. At the same time, we believe it can be strengthened with the following revisions: ? On page 4 (C, 2. Length of Degree, Delivery Method, and Design),“fulfil” should be amended to “fulfill” ? Regarding this same section (C 2), We acknowledge that this document was written prior to the COVID-19 pandemic, which has greatly impacted requirements around residency. We respectfully suggest that further consideration may be needed regarding residency requirements and provision of online training, including how programs can meet training standards given uncertainty during the pandemic and beyond. We believe a statement on remote supervision, remote learning, and obtaining clinical hours that meet requirements for licensure would be important to include here for current and future preparedness based on the fluidity of the situation and as a result, the changing recommendations. ? On page 4 (C4. Resources): It may be helpful to consider what additional resour...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Debra	Freburg		Section I,C.2 As a practicing school psychologist for over 35 years, I see this standard as inconsistent with training standards recommended by NASP for entry into the field of school psychology. NASP standards require a minimum of 60 semester hours of graduate training prior to internship. State licensure often requires that 60 hour minimum.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Jessica	Mefford	Kansas Association of School Psychologist	The Kansas Association of School Psychologists (KASP) has reviewed the standards for accreditation of Master’s level Health Service Psychologists (HSP) as it relates to the training of potential School Psychologists and HSPs who seek to work in school settings. School psychology training programs in Kansas follow NASP Standards for training. Kansas Department of Education (KSDE) standards for training closely align with NASP Standards for credentialing of school psychologists, and are undergoing revisions beginning this month to align with NASP 2020 Standards. Of concern is that the HSP proposal is deficient in requirements for accreditation - as proposed, with 2 years of graduate level coursework inclusive of one year of full-time residency within the degree granting program, there is no standard to indicate what coursework would suffice. Such a plan could cause harm in Kansas, as it does not align with NASP standards requiring specialist-level training with a minimum of 60 graduate c...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	June	Preast	University of Alabama, School Psychology Program	HSP programs preparing for practice in school psychology should require a minimum of 60 graduate semester hours in the specialty area of school psychology to align with NASP’s professional standards.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	UMMP	Board	Group	C.2: Length of Degree, Delivery Method, and Design The inclusion of part-time, distributed, and online programs cited above is positive. UMMP hopes, that in practice, there will be strong consideration for these programs as a one-year residency requirement is not always feasible. (For example, those working and going to school). Flexibility in this area will expand opportunity and access for talented individuals from diverse backgrounds to enter into the profession of psychology. UMMP favors in-person programs. In light of current events with COVID-19 and what likely will be a long-term impact on learning and service provision, the profession should be flexible to evolve in appropriate ways to determine and integrate online instruction. Online instruction can enhance competency and training by access to otherwise unavailable instructors and instruction content. C.2: “Full- time” residency and “full-time” graduate study are not defined in either hours or graduate credit hours. Exclu...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Rhonda	Remsen		As a practicing school psychologist with a specialist level degree (Ed.S.)I believe that the wording in #2 is inconsistent with the National Association of School Psychologists (NASP) accreditation standards requiring a minimum of 60 graduate credits. I received my degree in 1991 which shows the historical perspective of the high standards that have been recommended for the field of school psychology. HSP programs preparing for practice in school psychology should require a minimum of 60 graduate semester hours in the specialty area of school psychology to align with NASP’s professional standards.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Shawna	Kelly		C.i.a. - The standards should include guidance around appropriate faculty. Specifically program leadership and program faculty should be trained, credentialed and have experience in the specific specialty area.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Shawna	Kelly		C.2. - As currently written, the standards are significantly lower than those required for practice in the field of school psychology. While I defer to experts in the field of clinical and counseling psychology as to the requirements for sufficient training to practice in those areas, standards for practice in school psychology clearly indicate that the minimum entry for practice in schools should be at the specialist level or equivalent. This should be articulated clearly in requirements for semester hours, specifically a minimum of 60 graduate credit hour. Failure to acknowledge the specialist level as the minimum criteria for entry into the field of school psychology suggests that there is a lack of knowledge, awareness, or recognition of the the requirements for training in the field.
SoA for Masters Degree	I. Institutional and Program Context	C. Program Context and Resources	Mallory	Hart	Kentucky Association for Psychology in the Schools	Section I, C.2 Based on the nature and degree of specialization required to practice competently in the field of school psychology, the NASP Standards, requiring a minimum of 60 graduate semester hours in the area of school psychology, is requested. This too, aligns with the certification requirements in Kentucky’s Education Professional Standards Board through which the majority of Kentucky school psychologists will be credentialed.
SoA for Masters Degree	I. Institutional and Program Context	D. Program Policies and Procedures	John	Garruto	New York Association of School Psychologists	D.2 - Program Policies and Procedures: Implementation NYASP recommends that “ethics codes” reference discipline-specific ethical principles. It would be more appropriate to state the following: All policies and procedures used by the program must be consistent with the profession’s ethics code, as well as the HSP specialty area’s current ethics code (e.g., Principles for Professional Ethics, NASP 2020)
SoA for Masters Degree	I. Institutional and Program Context	D. Program Policies and Procedures	Kelley	Fillion		D.2 - It is recommended that “ethics codes” also reference discipline-specific ethical principles. It would be more appropriate to state the following: All policies and procedures used by the program must be consistent with the profession’s ethics code, as well as the HSP specialty area’s current ethics code. Note that the NASP 2020 Standards, effective July 1, include Principles for Professional Ethics, which define the ethical standards for school psychologists.
SoA for Masters Degree	I. Institutional and Program Context	D. Program Policies and Procedures	Holly	Yoke	West Virginia School Psychologists	D.2. Program Policies and Procedures: Implementation: WVSPA believes that when referencing the profession’s code of ethics, it is specified that professionals follow the specialty area’s current ethics code.
SoA for Masters Degree	I. Institutional and Program Context	D. Program Policies and Procedures	Kimberly	Daniel		I appreciate the opportunity to comment on this matter. As you know, the National Association of School Psychologists (NASP) has delineated a comprehensive framework for training and credentialing school psychologists. School psychology programs which have been approved by the NASP Program Accreditation Board (or aspire to be approved), have worked tirelessly to secure and maintain this recognition. As a 16-year full-time practitioner coupled with an additional 15 years as a trainer of school psychology candidates, I have found that NASP standards for training and practice have provided a strong foundation for preparing and credentialing early career school psychologists. Candidates in NASP approved programs must take sixty (60) credit hours minimum of course work; must matriculate in a three (3) year graduate program, must complete field practicum experiences and a 1200 clock hour internship. Our specialist level graduates typically secure master’s or post-master’s training, depen...	See Full Comment
SoA for Masters Degree	I. Institutional and Program Context	D. Program Policies and Procedures	Kristen	DeYorio		I agree with and support the proposed Program Policies and Procedures.
SoA for Masters Degree	I. Institutional and Program Context	D. Program Policies and Procedures	Amy	Balmanno	California Association of School Psychologists	With regard to ethics, it is commonly held that there are discipline-specific ethical principles. We suggest wording to reflect that program policies and procedures are consistent with the profession's ethics code, as well as the specialty area's current ethics code. For example, the CASP and NASP codes of ethics include Principles for Professional Ethics, which define ethical standards for school psychologists.
SoA for Masters Degree	I. Institutional and Program Context	D. Program Policies and Procedures	Michelle	Krieger	APAGS	? In addition to nondiscrimination policies (page 5, D. Program Policies and Procedures -1G), consider adding a statement regarding the importance of policies that promote diversity and inclusion, including a greater emphasis on, and accountability processes for, recruiting people of color. It would be helpful to highlight some specific actions that demonstrate understanding of cultural and individual diversity. For example, does this include having seminars on diversity, all gender restrooms, inclusive language, ongoing training on cultural diversity for staff? We support the mention of nondiscrimination, but believe it would strengthen this document to specify what programs should be doing to cultivate respect for diversity and in particular, specify that programs need to build in ways to be accountable.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Amy	Cannava		Program-Specific Competencies and Related Curriculum should be defined. As the HSP credential would accredit non-doctoral level programs in school psychology, clinical psychology, counseling psychology, which are vastly different professions, there should be defined differences for each program in the "Program-Specific Competencies."
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Amy	Cannava		As clearly indicated in the National Association of School Psychologists' publication (National Association of School Psychologists. (2019). NASP Response to Master’s-Level Accreditation in Health Service Psychology [Task force report]. Bethesda, MD: Author.), APA recognizes the unmet mental health needs of communities and the increasing need for mental health practitioners. That said, there is a shortage of school psychologists nationwide. There should be clarity in that a school should be able to award both the School Psychology graduate degree and HSP simultaneously if students meet both program and credentialing requirements. Those set forth by these standards clearly align with the NASP "Standards for Graduate Preparation of School Psychologists." If accepted, graduates from NASP accredited universities should be able to practice within schools and in private practice if state licensuring boards accept masters' level clinicians to practice independently.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Donald	Mott		It is extremely important that any Masters programs for psychology students include consideration of licensing standards at the Masters level in the various States. These standards tend to be less uniform than those for Doctoral level psychologists and in some cases students may obtain a Masters degree that does not allow them to become licensed as a psychologist, psychological associate, or similar credential. I suggest that the proposed standards include an explicit statement that students should have access to up-to-date information about licensing standards at the Masters level, and that programs should provide guidance to them in this area.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Carol	Williams	North Carolina Association of Professional Psychologists	For any program to be credible, it should meet observable, measurable standards for success. This includes setting a realistic expectation for the rate of “success” by its graduates, by measuring the rate of their licensure, certification, and employment. A program which does not meet even a minimum standard should attempt to determine the cause. It would be unfair to future students not to disclose the rate of “success” in the program’s communications. As required in Section V. A. 2. b., program is expected to “describe accurately and completely in documents that are available to current students, prospective students, and other publics. This information should be presented in a manner that allows applicants to make informed decisions about entering the program.” How does this draft SoA meet this expectation?
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Carol	Williams	North Carolina Association of Professional Psychologists	Psychology consistently and continually has been losing ground to our allied fields (e.g. counseling, licensed clinical social workers, etc) to the detriment of the people who need our care. Overall, there is a shortage of psychological services, which adversely affects those in need. In NC alone, there are 20% of the counties where mastered-degreed psychologists are the ONLY psychologists available. How does this effort expand psychological services and benefit those who need services, in particular, how does the SoA better prepare graduates to become master’s credentialed practioners? Only in the behavioral health area of psychology, do we find, via the APA, attempts to suppress, marginalize, and block access to care from master’s- degreed practioners. This increases the divide between master’s and doctoral psychologists and reduces the numbers of psychologists coming together to grow and strengthen the field, and does not best serve the public. This leads to the issue of title....	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Carol	Williams	North Carolina Association of Professional Psychologists	NCAPP response: We, the board members of the North Carolina Association of Professional Psychologists (NCAPP), have reviewed the draft Standards of Accreditation (SoA)in Health Service Psychology – Master’s, and appreciate the opportunity to comment. We are interested in this effort hoping that this would be a signal that the American Psychological Association’s (APA) recognizes the important contributions of master’s degreed psychological professionals and practioners. Unfortunately, this draft SoA does not seem to account for the required coursework, competencies, and standards necessary for licensure in states where master’s degreed psychologists practice. There are numerous concerns with this SoA with regard to content, expectations, and perhaps most importantly, intent. Some of those concerns are contained in the following comments and questions: Type of Program: Health Service Psychology. Does this draft SoA support Independent Practice for master’s degreed professionals? ...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Kristen	DeYorio		I question the ability of any program to adequately prepare for three separate, and very different, fields of psychology with such a vague description of the Aims of the Program. School Psychology, for example, requires very specific knowledge in statistics, educational law, assessment implementation, and academic curriculum and intervention. Working within education is very different than working in clinical or counseling fields. Unless programs are tailoring their curriculum specifically toward each of these three areas within HSP, none of the students attending these programs will be adequately prepared for their chose profession.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Jim	Deni		Entry-level school psychologists in North Carolina are licensed at the specialist-level or doctoral level and must pass the Praxis Examination in School Psychology. In North Carolina, we have five school psychology training programs (Appalachian State University, East Carolina University, Western Carolina University, North Carolina State University, and the University of North Carolina at Chapel Hill). All five programs are NASP approved or a combination of APA and NASP approved. Our workforce of over 800 school psychologists includes both doctoral and specialist-level who hold degrees in School Psychology. NASP maintains that the specialist-level degree in school psychology represents the entry-level degree to work as a school psychologist in the United States. NCSPA concurs with NASP that those providing school psychological services in schools should meet the credentialing requirement to work as a school psychologist by the appropriate state credentialing agency, and they should use...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Janet	Larsen		I am writing these comments to the American Psychological Association (APA) because I am encouraged that the APA is looking to create an accreditation process for clinical psychology/health service provider master’s programs. While this is a positive step, it is my belief that this is long overdue, and this should be acknowledged and validated in the process of developing this accreditation. Between doctoral and master’s-level psychologists there is much healing that needs to be done in our field. There is a great divide that the APA has fostered, and currently, I do not see how this is being directly acknowledged and sufficiently addressed. For this reason, I have some reservations as the APA moves forward with an accreditation process: Is the APA attempting to restrict our practice? Turn us into assistants to doctorates? Strip us of the title psychologist and/or assign us a demeaning title such as associate or assistant? Do they welcome master’s practitioners into the family of psych...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Freeman	Kurt		This section (like most of the proposed standards) appears to be almost (if not 100%) verbatim from the doctoral SoA. The rationale for expecting the same breadth and depth of coverage in DSK and PWC in a master's program is not articulated. This highlights my general impression that the CoA is simply placing Doctoral-level standards onto master's level training without a clear articulation of a) why this move toward accrediting master's programs and b) how it is differentiating between master's and doctoral level training.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Tammy	McClain		I would strongly encourage you to review the training competencies suggested by Cooper, L.D. et al. (2020). "Training Competencies for Master's Programs in Health Service Psychology." Unpublished manuscript. contact ldcooper@vt.edu. They simplified the competencies to include scientific foundations, common factors, assessment, intervention, and professional values.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Alan	Burkard		The DSKs and PWCs are essentially the same as the doctoral program standards. There is no acknowledgment of the developmental level of students (i.e., master’s vs. doctoral) and what might be appropriate for master’s level practitioners. Also, what happens if this master’s degree is a terminal degree and the student decides to practice at the master’s level? For our current master’s program, this would be the majority of graduating students (likely about 95%). Based on these standards, no graduate would meet current state requirements for master’s level licensing. It seems prudent to create a set of standards that are actually relevant to how master’s graduates practice and that meet current state licensing requirements. Otherwise, you are creating an irrelevant set of standards. Finally, these standards do not address the range of potential practice areas at the master’s level. For instance, the current DSKs and PWCs have no relevance to School Counseling, which is a terminal area...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Lee	Cooper	Association for Behavioral and Cognitive Therapies	We are glad that DSKs related to core knowledge of psychology (Section II.B.1.a.i, DSK-Category 1) is a standard and there is flexibility for the standard at the undergraduate or graduate level. We recommend that the SoAs underscore that basic science concepts should inform application or practice, especially on the part of master’s programs providing this educational component. As noted above, the DSK-Category 2 standard (Section II.B.1.a.i) gives programs the option to fulfill this standard at the undergraduate level, which we believe provides necessary flexibility for training programs. However, we are concerned how training programs will address the Affective component, especially given that abnormal/psychopathology courses are excluded from fulfilling the requirement. Our concern stems from our understanding that this may be an additional burden for training programs that already have to adhere to state-mandated courses, which may hinder adoption of the SoAs. Those of us who ar...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jason	Washburn	Council of University Directors of Clinical Psychology	The CUDCP Board agrees that Discipline Specific Knowledge (DSK) represents the "requisite core knowledge of psychology". Further, the CUDCP Board supports the inclusion of undergraduate acquisition of Category 1 DSK for Master’s level HSP programs. The CUDCP Board is unclear, however, as to the rationale for requiring graduate-level Category 2 DSK (Standard IIB1aii), given that these programs are intended to prepare students for clinical practice (IA1b). The CUDCP Board believes that graduate-level Category 2 DSK is only relevant for Master’s level HSP programs when it is directly applicable to clinical practice. For example, the standards should support development of critical thinking skills, the ability to evaluate research-based claims, knowledge of test validity and reliability, and skills for analyzing clinical outcome data.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jason	Washburn	Council of University Directors of Clinical Psychology	The CUDCP Board agrees that Master’s level HSP practitioners should develop Profession Wide Competencies; however, the proposed standards fail to delineate the scope of practice for psychological assessment (Standard IIB1bvi) and psychological intervention (Standard IIB1bvii). Although it is possible that the CoA plans to address the scope of practice for Master’s level HSP practitioners in future Implementing Regulations, CoA should consider the utility of including some scope of practice into the Standards.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Adams	Kimbelry		Please provide additional discussion of what an "appropriately trained and credentialed" individual means. I also strongly support a year of supervised internship prior to licensing. As a school psychologist and a former Director of Special Education, I have hired interns into full school psychology positions. It was NOT good for either the school, students, staff, or the school psychologist. Students need a year of supervised internship allows students to put their learning into practice under the watchful eye of a credentialed school psychologist. It is critical that this experience, through the cycle of an entire school year, is critical for a student's development prior to independent practice.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Brandi	Duskie		As a school psychologist, there are a few areas regarding accreditation of Masters level HSP. I've indicated my concerns below: Section I, C.2. regarding length of degree - The length of 2 full years, with one of those in the area of specialty is inconsistent with current NASP Standards regarding. HSP programs for School Psychology should require a minimum of 60 graduate credit hours in the area of School Psychology to align with NASP Standards.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Brandi	Duskie		As a school psychologist, there are a few areas regarding accreditation of Masters level HSP. I've indicated my concerns below: Section II, B.3.a and B.3.c regarding Required Clinical Training Elements Concerns with (a) are in regard to the supervision as NASP Standards require a minimum of 1200 hours of supervision during internship with 600 of those hours in a school setting and this specific distinction is left out of the HSP language. Direct experience and supervision in a school environment is paramount to effective training for school psychologists, including HSP in school psychology. Concerns with (c) are in regard to more clarification regarding those "appropriately trained and credentialed" to provide supervision to these interns. NASP Standards has specific clarification of the training and skills necessary to provide that supervision for effective training of interns.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Kari	Oyen		It is critical to provide comprehensive discipline-specific knowledge to be able to engage in psychological practices. This seems unreasonable to obtain in a two-year master's program. These competencies, at a minimum, would need a specialist-level program of study. It is also important to note that the competencies that are highlighted in these standards highlight much of the intervention and pathology-based competencies without regard to prevention and systems-based prevention programming. Supervision should also require special coursework that highlights specific guidelines of practice (including what levels of practice are acceptable with this level of training).
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Sterling	Stauffer		I think more clarification needs to be provided regarding the supervision provided by "appropriately trained and credentialed individuals." For example, in my training program for school psychology, I was required to be supervised by a licensed school psychologist as the work done in schools by a school psychologist may be very different from work done by a clinical or other psychologist in other settings. I think the individual supervising needs to be specifically trained and credentialed to supervise in that area of practice. The National Association of School Psychologists has specific requirements for supervisors that could serve as an example. I am concerned that it will be very easy for someone to say that they are appropriately trained and credentialed, when that may not actually be the case for the specific application of the practitioner.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Kari	Oyen		Regarding "Required Clinical Training Elements", these standards are entirely too vague. As a trainer of School Psychology as well as a Licensed Psychologist, I am concerned about the lack of specificity and minimum standards for internships. For the practice of school psychology, the minimum standard is a 1,200 hour internship with at least 600 hours of that time in a school setting. It should be explicitly stated that HSP programs cannot endorse a school psychology entry level degree without both a specialist level of training as well as the aformentioned internship level requirements. It would also be helpful to have the minimum internship competencies highlighted on these standards to note that licensure in the practice of School Psychology is not possible without meeting the NASP Graduate Education standards.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Liliana	Lengua		I have several concerns with the Standards as currently formulated. The first set of concerns have to do with Categories 1 and 2 of the Discipline-Specific Knowledge (DSK) competencies: 1. Including eight DSK competencies as separate courses will make it difficult for students to learn how to integrate empirical evidence into practice: I recognize the value of coursework in affective, cognitive, biological, social and developmental bases of behavior. I also believe strongly that these DSK competencies should be integrated into coursework on assessment, treatment and psychopathology and reject the idea that we need individual courses that cover each topic separately. Having topics on affective, cognitive, biological, social and developmental bases of behavior woven into clinical coursework will maintain the applied focus of the program, and train clinicians in how to integrate empirical evidence into practice so that these skills are maintained far into their clinical careers. ...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Lynn	Fainsilber Katz		I have several concerns with the Standards as currently formulated having to do with Categories 1 and 2 of the Discipline-Specific Knowledge (DSK) competencies: 1. Including eight DSK competencies as separate courses will make it difficult for students to learn how to integrate empirical evidence into practice: I recognize the value of coursework in affective, cognitive, biological, social and developmental bases of behavior. I also believe strongly that these DSK competencies should be integrated into coursework on assessment, treatment and psychopathology and reject the idea that we need individual courses that cover each topic separately. Having topics on affective, cognitive, biological, social and developmental bases of behavior woven into clinical coursework will maintain the applied focus of the program, and train clinicians in how to integrate empirical evidence into practice so that these skills are maintained far into their clinical careers. 2. Including eight DSK...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Greg	Machek		Those familiar with APA accreditation of doctoral training programs will find this familiar, perhaps too familiar, which raises the issue of how MA and doctoral programs will be distinct from one another given the large overlap in curricular/learning elements. A related issue is whether an MA program will be able to successfully cover all proposed content areas and still have enough room and time to teach discipline-specific applied skills. Finally, the robust coverage of stats/inquiry/psychometrics may be to broad for students who need to be good consumers of research but who likely will not do actual research.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Shawna	Rader Kelly	National Association of School Psychologists	B.1.a.i - Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession: Discipline Specific Knowledge It is unclear which “Discipline-specific knowledge representing the requisite core knowledge of psychology” can be accomplished at the undergraduate and graduate level. Greater clarity is needed; this seems predicated on the assumption that students entering graduate preparation programs have a background in psychology. If expected of undergraduate training, individuals coming from non-psychology backgrounds (e.g., education) will be at a disadvantage in meeting HSP discipline-specific knowledge requirements if not already embedded in graduate coursework.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Shawna	Rader Kelly	National Association of School Psychologists	B.1.b Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession: Profession wide competencies The area of “Prevention Strategies” is glaringly missing. We suggest consideration of “prevention and intervention” as a single area of competency. Supervision should be treated as a profession wide competency addressed in the curriculum. This would require distinct coursework and opportunities for practice with meta-supervision.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Shawna	Rader Kelly	National Association of School Psychologists	B.3.a Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession: Required Clinical Training Elements It is unclear why the proposal avoids any official term of “practicum” or “internship” and instead refers vaguely to “supervised field experiences.” Practica and internships are an established practice for all areas of graduate preparation in psychology and have specific and distinct meanings within graduate programs. Additionally, this section should include mention of the role of the university program in these supervised field experiences. Specific competencies should ensure acquisition of competencies aligned with that of the appropriate specialty area (i.e., school, clinical, counseling). HSP programs preparing for practice in school psychology should require a minimum of a 1200-hour internship in the specialty area of school psychology, with a minimum of 600 hours in a school setting. Direct experience in a school...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Shawna	Rader Kelly	National Association of School Psychologists	B.3.c - Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession: Supervision Greater clarity is needed for what constitutes supervision provided by “appropriately trained and credentialed” individuals. We recommend that supervision is provided by individuals with relevant training and appropriate credentials for the settings in which supervision is provided.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Megan	Vinco		I have concerns related to the inclusion of school psychology practice in the HSP master’s degree. NASP maintains the specialist-level degree as entry level to school psychology work. With this, school psychologists have extensive training, including broad psychology competencies and school- and systems-based competencies related to the specialty of school psychology, achieved with a minimum of 60 semester hours and a full year internship. The proposed HSP standards do not align with the recommended level of training for school psychology practice. Establishing a less rigorous, less specialized route to school psychology practice may pose risks for potential graduate students determining career paths when entry-level expectations for practice may exceed their scope of training, confusion among administrators employing school psychologists, and damaged public perception of “psychologists” if the public is served by individuals with less training than is recommended for the domain of pra...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	John	Garruto	New York Association of School Psychologists	B.3.a Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning Curriculum Events Required by the Profession: Required Clinical Training Elements Health Service Psychology programs preparing for practice in school psychology should require a minimum of a 1200-hour internship in the specialty area of school psychology, with a minimum of 600 hours in a school setting to align with national standards. Direct experience in a school setting remains paramount to effective preparation in school psychology. New York State requires an internship in a “school setting under the supervision of a regionally accredited college or university having an approved program of preparation for the certificate in question.” Therefore, the role of the university program needs to be identified. B.3.c - Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession: Supervision Greater clarity is needed for what constitutes supe...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Peggy	Brady-Amoon	Alliance for Professional Counselors	II – Aims, Competencies, Curriculum, and Outcomes B.3. APC recommends expanding the requirement that clinical training include supervised experience providing direct services to people with “a variety of presenting problems, diagnoses, and issues” to include (and acknowledge) counseling and counseling psychology’s focus on human strengths and typical life development.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Suzanne	Botana		Please add a definition of “appropriately trained and credentialed” individuals. This supervision should be provided by individuals with relevant training and appropriate credentials for the settings in which supervision is provided. For example- specifically in a school, the supervision is provided by a graduate from a NASP or APA approved program in School Psychology. Suzanne Botana Ph.D.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Patsy	Brock		3. a. It is critical that training include intensive experiences in a school setting. NASP requires a minimum of 1200 hour internship in a school setting. This direct experience is imperative to prepare students for school-based services.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Patsy	Brock		3. c. Supervision needs to be defined and should be specified as specialist serving in the field of school psychology. Clinical and school practices are different. Students need to be aware of these differences and supervised by appropriate personnel.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Laura	Spenceley		I thank APA Commission on Accreditation (CoA) for the opportunity to review and provide comment on the proposed accreditation for Master’s degree programs in health service psychology (HSP). I have significant concerns that the proposal fails to recognize the well-established minimum standards for training in the field of school psychology, which include 60+ graduate credit hours of coursework across the ten (10) domains of practice consistent with the National Association of School Psychologists' practice model. Most concerning is the complete omission of training regarding educational systems, the provision of mental and behavioral health care in schools, and the importance of equitable academic interventions across tiers. By introducing a degree that would reduce the training of mental and behavioral healthcare providers in schools, we may inhibit rather than promote best practices in the field and prevent students from accessing care from the highly trained professionals that a...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Kelley	Fillion		B.1.a.i - It is unclear which “Discipline-specific knowledge representing the requisite core knowledge of psychology” can be accomplished at the undergraduate and graduate level. Greater clarity is needed. B.1.b - Prevention Strategies is an area that is missing. B.3.a - Why are the words “practicum” or “internship” and not used? Practica and internships are an established practice for all areas of graduate preparation in psychology and have specific and distinct meanings within graduate programs. HSP programs preparing for practice in school psychology should require a minimum of a 1200-hour internship in the specialty area of school psychology, with a minimum of 600 hours in a school setting. Direct experience in a school setting remains paramount to effective preparation in school psychology. B.3.c - “Appropriately trained and credentialed” individuals needs to be clarified. We recommend that supervision is provided by individuals with relevant training and appropriate c...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	David	Lillenstein	Association of School Psychologists of Pennsylvania & The Pennsylvania Psychological Association	Together, the Association of School Psychologists of Pennsylvania and the Pennsylvania Psychological Association support the current NASP requirement of a minimum of 1200 hours for internship. ASPP and PPA also support the current requirement that school psychology internships consist of a minimum of 600 hours in a school setting, which is essential to ensuring adequate training and preparation. All school psychology training programs in Pennsylvania currently adhere to these standards for internship. In Pennsylvania, school psychology interns must be supervised by a certified school psychologist with at least 5 years of experience in the field which helps to ensure quality control and protect the public. ASPP and PPA view the current requirement that school psychology trainees obtain direct instruction and a comprehensive supervised clinical experience in a school setting as essential to the training and preparation of competent school psychologists. The proposed HSP standards do not...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	David	Lillenstein	Association of School Psychologists of Pennsylvania & The Pennsylvania Psychological Association	Together, the Association of School Psychologists of Pennsylvania (ASPP) and the Pennsylvania Psychological Association (PPA) agree that the current wording in the APA draft document regarding required clinical training elements is vague and needs to be clarified. Specifically, who is “appropriately trained and credentialed,” and what training and credentials are required of a supervisor? ASPP and PPA strongly support the requirement in Pennsylvania Department of Education Regulations and the NASP Standards that certification to become a credentialed school psychologist requires supervision by a certified school psychologist who also has at least 5 years of experience in the field of school psychology. ASPP and PPA agree with the Pennsylvania Department of Education Regulations and NASP Standards that it should be a requirement that supervision be provided by a supervisor who has school psychology experience AND school psychologist certification. Hence, students completing HSP ...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Brian	McKevitt	Nebraska School Psychologists Association	We agree that clinical experience is critical. However, we urge you to consider recommending a minimum number of hours for that experience, particularly for HSP programs in school psychology. In Nebraska, our state certification requirements indicate a 1200 hour internship is mandatory, with at least 600 hours in a school setting required for certification as a school psychologist. If this minimum is not stated, we are concerned that HSP programs in school psychology could graduate students who have not had sufficient school-based experience, and therefore would not be eligible for certification. Examples of practice areas that can only be developed through school based internship experiences include teacher consultation, development and evaluation of academic and behavioral prevention and intervention programs, school culture and systems including MTSS, and the application of special education law during student evaluation and IEP development. Individuals not specifically trained to d...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Brandon	Wilks		As someone who provides supervision to school psychology students that are still training or recent graduates that are new to the field, I am concerned about the lack of clarification of externship and internship hours. The practice of school psychology is very nuanced and usually requires many hours of practice before state certification to build experience. Post-certification in my state (Louisiana) typically leads to school psychologists being viewed as experts in how to lead academic and behavioral interventions in school settings with mental health knowledge used in best practices. I am worried that the length of study proposed by the 2 years master's degree would, with no mention of specified externship or internship hours within a school setting, lead to underprepared individuals to work as school psychologists in a school setting.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Ashley	Arnold		The appropriate internship for school psychology graduate students is a minimum of 1,200 hours, 600 of which must be completed in a school setting. Parameters for school psychology must include the NASP Standards for Graduate Preparation of School Psychologists. School psychologists have numerous ethical, federal legislation, state rules and regulations to follow and abide by that masters level clinicians do not have to balance to complete their job.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jana	Aupperlee		•The curriculum, as outlined, seems to assume everyone enters the program with a Bachelor’s degree in psychology. I worry that students with other educational backgrounds will not have the requisite knowledge to succeed. •The standards for research methods seem too high for a two year degree or even a three year degree. I’m not sure psychologists need to produce research so much as be critical consumers and disseminators of research. •The PWCs are extremely focused on psychopathology, which is totally contrary to the prevention approach used in school psychology. In addition, education is strengths and skills-based, not deficit-centered. The pathology emphasis is inappropriate for school psychology and education. In fact, prevention is totally neglected in the PWCs.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Dickinson	Emma	Nevada Association of School Psychologists	In response to section B, 3a: The clinical training specified does not include specifics for specialist-level internship of a minimum 1200 full time hours, and 600 hours of which require in-school experience. If programs fall short of this standard, it would detract highly from well-trained and experienced individuals with the title of School Psychologist entering the field. It is imperative that School Psychologists receive supervised internship training within the context of which they will be working. We are concerned that there is little specification in your proposal (section B, 3C) of what constitutes appropriately credentialed individuals who will provide supervision. It would be important for these individuals to have the same credential for which the degree is being offered. This would be important in terms of imparting appropriate knowledge and experience to School Psychologists in order for adequate preparation to enter the workforce and the school site.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Ashley	Arnold		School psychology interns and practicum students must be supervised by an individual appropriately credentialed to practice in the school setting. The proposed language around supervision is vague and will not work for the field of school psychology; where requirements for supervision must included competency in all areas of the NASP Practice Model as well as specific number of years of independent practice before supervising.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Teresa	Fritsch		As a nationally certified school psychologist and a member of the National Association of School Psychologist's Leadership Assembly, I have significant concerns related to the Length of Degree, Delivery Method, and Design section, because it directly conflicts with NASP's Standards for Graduate Programs. I do not believe the number of hours you have listed for this master's level program will adequately prepare students for the work force of school psychology. I've been a practitioner for 27 years and know the amount and complexity of knowledge a school psychologist must have graduating from a program and begin working right out of the starting gate (education, ethics, counseling, assessment, child development, etc.). I would highly recommend 60 graduate semester hours in the specialty area as a school psych in training will need all of those hours; this also matches NASP's Standards.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Teresa	Fritsch		I'm greatly concerned with the lack of clarity under the Required Clinical Training Elements section. NASP Standards require a minimum of 1200 hour internship (with 600 hours in a school setting) in the specialty area of school psychology with the supervision done by appropriately trained school psychologists. There is no mention in this document specifically what the requirements would be out in the field during the clinical training. Graduate students should be held to a high standard and adequately trained for the field of school psychology and a full year of internship experience would provide them that. The field of school psychology is complex with breadth and depth of knowledge needed in many areas. Graduate students need to be adequately trained or they will not be prepared for the issues that come their way. If they are not well-prepared then they will not have success as a practitioner.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Teresa	Fritsch		I'm greatly concerned with the lack of clarity under the Required Clinical Training Elements section. NASP Standards require a minimum of 1200 hour internship (with 600 hours in a school setting) in the specialty area of school psychology with the supervision done by appropriately trained school psychologists. There is no mention in this document specifically what the requirements would be out in the field during the clinical training. Graduate students should be held to a high standard and adequately trained for the field of school psychology and a full year of internship experience would provide them that. The field of school psychology is complex with breadth and depth of knowledge needed in many areas. Graduate students need to be adequately trained or they will not be prepared for the issues that come their way. If they are not well-prepared then they will not have success as a practitioner.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Ashlee	Taylor		1. The Discipline-Specific knowledge of school psychologists includes a knowledge base for both psychology and education, including theories, models, research, evidence-based practices, and implementation strategies, and the ability to communicate important principles and concepts. School psychologists apply their knowledge and skills by creating and maintaining safe, supportive, equitable, and effective learning environments and enhancing family, school, and community collaboration for all students. The profession-wide competencies of the HSP do not seem to include the knowledge base of education such as learning theories, models, research, evidence-based practices, and implementation strategies.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Ashlee	Taylor		3. NASP standards indicate that the school psychology program includes clinical field experiences that allow candidates to develop, practice, demonstrate, and reflect upon evidence-based practices in a graduated manner that increases in complexity. They also require a comprehensive, supervised, and carefully evaluated internship in school psychology. The HSP program does not seem to be that detailed or extensive.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jill	Battal	Massachusetts School Psychologists Association	Section II, B.3.a - Required Clinical Training Elements The Massachusetts School Psychologist’s Association (MSPA) strongly encourages requiring that a minimum of 1200 hour internship must be completed, at least half (600 hours) of which is completed in a school setting. Schools are unique systems, and school and district employees alike recognize the importance of true school based experience in preparation for the workforce. Section II, B.3.c - Required Clinical Training Elements The Massachusetts School Psychologist’s Association (MSPA) strongly encourages strengthening the language around supervision requirements. For example, supervision of HSP students completing an internship in a school setting should require that they are supervised by someone who is specifically trained and credentialed to work within the school setting. Section II, D.3 - Documenting and Achieving Outcomes Demonstrating Program’s Effectiveness Further definition of “master’s degree” / “master...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jill	Battal	Massachusetts School Psychologists Association	Section II, B.3.a - Required Clinical Training Elements The Massachusetts School Psychologist’s Association (MSPA) strongly encourages requiring that a minimum of 1200 hour internship must be completed, at least half (600 hours) of which is completed in a school setting. Schools are unique systems, and school and district employees alike recognize the importance of true school based experience in preparation for the workforce. Section II, B.3.c - Required Clinical Training Elements The Massachusetts School Psychologist’s Association (MSPA) strongly encourages strengthening the language around supervision requirements. For example, supervision of HSP students completing an internship in a school setting should require that they are supervised by someone who is specifically trained and credentialed to work within the school setting.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Moira	McKenna	Oregon School Psychologists Association	The Oregon School Psychologists Association has significant concerns about the standards proposed by the APA. The proposed HSP Master’s level standards includes the field of school psychology, without including crucial components of the discipline. School psychologists receive specialized training in not only the areas of practice outlined by the standards, but also uniquely so in the prevention and interventions systems within schools. School psychologists contribute to their school communities by both providing much-needed mental health services, but by also working with school teams to develop the systems that provide academic and behavioral health supports to students. This training within school systems, as emphasized by the 60 hours of course work and further refined through 1,200 of internship - as outlined in the ethical guidelines written by the National Association of School Psychologists - is non-existent within the HSP Master’s level standards as written. As a specialized ...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Lisa	Baker		As a newly-minted school psychologist, I have significant concerns about the standards proposed by the APA. The proposed HSP Master’s level standards includes the field of school psychology, without including integral components of the discipline. School psychologists receive specialized training in not only the areas of practice outlined by the standards, but also uniquely in the prevention and intervention systems within schools. During my internship, the value I brought to my school community was most clearly seen in how I supported the development and implementation of Multi-tiered Systems of Support in my elementary school placement, and in my knowledge of both behavioral and academic interventions to support students. The 60 hours of coursework and 1,200 hours of internship I completed - as outlined in the ethical guidelines written by the National Association of School Psychologists - was wholly necessary in my development as a school psychologist. It concerns me that this same ...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Andy	Mogan		When students are training for practice in the school setting there should be an emphasis on an internship experience that requires a minimum of 1200 internship with a minimum of 600 of those hours being in the school setting. For individuals aiming to work in the school setting, this allows for supervised experiences within a school setting in order to more appropriately prepare students.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Andy	Mogan		It would also be of benefit to define "appropriately trained and credentialed" individuals further including individuals with relevant training and appropriate credentials for the settings in which supervision is provided.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Emilie	Ney		The comprehensiveness of the required discipline specific knowledge seems ambitious for a two year master's degree program. Requirements for Research Methods at the master's level may be more appropriate to focus on content necessary to be consumers, rather than producers, of research. Profession-wide competencies should also include a focus on prevention, rather than just responsive intervention. Requirements for field experiences should reflect a developmental progression as the student progresses through the program, with students taking a higher level of responsibility later in the program. In addition, requirements for the credentials of the supervisor should more clearly specify that the supervisor has credentials for the setting in which supervision is provided. HSP programs preparing for practice in school psychology should require a minimum of 1,200 hour internship in the specialty area of school psychology, with a minimum of 600 hours in a school setting.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Pamela	August	Missouri Association of School Psychologists	More clarification in this area would be helpful. Some school psychologists have undergraduate degrees in related fields such as education. This may put them at a disadvantage, and at the very least it should be clarified what courses/topics would be required to align training from other disciplines to allow them to proceed in a graduate program.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Pamela	August	Missouri Association of School Psychologists	School psychologists, possibly to a greater degree than clinical and counseling psychologists, are very focused on prevention and early intervention. This is an area where we have a lot of training and our position in public schools makes it an essential part of our profession. Please consider Prevention and Intervention as a key area of competency. Additionally, training in supervision is considered a key competency in school psychology and this should be required curricula as well. We do not see clear guidance around the requirements for practicum and internship, which are essential parts of school psychology training and carry very specific hours requirements. Clarification around the type of training, the supervision provided, and the world of the university training program is essential. This training may look very different for clinical and counseling fields so it may be helpful to specify for each area on its own. A 1200- hour supervised internship and 600 hours of practic...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Kimberly	Sherman		The clinical training and supervision requirements are vague and inconsistent with many states' certification criteria. It's critical that school psychologists receive sufficient applied training in school contexts with appropriate supervision from individuals credentialed to work in schools. Supervisors without school credentials often lack knowledge of relevant laws, models, and contexts (e.g., FERPA, MTSS, classwide intervention, universal academic screening, etc.). State certification criteria often require a 1200-hour internship with at least 600 hours in a school setting, consistent with NASP standards. If APA moves forward with the current standards, we risk producing graduates who lack appropriate training to serve the public in schools. The current standards also risk producing graduates who are not employable (as they won't meet minimum certification requirements in many states without the requisite internship hours / setting).
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jared	Dart	Search Results Web Result with Site Links Virginia Academy of School Psychologists	Current standards as written appear vague. To become a school psychologist, the minimum training programs should require a 1200 hour internship in the area of school psychology, with a minimum of 600 hours in a school setting. Schools are very unique systems. This experience is a vital aspect of a successful training program.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jared	Dart	Search Results Web Result with Site Links Virginia Academy of School Psychologists	NASP maintains that internship supervision at the specialists level is provided by a credentialed school psychologist who has a minimum of three years of full time experience or the equivalent. More definitions related to “appropriately trained and credentialed” is needed. Supervision provided by individuals with little or no experience working in schools would contribute to a set of practitioners who would view student difficulties very differently from students being trained in specialist level programs. This likely would lead to very different approaches to diagnosis, prevention, and intervention.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jared	Dart	Search Results Web Result with SitVirginia Academy of School Psychologists	Current standards as written appear vague. To become a school psychologist, the minimum training programs should require a 1200 hour internship in the area of school psychology, with a minimum of 600 hours in a school setting. Schools are very unique systems. This experience is a vital aspect of a successful training program.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jared	Dart	Search Results Web Result with SitVirginia Academy of School Psychologists	NASP maintains that internship supervision at the specialists level is provided by a credentialed school psychologist who has a minimum of three years of full time experience or the equivalent. More definitions related to “appropriately trained and credentialed” is needed. Supervision provided by individuals with little or no experience working in schools would contribute to a set of practitioners who would view student difficulties very differently from students being trained in specialist level programs. This likely would lead to very different approaches to diagnosis, prevention, and intervention.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Kirstin	Wilson	Indiana Association of School Psychologists	We submit that a 1200 hour internship should be required prior to the granting of a school psychology degree with 600 hours of that internship being completed within the school setting. Students wanting to practice within a school setting need to have the opportunity to experience the school setting prior to accepting a job there. A school setting is very, very different from a clinical or private practice setting. There are many variables that students need to experience such as working with teachers, learning how a school operates, and the difference between the DSM-5 and special education law. Also, a 1200 hour internship aligns with the National Association of School Psychologists (NASP) practice model.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Kirstin	Wilson	Indiana Association of School Psychologists	While completing an internship or practicum, graduate students need to be supervised by practicing school psychologists. In order to practice in a school, not only do school psychologists have to understand testing, but they also have to understand curriculum, reading development, the teacher's perspective, the stress placed on teachers for students to perform, and the system of a school as it is very different from a clinical or private practice setting. Graduate students also need to understand special education law as well as eligibility criteria for special education. While eligibility criteria are taught, the other areas that school psychologists need to be versed in comes through experience within a school.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jayne	Boulos		Section 11 B . 3.a As a school psychologist I am very concerned with having a minimum of six hundred hours of training in a school setting as this would not give a student nearly enough time to prepare them for the work that would be required in the setting. Section II B.3.c: I do not believe the APA has made it clear what an appropriately trained and credentialed individual would look like? The significant negative affects on a poor supervisor or a properly credentialed person would have long-standing consequences for the practitioner.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Moira	McKenna		While the overall concept of the HSP Masters Program attempts to address a need in the field of psychology, that by perception, cannot be achieved by any currently existing Master's or Doctoral level degree, the proposed program is trying to reach across a spectrum of content that may not adequately address any areas in a sufficient manner in which to serve effectively, once graduated from the program. From the perspective of practice in school psychology, a student who has completed a school psychology program at the Specialist's level will have completed a minimum of 60 credit hours and a 1200 internship, with a minimum of 600 hours supervised in a school setting with a qualified school-psychologist in the field as aligned with 2020 Standards of the National Association of School Psychologists (NASP). Without this experience, not only would a HSP have a difficult time obtaining a license to work in schools in a given state, they may not have the actual skill to perform a range of tas...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Charles	Archer	Ohio School Psychologists Association	Section II, B.3.a - Required Clinical Training Elements Existing standards for training and credentialing School Psychologists at the Specialist degree level require a minimum of a 1200-hour supervised internship. This direct experience within a school setting is critically important to being effectively prepared to do this work. In Ohio, anything less would not qualify for a license to practice without meeting this requirement and could end up precluding students in an HSP Mater’s program from gaining employment in any public schools in the state. All told, our training standards leading to credentialing as a School Psychologist require a minimum of 2 years of full-time graduate studies with 1 year of full-time internship. This results in a 60 graduate semester hour commitment with an entire school year of fulltime internship or a total of three years of university training.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jayne	Boulos	Maine Association of School Psychologists	Section II B.3.a The Maine Association of School Psychologists disagree with the minimum of 600 hours of training in a school setting as this would not nearly give a student enough time to properly prepare them for the work that will be required in that setting. Section II B.3.c_ The Maine Association of School Psychologists have a great concern about what the APA means by an appropriately trained and credentialed individual to provide supervision. Without a properly credentialed supervisor, this could have significant negative consequences on the training of the master’s level practitioner.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Kimberly	Adams	Minnesota Association of School Psychology	The Minnesota School Psychology Association (MSPA) recommends that HSP programs require a minimum of 1200 hours of internship within the specialty area of school psychology, 600 of which will be in a school setting. This internship is critical to effectively preparing school psychologists to engage in the full role a school psychologists play in a school. These supervised experiences are foundational in preparing students for a career as a school psychologist and support the skills needed to effectively practice school psychology.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Kimberly	Adams	Minnesota Association of School Psychology	The Minnesota School Psychology Association (MSPA) advocates for greater clarity in what constitutes supervision by “appropriately trained and credentialed” individuals. MSPA supports a recommendation that supervision is provided by individuals with relevant training and appropriate credentials for the settings in which supervision is provided.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Holly	Yoke	West Virginia School Psychologists	B.1.a.i. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning Curriculum Elements Required by the Profession: Discipline-Specific Knowledge: With the standards as currently written, it is not clear if the core knowledge of psychology requirements must be obtained prior to graduate coursework, or if it can be obtained during graduate coursework. Many school psychologists enter the field with undergraduate degrees in education or related fields. B.1.b Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession: Profession wide competencies: The lack of inclusion of “prevention” as a competency for all HSP programs is a concern to WVSPA, and we believe that it should be included with Intervention as “Prevention and Intervention.” B.3.a Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession: Required Clinical Training Elements WVSPA belie...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Megan	Cutrer		Concerns in this area are mainly with credentials. Many states require the 60 hour minimum, as well as the 1200 hour, year-long internship (600 hours in school setting required) for appropriate credentials. Greater clarity is needed to avoid confusion in this. Also, there are minimum requirements for intern students to be properly supervised according to NASP standards. As written, this may not adequately satisfy those standards.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Kim	Sherman	Louisiana School Psychological Association	As written, the description of required clinical training elements would not ensure that graduates in school psychology programs complete an internship consistent with most states' credentialing criteria. As in many other states, Louisiana's minimum credentialing criteria for school psychologists require a 1200-hour internship with at least 600 hours in a school setting. Standards for HSP programs that aim to prepare school psychologists should require internships that will prepare graduates to achieve the contextual competencies and entry-level practice credentials needed for school psychology practice. Further, to optimize training and protection for the public, supervisors should have credentials appropriate for the settings in which they supervise. The current proposed standards could benefit from greater clarity in defining "appropriately trained and credentialed" supervisors.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jess	Swan		The supervision experience is crucial in the development of well prepared, competent practitioners. “Appropriately trained & credentialed” is vague and unclear. More specifics about relevant training/ credentials that are aligned to setting, programs, services, & training matched to the supervisee’s goals & the NASP practice model goals may help ensure appropriate supervision at the specialist level. As a recent School Psychology graduate, with the utmost respect, supervision by an “appropriately trained & credentialed” psychologist approved to work in schools, but primarily trained outside of this discipline, very likely would have resulted in significant frustration or confusion as there is considerable variation in training and practice. Finding a good supervisor/ supervisee match in rural underserved areas can be a huge challenge, and, defining requirements in more detail will be important to holding institutions to seek a high standard in a critical area.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Ginger	Newberg		II. B. 1. a. proposes that "Programs may elect to meet the following areas of knowledge at either the undergraduate- or graduate-level"...UNDERGRADUATE coursework is not adequate or appropriate for GRADUATE level degrees. ALL classes for a MASTERS degree should be taught at the GRADUATE level.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Ginger	Newberg		II. B. 3. c. "Supervision must be provided by appropriately trained and credentialed individuals." This is too vague. Appropriate supervision should only be provided by an appropriately trained and credentialed PSYCHOLOGY PROFESSIONAL, LICENSED in the state.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Carol	Williams	North Carolina Association of Professional Psychologists	Supervision is a key element for early career psychologists, such that it is important to have a knowledgeable, experienced, psychologist providing this necessary teaching element. What is meant by this draft SoA supervision specification that provides only that supervision should be provided by “appropriately trained and credentialed individuals”?
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Carol	Williams	North Carolina Association of Professional Psychologists	Psychology and behavioral sciences licensing boards across the nation already specify education and institutional requirements toward licensure, which includes accreditation. Currently, a number of states provide a full spectrum of psychological services provided by master’s degreed practitioners who have attended accredited institutions. Is this to provide a foundation toward assisting other states to license master’s degreed psychologists to provide much needed psychological services, or to strip the ability of master’s degreed practitioners to provide the full scope of services to which they have been trained?
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Karah	Chapman		B.1.a.i - Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession: Discipline Specific Knowledge More clarification in this area would be helpful as some individuals moving into the field of school psychology have undergraduate degrees in related fields such as education. And while this may not be a desirable area of expertise for other psychology areas, it is for the field of school psychology. The current description may put those individuals at a disadvantage. At the very least it should be clarified what courses/topics would be required to align training from other disciplines. B.1.b Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession: Profession wide competencies School psychologists place a significant focus on prevention and early intervention. As such, these areas require a significant amount of training for public school practice and an ...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jennifer	Tininenko		A master's degree is by nature a different degree from a PhD, which I hold. A masters level degree is a shorter-term training (less than 2 years) that is accessible to a wider variety of applicants and must embody practical training that can launch students into employment in a clinical position. A clinical psychology masters degree offers a unique opportunity for a larger number of clinicians to have training and deliver effective care for a wider range of patients. Given this, I have concerns about the proposed DSK course descriptions and clinical requirements. If in fact each of the 8 DSK courses are required, it would put the program past the 2 years or less goal that other masters programs offer. I believe that graduates will be better prepared to utilize their training if they were to receive all coursework and clinical experiences focused on the science and implementation of evidence based treatments. With the proposed DSK list, graduates may have breadth of "orientation" to...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Francine	Conway	NCSPP	The MA standards list the same PWCs as the doctoral SoAs, but can you cover all of these in two years? Some of the PWCs (supervision, consultation) are generally seen as competencies that are introduced at the end of the doctoral program and covered to a greater degree on internship and at postdoctoral training. What level of competency can be expected in a MA program?
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Francine	Conway	NCSPP	Does it make sense to list coverage of all of the DSKs at this level? Currently many accredited doctoral programs only cover some of the DSKs for their embedded MA.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	stephanie	sokolosky	Texas Association of Psychological Associates	Supervision for master's training in the field of psychology must be provided by an appropriately trained and credentialed psychologist, licensed in the state in which supervision is being provided. If online/virtual supervision is allowable, each state provides guidance on the current status and guidelines for receiving supervision using virtual methods. In every case, the supervision needs to be provided by a properly trained and credentialed psychologist.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Moery	Teresa		Section II, B.3.a: These guidelines do not include the requirement for students to complete any of their supervision in a school setting. The practice of school psychology requires knowledge of and experience with providing services in that setting. Section II, B.3.c: The supervising individuals should be required hold appropriate training and credentials for the setting in which they are providing supervision.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Tanya	Cook		Section II,B.3.a - I have concerns for any program of psychology that does not require training within a school setting. I feel it is critical to have an understanding of the total workings inside a school system. School psychologists are required by NASP to complete a full year internship (with a minimum of 600 hours of that 1200 hour year to be in a school setting) working in a school system. This provides the opportunity to learn that many "ideal" or "theoretical" interventions may not have practical application within a school setting.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Kristen	DeYorio		In reference to Discipline-Specific Knowledge and Profession-Wide Competencies: -The required trainings listed (Research Methods, Statistical Analysis, Psychometrics) are all generally part of an undergraduate program. Requiring additional graduate level courses in these areas, while certainly helpful for going deeper into all three area, takes the focus of a graduate degree from the application of psychological and statistical understanding and places it it theoretical learning. The greater purpose of a master's degree in psychology should be learning the application of your knowledge. Coursework should focus on implementation of, and learning to read and administer, assessments, group, family, sand individual counseling, and development. In reference to Required Clinical Training Elements: -It is my understanding that the introduction of the HSP graduate degree is intended to help address the shortage of qualified professionals in the fields of counseling, clinical psychology, ...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Joy	Ensor	Michigan Psychological Association	On behalf of the Executive Committee and Master’s Committee of Michigan Psychological Association: Seventeen states credential master’s level psychological practitioners. Michigan has over half of the licensed master’s psychological providers nationwide. Our comments focus on educational standards that prepare HSP graduates for clinical practice. We welcome standards that will (a) distinguish the skills and competencies of master’s trained HSP practitioners from those of doctoral trained Professional Psychologists and (b) open a pathway to a licensure law in Michigan that will confer on HSP practitioners independent practice privileges within a scope of practice consistent with their skills and competencies. Definitions: The CoA’s definition of HSP is educational, while its definition of Professional Psychology is service oriented. We propose a comparable focus on professional practice in the HSP definition. Length of degree, delivery method, and design: We appreciate that pr...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jackie	Tyson	Board of Educational Affairs	4. There are several places throughout where we believe further clarification is important to understanding the intent of particular standards. For example: a. Standard II.B.1.a There are few differences between the master’s DSKs and doctoral DSKs, which makes sense given that these areas are requisite for practice; it might be helpful to state explicitly what separates the levels of training.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Amy	Balmanno	California Association of School Psychologists	B.1.b We recommend that competencies for Prevention and Intervention as well as Supervision be explicitly stated as required coursework on School Psychology programs.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jackie	Tyson	Board of Educational Affairs	5. Standard II.B.1.a It is unclear why History and Systems is not required for master’s HSP students. History and Systems is also important to establishing a professional identity as a psychologist. It could be appropriate under sub-bullet i. as a DSK area that could be fulfilled either by undergraduate or graduate-level coursework. 6. Standard II.B.1.a Why is it that programs “may” elect to meet certain areas of knowledge (pp. 6-7)? Would we want students graduating from APA-accredited Master’s HSP programs who know nothing about Affective Aspects of Behavior or Developmental Aspects of Behavior, for example? Presumably, Master’s programs will cover these areas regardless of what the DSKs designate, but the term “may elect” provides a loophole that perhaps should not be there. a. It is possible that the intent was that programs could offer undergraduate-level courses in these areas rather than graduate-level courses; either way, greater clarity is needed. 7. Standard II.B.1.a Perh...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jackie	Tyson	Board of Educational Affairs	11. There are several places throughout where we believe further clarification is important to understanding the intent of particular standards. For example: a. Standard II.B.2: Clarify whether this standard is referring to the consumption of research, the production of research, or both. 12. Standard II.B.2 It will be important to provide greater clarity of what competency in Assessment looks like for the master’s level, or at least a clarifying statement (e.g., “Assessment, appropriate to the specialty and scope of practice”) 13. Standard II.B.2 Greater attention should be paid to cultural diversity, and specifically adopting the language and understanding of the APA 2017 Multicultural Guidelines. Although this language was likely and understandably adopted from the doctoral SoAs, this language does not reflect our shift toward understanding systems, structures, oppression, and social determinants of health disparities. It will be important to shift away from outdated language and...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jackie	Tyson	Board of Educational Affairs	14. Standard II.B.3 There is little information in the document pertaining to supervision and supervised experiences. Specifically: a. Given that the overriding concern of membership has been whether Masters HSPs could be prepared for practice, we would have expected far more emphasis on supervised experiences at the practicum level. b. Further, it may be prudent to add a shorter internship that can be completed in a semester (e.g., 600 hours) to better evaluate profession-wide competencies as they integrate more fully before graduation. Practicum and internship experiences are qualitatively different in that students completing practicum are still completing required coursework, are more closely supervised, and often provide a limited or focused range of clinical services (e.g., therapy practicum vs. assessment practicum). In contrast, internship is a culminating clinical experience, after the completion of coursework, in which students provide a broader range of clinical services....	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Amy	Balmanno	California Association of School Psychologists	B.3.a In California, our credentialing body requires 450 hours of supervised practicum (300 of which must be completed in a preschool-grade 12 setting) in addition 1200 hours of supervised internship (1000 of which must be completed in a preschool-grade 12 setting). We recommend aligning with this or HSP graduates in CA who are wanting to specialize in School Psychology will not be eligible for the credential and ultimately will not be able to practice.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Amy	Balmanno	California Association of School Psychologists	B.3.c In California, the CTC explicitly states the following qualifications for site supervisors: "1. Minimum of 3 years of experience as professional in the field 2. Possession of a PPS School Psychology Credential 3. Knowledge of context and content appropriate to the practicum experience." Further, "a field-based professional holding a current and valid credential authorizing service as a school psychologist provides direct culminating fieldwork or internship supervision. This supervisor must have at least the equivalent of three (3) years of full-time experience as a school psychologist. A field experience placement site is approved by the program and provides experiences that are consistent with the program design and objectives."
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Dawson	Betty		Credit in a graduate program should NOT be given to undergraduate courses. The courses referenced are in the “requisite core knowledge of psychology.” Undergraduate courses do not provide the depth of knowledge from which to build "a foundation for further training in the practice of health service psychology."
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Dawson	Betty		(c) Psychometrics should include training in the selection, administration, analysis, and interpretation of psychological assessment, including direct experience in the specific practice area. Accurate assessment is crucial for implementing an educational plan, an intervention, a treatment plan, etc. Many licensed masters-degreed psychology practitioners provide competent psychological assessments in a variety of settings.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Dawson	Betty		To be valuable, supervision MUST be provided by a licensed practitioner in psychology, who is knowledgeable and experienced in the practice area he or she is supervising.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Erika	Olinger	Oklahoma School Psychological Association	Section II, B.3.a: For those completing School Psychology degrees, standards should match those approved in the NASP "Standards for Graduate Preparation of School Psychologists" (2020), and should specify a 1200 hour internship in school psychology, with at least 600 hours of direct supervision within a school setting. Direct experience in schools is imperative for appropriate training and preparation of school psychologists. Section II, B.3.c This language is vague. More specific definitions should be used to operationalize "appropriately trained and credentialed individuals" to ensure that supervision is provided by supervisors with training and credentials in specific settings (ie, schools).
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Emily	Klein	Delaware Association of School Psychologists	The Delaware Association of School Psychologists (DASP) wishes to thank the Commission on Accreditation (CoA) for all its thoughtful and hard work on behalf of the education and training of professional psychologists who deliver health service psychological services. We appreciate the CoA’s efforts to address the shortage of mental health professionals by considering accreditation of non-doctoral level programs. With all due respect to the high level of professionalism and the hard work evident in the CoA’s draft standards and processes for accrediting Masters’ degree programs in Health Service Psychology, DASP wishes to submit the following comments/recommendations for consideration. All of these comments/recommendations are specific to the School Psychology branch of Health Services Psychology, in keeping with our area of expertise. B.3.a. DASP recommends that the CoA should consider specifying that HSP programs training school psychologists should include more specific requiremen...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Mary	Satchwell	Illinois School Psychologists Association	II.B.3. - Required Clinical Training Elements ISPA strongly encourages requiring that a minimum of 1200 hour internship must be completed in a school setting as part of a school psychology HSP training program. Schools are unique systems, and school and district employees alike recognize the importance of true school based experience in preparation for the workforce. ISPA strongly encourages strengthening the language around supervision requirements. For example, supervision of HSP students completing an internship in a school setting should require that they are supervised by someone who is specifically trained and credentialed to work within the school setting. A school setting is very, very different from a clinical or private practice setting. There are many variables that students need to experience such as working with teachers, understanding school systems, and critical differences between clinical diagnoses/treatment and special education law. Coursework and field-based ...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Stephanie	Barbre	Texas Association of School Psychologists	The appropriate internship for school psychology graduate students is a minimum of 1,200 hours, 600 of which must be completed in a school setting. The extensive supervised experience is critical for career preparation, appropriate service delivery, and necessary for licensure under our state credentialing requirements in Texas. We ask that APA adopt these internship specifications for school psychology specialization programs to align with the NASP Standards for Graduate Preparation of School Psychologists. School psychologists must be aware and abide by not only the ethical principles of our professional practice, but also multiple legal regulations. To work in the school setting, we must be knowledgeable of federal education laws, state education laws, codes, and regulations as well as our state licensing board rules and regulations. Because we are trained to enter a comprehensive role, we must have supervised field experience in each of the following areas:Data-based decision maki...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Julene	Robbins	Arizona Association of School Psychologists	Although the proposed language does not specify level of training and credentials for supervisors, the term of "appropriately trained and credentialed" should be defined to reflect a supervisor's competency specific to trainee's areas of study. For example, the NASP clearly outlines that the school psychology trainees' internship experiences should be supervised by a credentialed school psychologist with a minimum of 3 years of experiences in the field.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Julene	Robbins	Arizona Association of School Psychologists	Although the proposed language does not specify level of training and credentials for supervisors, the term of "appropriately trained and credentialed" should be defined to reflect a supervisor's competency specific to trainee's areas of study. For example, the NASP clearly outlines that the school psychology trainees' internship experiences should be supervised by a credentialed school psychologist with a minimum of 3 years of experiences in the field.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Julene	Robbins	Arizona Association of School Psychologists	Although the proposed language does not specify level of training and credentials for supervisors, the term of "appropriately trained and credentialed" should be defined to reflect a supervisor's competency specific to trainee's areas of study. For example, the NASP clearly outlines that the school psychology trainees' internship experiences should be supervised by a credentialed school psychologist with a minimum of 3 years of experiences in the field.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Stephanie	Barbre	Texas Association of School Psychologists	School psychology interns and practicum students must be supervised by an individual appropriately credentialed to practice in the setting in which the internship hours are obtained. We recommend specifying school psychologists must be supervised by an individual with the appropriate credentials relative to the setting of the internship or practicum experience. School psychology supervisors must be trained in the NASP practice model and be able to provide the student with well-rounded field experiences specific to domains of practice. Further, for the requirements to obtain the NCSP, supervisors must have a minimum of three years of independent practice before they can supervise school psychology interns.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jim	Deni		The M-HSP should require a minimum of 60 semesters of training including practicum and a 1200 internship both in a school setting. The 10 domains of training should be consistent and aligned with the NASP 2020 Professional Standards. As current written many competencies required of a school psychologist are missing. The professional work competencies have no focus on prevention and intervention. In addition there is little required sequence in cognitive and achievement assessment. Another concern is the lack of clarity for preparedness for entry-level practice." A traditional master's degree is not the entry-level for practice as a school psychologist, which is much more rigorous and comprehensive at the specialist level training is. (Standard II.3 Documenting and Achieving Outcomes Demonstrating Program's Effectiveness.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Samuel	Song	Council of Directors of School Psychology Programs (CDSPP)	Regarding DSKs, it would be helpful to add History and Systems as required for master’s HSP students because of it is important to establish a professional identity as a psychologist. It could be appropriate a DSK area that could be fulfilled either by undergraduate or graduate-level coursework. More information should be included on supervision and supervised experiences. Specifically, the addition of a short internship that can be completed in a semester (e.g., 600 hours) could be beneficial to support the evaluation of profession-wide competencies before graduation. Providing adequate coverage of DSKs at the masters level seems challenging in such a short time. It could be more easily achieved if multiple DSKs can be covered in a single course (perhaps more liberally than is allowed at the doctoral level?)
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Diana	Barroso		The scope of the proposed HSP umbrella in terms of specialties is not altogether clear, and the proposed standards seem to be better suited to a doctoral level program. How would a health psychologist or practitioner at the master level be expected to be licensed and/or function in the community? Many master level programs, unless research-based, take a practitioner approach to produce graduates who will engage mostly in clinical practice. While we assume that the counseling designation under the proposed HSP specialty includes mental health counseling, the potential applicability of the standards to related areas, such as marriage and family therapy, is not addressed. It should also be noted that multiple courses in statistics and research methodology are not required subject areas for licensure of mental health counselors (LMHC, LPC), or certification of school counselors (this category is not the same as school psychologists). Mental health counselors, for instance, must take one co...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jessica	Carranza	Montana Association of School Psychologists (MASP)	B.3.a Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession: Required Clinical Training Elements The standards would be strengthened by providing specific requirements for practicum and internship and the role of the university program in these supervised field experiences. Programs preparing for practice in school psychology should require a minimum of a 1200-hour internship in the specialty area of school psychology, with a minimum of 600 hours in a school setting, consistent with current NASP Standards. Direct, supervised experience in a school setting is critical to effective preparation in school psychology. As written, the HSP students with specialty in School Psychology would not receive the same high level of training that school psychology students receive in Specialist level programs. B.3.c - Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Pro...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Michelle	Krieger	APAGS	? In the section on Profession-wide Competencies, “viii.Supervision” is listed as a competency. Respectfully, we suggest that this is clarified, perhaps to “how to effectively use supervision” if this is the intent of the statement.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Debra	Freburg		Section II, B.3.a This standard is not specific enough. In order for school psychologists to be adequately prepared for the school setting it is critical that they participate in an internship in a school setting with a highly qualified supervisor who has had experience as a school psychologist in a school setting. the NASP standard for this would be a 1200 hour internship with a minimum of 600 supervised hours in a school setting. School Psychologists would be expected to have competencies beyond testing and diagnosis in line with the NASP practice model.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jessica	Mefford	Kansas Association of School Psychologist	The Kansas Association of School Psychologists (KASP) has reviewed the standards for accreditation of Master’s level Health Service Psychologists (HSP) as it relates to the training of potential School Psychologists and HSPs who seek to work in school settings. Direct experience in a school setting remains essential to effective preparation for school psychology practitioners. NASP standards require specialist-level training with a minimum of 60 graduate credit hours including practica in a school setting, and a 1200 hour internship (with at least 600 hours in a school setting) supervised by one credentialed in the setting of internship. Regarding the minimum of 600 hours in a school setting, required for supervision is one with a credential in that state for school psychology with 3 or more years of experience beyond internship. HSP programs preparing for practice in schools under a title including school psychology should require a practica experience in schools, and then a minimum o...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jessica	Mefford	Kansas Association of School Psychologist	In relation to Section II. B.3.c: The Kansas Association of School Psychologists (KASP) has reviewed the standards for accreditation of Master’s level Health Service Psychologists (HSP) as it relates to the training of potential School Psychologists and HSPs who seek to work in school settings. With regard to supervision provided by “appropriately trained and credentialed” individuals, more clarity is needed. KASP recommends that supervision of school psychologists is provided by individuals with relevant training and appropriate credentials for the settings in which supervision is provided. NASP standards require a 1200 hour internship (with at least 600 hours in a school setting) supervised by one credentialed in the setting of the internship in that state, and for the school setting this is one with 3 or more years of experience beyond internship. HSP programs preparing for practice in schools under a title including school psychology should require a level of supervision of one tr...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	June	Preast	University of Alabama, School Psychology Program	The comprehensiveness of the areas of discipline-specific knowledge seem ambitious for 2-year master’s programs. There seems to be an assumption that anyone entering a graduate program is coming with undergraduate training in psychology, which puts those entering from other areas (education, family science, public health, etc.) at a disadvantage. This also places a significant burden on the faculty to develop those additional competencies during graduate training. Research Methods: As written, they seem like they are more appropriate for the doctoral level and suggest graduates of master’s programs will be producers of research. The description should include language that reflects the need for M-HSP providers to be critical consumers of research and engaged in applied research in the field. The profession-wide competencies are very clinical and psychopathology focused, with no mention of prevention (intervention included as a profession-wide competency). Supervision should be tre...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	June	Preast	University of Alabama, School Psychology Program	There is a lack of continuum for field experiences and acquisition of competencies over time. The field experience requirements are not graded and complex. Trainees should have greater levels of responsibility as they progress through their programs. The supervision requirement is vague and it is not clearly stated that supervisors need to be trained in an HSP area and in the specialty of school psychology, appropriately
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	UMMP	Board	Group	B.1: The description of DSK (Discipline-Specific Knowledge) with PWC (Profession-Wide Competencies) seems transposed. A PWC should serve as the cornerstone for graduate level Master’s psychologist practice. The DSK would more appropriately refer to a defined/specialized practice area within psychology after or concurrent with the foundation requirements and competencies being met. School, Clinical and Counseling psychology (proposed defined practice areas in HSP) require additional and diverse skill sets for their practice environments. Worded as is, each practice area would be required to include the other’s specialized practice for accreditation. This would be impractical and potentially lead to a downgrade in standards for all defined practice areas. B.1.a.i: Transferring “credit” from a Bachelor’s program into a Master’s program is not appropriate. A key goal is to accomplish a consistent standard for foundational education/competency, with appropriate/ vetted instruction and w...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Mallory	Hart	Kentucky Association for Psychology in the Schools	Section II, B.3.a Specific to school psychology training programs, it is recommended to accredit health service psychology training programs consistent with the National Association of School Psychology recommended comprehensive practice model. Specifically, the inclusion of a minimum of 1200 hour supervised internship in the specialty area of school psychology, with a minimum of 600 of the 1200 supervised hours in a school setting to appropriately provide school-based services.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Rhonda	Remsen		Required Clinical Training Elements: As part of my training and one of my current roles as an intern supervisor for school psychologists, I find the internship requirement invaluable. Current NASP standards require a 1200 hour internship experience with 600 hours directly served in a school setting. As the "brick and mortar" environment of a school is unique, the need to provide training in the school setting is crucial. Supervision by appropriately trained (i.e. practicing school psychologists holding the necessary credentials as required by the state)and credentialed school psychologists is also crucial for the graduate students participation and application of skills to competency. Along with a broad course type of graduate program of 60 credits, the internship (conducted after the two years of course work)is imperative for becoming a highly trained school psychologist.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	UMMP	Board	Group	B.1.b: UMMP agrees the i-ix list of Profession-Wide Competencies are essential. Our concern is the PWC’s and DSK’s are unclear and do not specify operational definitions and standards. For example, what comprises Assessment? What are the specific competencies and standards? It is unclear if psychological testing is included at all. If so, via theoretical or direct application and training. Does Supervision refer to being Supervised or Supervising? Where do practicums and clinical experience during the graduate program fit in? It is difficult to determine specifically what would comprise Master’s Psychologist education/training. It is difficult to assess the benefit of the APA CoA programs for Master’s Psychologists without these specifics. It is difficult to compare the APA CoA program to other Accreditation organizations for Master’s Psychologists which are providing these specifics.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	UMMP	Board	Group	B.3.C-D: “Individuals” providing supervision should also: 1) Be licensed as Master’s or Doctorate Psychology professionals in the state, 2) Have a minimum standard of years of experience with clinical practice, 3) Have appropriate training to supervise.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Samara	Way		As a licensed psychologist and nationally certified school psychologist and former Director of Clinical Training, I would advocate for greater specificity regarding minimum requirements for supervision.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Shawna	Kelly		There seems to be an assumption that all graduate students enter graduate level training from undergraduate programs and ignores the fact that there may be multiple points of entry into the field of psychology.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Shawna	Kelly		It is unclear why the standards, as currently written, do not make any mention of the requirements for practicum or internship experiences. These experiences are critical to ensuring an adequate level of training to practice independently. Programs preparing students in the area of school psychology should require a minimum of a 1200-hour internship in the specialty area of school psychology, with a minimum of 600 hours in a school setting. Direct experience in a school setting is critical to ensure that students are adequately prepared for practice in schools. Additionally, supervision of the practicum and internship experiences should be provided by someone with experience in and a current credential to practice in the speciality area.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Shawna	Kelly		With regard to B.3.c, supervision should be provided by individuals who are appropriately trained and credentialed to practice in a given specialty area.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	UMMP	Board	Group	B.1.a.ii a-c: UMMP agrees the Program must include the three areas of Research Analysis, Statistical Analysis, and Psychometrics. Psychological assessment must be a core competency. While there are many methods of assessment, in this context, assessment is a scientific, evidenced-based practice that differentiates psychology from other mental health professions. It is integral in diagnosis, development of treatment plans, informing clinical work, and the application of appropriate interventions. ALL three areas are fundamental for competent clinical assessment at the Master’s Level. Therefore, it is important that these 3 domains be taught not just theoretically, but in direct application and process to gain experience and fundamental competency in the interpretation of scientific-based information. These three areas should be taught in such a manner that a student will be sufficiently prepared to take the EPPP and also to administer/interpret standardized test results, write reports, ...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Laurie	Klose		This allows programs to require specialist level or certificate of advanced graduate studies but does not require it- as is the case for programs to meet required professional standards for the practice of school psychology. This is a slippery slope and can lead to inadequately prepared school psychologists.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Darcie	Tramp		In order to become a fully trained and competent school psychologist, it is necessary to participate in a full 1200-hour supervised internship, as well as a 600-hour practicum experience. Internship and practicum experiences should mostly take place in school settings, as the majority of school psychologists are hired within the school setting, and their training is specific to the school setting. It is during these experiences that school psychology students learn how to apply their vast knowledge in the areas of academics, behavior, and law. It is my fear that if these expectations are left to dwindle, so will highly qualified and effective school psychologists. Though it is true that there are wide shortages of school psychologists, it is not helpful or ethical for schools to hire ineffective and poorly-trained professionals.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Kim	Sherman	Louisiana School Psychological Association	The proposed standards require a minimum of 2 years of graduate-level study, which is inconsistent with Louisiana's minimum credentialing standards for school psychologists, which require the equivalent of a specialist degree (60 credit hours, typically two years of coursework) and a 1200-hour internship with at least 600 hours in a school setting (typically a 1-year internship).These standards could shape school psychology programs that produce graduates who are not employable in Louisiana or in many other states (i.e., not eligible for certification or licensure) and who are not sufficiently trained in the broad range of competencies needed to practice school psychology. We recommend standards that require 60 credit hours and a 1200-hour internship with at least 600 hours in a school setting.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Carol	Williams	North Carolina Association of Professional Psychologists	Our allied professionals, including Licensed Clinical Social Workers, Licensed Professional Counselors, and Licensed Clinical Mental Health Counselors, are thriving despite doctoral-degreed psychologists' effort to thwart their independence and scope of practice over the years, in part because they are unified within their discipline and thus have greater numbers. Social workers and Counselors do not discriminate and undermine professionals in their field based on their degreed of education. How does this draft accreditation model promote master’s degreed psychologists toward practice within the full scope of their teaching and training? Master’s Degreed Psychologists have been recognized and credentialed by State Behavioral Sciences Regulator and Psychology Boards, and have served in a competent and professional manner for the last three decades. The current education, training, examination for license (EPPP) and credentialing is equivalent to or exceeds those of other professio...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Bradley	Petry		"...appropriately trained and credentialed" must be clarified given that this description does not take into account the training scope and sequence as indicated in by the school psychology training parameters outlined by NASP - including supervised internship beyond the master's degree.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Kristen	DeYorio		The idea of program-specific elements seems appropriate, though this description is vague. In order to better prepare graduates, this should more clearly outline the need for specific coursework in either counseling, clinical, or school psychology
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Rhina	Lovo	Puerto Rico’s School Psychology Association	Commentary about Master’s level training The Puerto Rico Association of School Psychology (APEP) supports providing predoctoral training for school psychologists that allows entering the profession at the master’s level. In Puerto Rico most school psychology programs offering master’s degrees were designed according to NASP guidelines. Therefore, the training requires a minimum of 60 credit hours and practicum and internship hours that vary in different institutions. Although local universities do not describe their programs as Specialist in School Psychology, the master’s degrees awarded generally comply with what NASP defines as Specialist. NASP guidelines were used in Puerto Rico since programs were founded during the last 30 years and there were no APA guidelines for the master’s level. The NASP requirements of 1200 hours including 600 in school settings should be included in APA guidelines. Also, a minimum of 60 credit hours. Therefore, we recommend that the APA guidelines for...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Amy	Balmanno	California Association of School Psychologists	In California, our CTC states: "Faculty, program supervisors and district-employed supervisors monitor and support each candidate toward mastering the SPPEs. The program uses evidence-based assessment instruments to guide and support candidates to understand and address areas for personal and academic improvement and to help candidates develop the knowledge, skills, dispositions and abilities necessary to perform as highly skilled school psychologists. Qualified faculty members have a minimum of three years of professional practice and are assigned and available to advise applicants and candidates about their academic, professional and personal development, and to assist each candidate’s professional placement. The program provides support and assistance to candidates and only retains candidates who are suited for entry into or advancement as school psychologists." We suggest more specific guidance about trainers and program leaders being required to have training and experie...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Amy	Cannava		D(1)(b) - what, if any, allowances will be permissible through grandfathering if masters' level clinicians graduated from programs which earn accreditation without additional changes to the existing structure? Would past graduates be able to retroactively obtain HSP credentialing having completed the same program requirements which future graduates obtain?
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Brandi	Duskie		As a school psychologist, there are a few areas regarding accreditation of Masters level HSP. I've indicated my concerns below: Section II, D.3 regarding documenting and achieving outcomes of a program's effectiveness School Psychology practitioners are entry-level at the Specialist level (of at least 60 graduate credit hours with 1200 hour internship), with many earning a Master's degree prior to the Specialist degree (after only ~30 graduate credit hours and no internship). It should be clear that the entry level for school psychologists is 60 graduate credit hours with 1200 hours of internship. In order to maintain high quality training and consistency across states and programs, clarity of the graduate preparation consistent with NASP Standards should be included for those seeking credentialing as School Psychologists.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Kari	Oyen		As both a Licensed Psychologist as well as a trainer of School Psychology, I am very concerned about how well a student would be prepared to engage in an entry level of practice. A master's level degree is not the entry level of practice for school psychology, nor is it the entry level of practice for a Licensed Psychologist. It is critical to require clear and rigorous standards to ensure that the ethical standards of our profession are met to "do no harm". My concern is that without rigorous training that aligns with discipline-specific standards, APA will be endorsing practices that may cause public harm. This could be resolved with increasing levels of training and competencies required. At a minimum, it should be required to complete a specialist level training for the entry level practice.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Greg	Machek		My opinion, coming from a School Psychology training program, is that an APA MA degree in the HSP subdiscipline of School Psychology potentially undercuts what already exists. Specifically, a minimal level of graduate preparation has been accepted and around for decades, which is a specialist-level of training that aligns with NASP preparation standards. This has been the foundation for graduate training programs as well as state licensure. Creating a "lighter" path to a graduate degree which comes with the APA's imprimatur at the very least could sow confusion and, potentially, could lead to the adoption of APA MA standards for full licensure by SEA licensing boards (and subsequent hiring of these MA professionals instead of those with a specialist degree). It also puts training programs, already based on rigorous NASP standards, in the position of trying to figure out if they need to still offer a full specialist-level of training or whether they just tamp it down to a lighter MA pro...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Shawna	Rader Kelly	National Association of School Psychologists	D.2 - Program Policies and Procedures: Implementation The section references following the “profession’s ethics code.” We recommend that “ethics codes” also reference discipline-specific ethical principles. It would be more appropriate to state the following: All policies and procedures used by the program must be consistent with the profession’s ethics code, as well as the HSP specialty area’s current ethics code. Note that the NASP 2020 Standards, effective July 1, include Principles for Professional Ethics, which define the ethical standards for school psychologists.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Shawna	Rader Kelly	National Association of School Psychologists	D.3. - Evaluation of Students and Program: Documenting and Achieving Outcomes Demonstrating Program’s Effectiveness Without a definition of “master’s degree” or “master’s level,” the requirement for preparing students for “Entry-level practice at the master’s level” is inconsistent with NASP’s established entry-level at the specialist-level for school psychological practice. Note that a specialist-level degree typically goes beyond the requirements of a traditional master’s degree; therefore, a set of standards that does not explicitly define “master’s level” and/or differentiate from a specialist-level degree has the potential to create confusion within the field and among stakeholders. Further, without consistent requirements for graduate preparation within the field of school psychology, the APA will be creating confusion for potential students choosing graduate preparation programs in school psychology, with the availability of programs inconsistent with established standards...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Suzanne	Botana		Please define the set of standards needed for the Masters program, and a model to compare the programs to, so that it is clear what the set of standards are. NASP approved programs go beyond a Master's degree and offer well prepared students for school psychological practice. Differentiating the programs more clearly will avoid confusion within the field and among stakeholders, and will allow students to be informed in deciding to pursue this degree or a NASP approved program which may offer additional standards and competency.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Laurie	Klose		School psychology graduates of MA level programs would not meet licensure/certification requirements in most states.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Kelley	Fillion		D.3. - Without a definition of “master’s degree” or “master’s level,” the requirement for preparing students for “Entry-level practice at the master’s level” is inconsistent with NASP’s established entry-level at the specialist-level for school psychological practice. Note that a specialist-level degree typically goes beyond the requirements of a traditional master’s degree; therefore, a set of standards that does not explicitly define “master’s level” and/or differentiate from a specialist- level degree has the potential to create confusion within the field and among stakeholders. Further, without consistent requirements for graduate preparation within the field of school psychology, the APA will be creating confusion for potential students choosing graduate preparation programs in school psychology, with the availability of programs inconsistent with established standards in the profession, and graduates who will not meet state level credentialing standards in school psycholog...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	David	Lillenstein	Association of School Psychologists of Pennsylvania & The Pennsylvania Psychological Association	Together, the Association of School Psychologists of Pennsylvania (ASPP) and The Pennsylvania Psychological Association (PPA) believe that the proposed outcome of entry-level preparation of HSP master’s program graduates does not apply to school psychology training. There are clear and consistent training standards and certification/licensure requirements across states for entry-level school psychologists, which specify that specialist-level training is required. The HSP outcomes standard specifically identifies a goal of preparing students for “entry-level practice at the master’s level...reflected in student success in achieving licensure, certification, and/or employment after the completion of the program.” This goal is definitionally unattainable in light of current Pennsylvania Department of Education standards for certification, which are based on a specialist-level training model. As proposed, the HSP standards for Master’s-level training in school psychology would not alig...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Brian	McKevitt	Nebraska School Psychologists Association	We are concerned that “entry level practice at the master’s level” is not consistent with training and practice in school psychology and will create confusion between master’s and specialist level training. In Nebraska, all three graduate training programs in school psychology require the specialist degree as the entry level degree, which goes above and beyond the requirements for a master’s degree in terms of coursework, field experience, and research requirements. One is not eligible for certification in Nebraska with just a master’s degree. A master’s degree alone is insufficient for providing training in all elements of school psychology service delivery. Additionally, in Nebraska there is growing confusion regarding the level of training and licensure requirements for master’s level and specialist level professionals as well as the credentialing for work in schools and clinical settings. For instance, master’s level professionals in community counseling and social work are eli...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Dickinson	Emma	Nevada Association of School Psychologists	Statement of concern regarding APA’s accreditation of Health Service Psychology Master’s Degree Programs: Although Nevada is impacted by shortages of school psychologists as is the rest of the nation, we feel it is imperative to adhere to the National Association of School Psychologists (NASP) national standards of preparation of school psychologists. APA’s proposal for accreditation of Health Service Master’s Degree programs (HSP) calls for a minimum of 2 years of graduate level work and one year full-time residency within the program granting the degree, suggesting that one year of coursework would suffice. This is clearly at odds with NASP standards which calls for specialist-level training of a minimum of 60 hours, with a 1200 full time internship, and 600 hours of which require in-school experience. If programs fall short of this standard, it would detract highly from well-trained and experienced individuals with the title of School Psychologist entering the field. It is impe...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Ashley	Arnold		There is already established language that entry-level for school psychology is at the specialist-level. This level of training is beyond a masters level. Without further clarification between masters and specialist level will only lead to confusion. This will impact candidates choosing a graduate program and could ultimately prevent obtaining the credential to practice in that specific state in the field of school psychology.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Teresa	Fritsch		My concerns in the section are related to Documenting and Achieving Outcomes Demonstrating Program's Effectiveness. I think there will be significant confusion in the credentialing offices and in school districts across the nation related to individuals only having a masters level credential when states require specialist level. This will then lead to graduates from these programs not being able to obtain state level credentialing because standards are not set at that level. Again, this require goes in direct conflict with already set NASP Standards for Credentialing and the NASP Practice Model.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Jill	Battal	Massachusetts School Psychologists Association	Section II, D.3 - Documenting and Achieving Outcomes Demonstrating Program’s Effectiveness Further definition of “master’s degree” / “master’s level” is necessary. Without expanding language to articulate that the specialist level degree (beyond a masters) is the entry level requirement for some fields, graduate students could be extremely misled. It is disingenuous to recruit students into graduate programs that are inconsistent with credentialing standards in most states.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Andy	Mogan		School psychologists have been training to the specialist level in order to meet licensure requirements in many states. By not explicitly defining "master's level" or indicating the difference between the specialist-level degree, the APA may inadvertently create confusion for students looking to study school psychology. This could also result in issues with licensure/credentialing bodies and prospective employers.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Pamela	August	Missouri Association of School Psychologists	NASP has developed its own “Principals for Professional Ethics” as party of our practice standards. It would be helpful in recognizing the unique nature of school psychology if it were clarified that there maybe specific ethical codes that would apply to each area of specialization, or at least for school psychology.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Pamela	August	Missouri Association of School Psychologists	The term Master’s Level is not clear to us, and we must stress that the entry level for practice as a school psychologist in Missouri and many states is an Educational Specialist degree which includes 60 credit hours, 600 practicum hours, and a 1200-hour internship. This may exceed some definitions of Master’s Level, and leave trainees with a degree that does not allow them to practice in many areas. NASP has worked hard over many years to establish consistent practice standards in the field of school psychology, and we have worked with the state of Missouri to recognize the school psychology training requirements. To create a new track that does not quite meet those standards could create significant confusion among stakeholders such as graduate students, trainers, hiring school districts, and state educational certification boards.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Kimberly	Sherman		For school psychologists, these standards threaten outcomes (e.g., certification, licensure, and employment) as there is no definition of master's degree (e.g., how many credits?), no mention of the specialist degree, and no specific internship requirements. Many credentialing bodies recognize the specialist level degree (typically 2 years of graduate study and a 1-year internship) as the minimum criteria to be certified or licensed as a school psychologist. In Louisiana, individuals who want to be certified as school psychologists or credentialed as licensed specialists in school psychology, need to complete the equivalent of a specialist degree, consistent with NASP standards.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Jared	Dart	Search Results Web Result with Site Links Virginia Academy of School Psychologists	Representing school psychologists across Virginia, VASP maintains the entry level degree to practice as a School Psychologist should be the EdS specialist degree in which future practitioners are required to earn a minimum of 60 credits hours in the field of school psychology. In addition, specialist level school psychology students must also complete a 1200 hour internship with at least 600 hours completed in a school based setting.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Jared	Dart	Search Results Web Result with SitVirginia Academy of School Psychologists	Representing school psychologists across Virginia, VASP maintains the entry level degree to practice as a School Psychologist should be the EdS specialist degree in which future practitioners are required to earn a minimum of 60 credits hours in the field of school psychology. In addition, specialist level school psychology students must also complete a 1200 hour internship with at least 600 hours completed in a school based setting.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Kirstin	Wilson	Indiana Association of School Psychologists	The National Association of School Psychologists (NASP) practice model is used by many school systems and school psychologists as the basis for a broad based practice. School psychologists need 60 hours of graduate courses in order to gain the knowledge needed to start to engage in the broad based practice outlined by the NASP practice model.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Charles	Archer	Ohio School Psychologists Association	Section II, D.3 - Documenting and Achieving Outcomes Demonstrating Program’s Effectiveness We maintain that the specialist-level degree in school psychology represents the entry-level degree to work as a school psychologist in the United States. The specialist-level degree is distinct from the traditional master’s degree. A specialist-level degree, by definition, requires a minimum of 60 graduate semester hours, including a full-year immersive and integrated internship experience, and often takes a minimum of 3 years of full-time study. The comprehensive range of services described can only be provided by those who receive direct instruction and supervised experience in the delivery of these services in the school setting, as is required by most, if not all School Psychology programs around the country. We also maintain that those providing school psychological services in schools should meet the credentialing requirements to work as a School Psychologist by the appropriate state c...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Darcie	Tramp		Furthermore, it is important that school psychologists have a minimum degree of an Education Specialist. This particular degree includes 60 credit hours, 600 practicum hours, and 1200 internship hours. A Specialist-level degree is a step above a Masters-level degree, and we must not forget the importance of all the training needed to become a highly-qualified school psychologist. Therefore, more clarification is needed for a Master’s Level program, as my definition of Master’s Level does not meet the educational criteria for becoming a sufficiently-trained and competent school psychologist. Once again, if the level of training is not specific, I fear that school psychologists will be neither highly effective nor highly qualified for the work that lies ahead of them.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Kimberly	Adams	Minnesota Association of School Psychology	The Minnesota School Psychology Association (MSPA) opposes that recommendation that a master’s level degree is sufficient for entry into the practice of school psychology. MSPA advocates that a specialist degree is the appropriate entry level for the practice of school psychology. Without further clarification of what is considered a master’s degree, entry to the profession of school psychology at a Master’s level will create confusion for stakeholders (prospective students, licensing bodies, school districts, etc.). Aligning with the NASP Practice Model creates a clear understanding for these stakeholders as to the capacity and breadth of school psychologist’s training and alignment with the NASP Practice Model. Different standards for training will unnecessarily confuse the credentialing process, would mislead stakeholders as to the knowledge, skills, and abilities, and could create a two-tiered system of accreditation.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Holly	Yoke	West Virginia School Psychologists	D.3. - Evaluation of Students and Program: Documenting and Achieving Outcomes Demonstrating Program’s Effectiveness By stating “entry level practice at the master’s level” the APA is inconsistent with NASP and many state credentialing requirements that establish an entry level school psychologist as a specialist-level or equivalent (i.e., Ed.S., MA +45, etc.). This creates confusion within the field, for students, and for state credentialing entities.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Kim	Sherman	Louisiana School Psychological Association	We appreciate that the standards will require documentation of program effectiveness outcomes, but we are concerned that the standards may not support school psychology programs in preparing graduates to achieve the identified outcomes (e.g., certification, licensure, employment) in Louisiana or in many other states. The proposed standards do not clearly define (e.g., in credits or hours) master's degree or internship requirements and there is no mention of specialist-level programs. As in many states, Louisiana's entry-level credentialing criteria for school psychologists require the equivalent of a specialist degree (60 credit hours) and a 1200-hour internship with 600 hours in a school setting. Based on the proposed standards, it would be possible for graduates to complete an APA-accredited master's program in school psychology and remain unqualified for certification, licensure, and employment as a school psychologist in Louisiana and in many other states. As it would be a few yea...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Ginger	Newberg		II. D. 3. These proposed standards are below what is currently required by many state licensing boards (including Texas) and will not allow students of these programs to achieve licensure/certification or employment at the level one would expect after completing a master's degree program in the field of psychology. These standards will allow schools to create subpar degree programs that will ultimately result in a dead end for their students seeking licensure and employment in the field.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Karah	Chapman		D.2 - Program Policies and Procedures: Implementation NASP has developed as a practice standard, “Principles for Professional Ethics”. In recognition of the unique nature of school psychology clarification of the specific ethical codes for application to specialty areas most specifically school psychology would be helpful.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Karah	Chapman		D.3. - Evaluation of Students and Program: Documenting and Achieving Outcomes Demonstrating Program’s Effectiveness The term “Master’s Level” is unclear. The entry level for practice as a school psychologist in my state of Missouri and many other states is an Educational Specialist degree this is inclusive of 60 credit hours, 600 practicum hours, and a 1200-hour internship. This is essential for adequate preparation and may exceed some definitions of Master’s Level. Trainees with this degree would not allow them to receive credentialling or practice freely. NASP has worked tirelessly over many years for consistent practice standards in the field and to create a new track with inadequate requirements would create significant confusions among stakeholders such as graduate students, trainers, hiring school districts, and state educational certification boards.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Bradley	Petry		Documentation of outcomes of a program needs to coincide with the NASP training program definitions and scope and sequence. NASP standards include language specifically related to the NASP practice model alignment, the need for training to NOT terminate in a master's degree, but a specialist degree that is awarded following didactic training and a one full year of specially supervised internship, and the national recognition of school psychology training graduate programs by NASP. Further, without these parameters, there is wide potential for confusion in the public as to what constitutes a school psychology training program that meets the robust standards that are set forth by the professional organization.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	stephanie	sokolosky	Texas Association of Psychological Associates	MPCAC sets forth guidance for standards for Master's training in psychology. The MPCAC document is clear, avoiding the ambiguity of this SoA document.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Moery	Teresa		Section II, D.3: The entry level for school psychologists is the specialist level. There are no current credentialing or employment opportunities for a master's level school psychologist. Allowing a master's level entry level position will cause confusion for employers, practitioners, and licensing offices. These guidelines are not consistent with NASP Standards and do not align with the NASP Practice Model.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Kristen	DeYorio		Evaluating students' competencies and program effectiveness are paramount in providing effective and appropriate education for all professional degree programs.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Jackie	Tyson	Board of Educational Affairs	15. Standard II.D.3 and Standard V.A.2 Relevant to pages 10 (“Documenting and Achieving Outcomes Demonstrating Program’s Effectiveness”) and 16 (“Communication with prospective and current students”): How will the SoA be evaluated within programs and among students? It might be helpful if the authors include some suggestions regarding how the competencies could be articulated for accreditation reviewers (e.g., in syllabi, through assignments in classes/in the program, in professional development seminars, etc.). I imagine it will be evaluated in much the same way the CoA evaluates doctoral programs, but some level of specificity might be helpful for the programs. It seemed that the authors simply acknowledge that aims and competencies can vary between institutions and “professional judgment” will be used to determine if students are successful upon graduation. However, some additional level of detail regarding how those competencies will be evaluated and documented in a master’s progra...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Jackie	Tyson	Board of Educational Affairs	19. Standard II.D.3 and Standard V.A.2 Relevant to pages 10 (“Documenting and Achieving Outcomes Demonstrating Program’s Effectiveness”) and 16 (“Communication with prospective and current students”): How will the SoA be evaluated within programs and among students? It might be helpful if the authors include some suggestions regarding how the competencies could be articulated for accreditation reviewers (e.g., in syllabi, through assignments in classes/in the program, in professional development seminars, etc.). I imagine it will be evaluated in much the same way the CoA evaluates doctoral programs, but some level of specificity might be helpful for the programs. It seemed that the authors simply acknowledge that aims and competencies can vary between institutions and “professional judgment” will be used to determine if students are successful upon graduation. However, some additional level of detail regarding how those competencies will be evaluated and documented in a master’s progra...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Amy	Balmanno	California Association of School Psychologists	D.3 In California, and across the country, many School Psychology programs (more specifically, the universities at which they are offered) are awarding Specialist-Level degrees versus a Masters degree to reflect the entry-level standards of NASP. California does not specifically mention a specific degree requirement; rather, the CTC states "post-baccalaureate degree study consisting of a minimum of 60 semester (or 90 quarter) units in a CA Commission-approved professional preparation program specializing in school psychology." We would recommended alignment of the entry-level definition for School Psychology with NASP's to decrease the likelihood of confusion for potential students.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Dawson	Betty		This document emphasizes empirically based methods, yet many of the descriptions of standards and means of accomplishing them do not lend themselves to measurement.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Dawson	Betty		Credible programs should meet observable, measurable standards of success. This includes setting a realistic expectation for the rate of “success” by its graduates, by measuring the rate of their licensure, certification, and employment. A program which does not meet even a minimum standard for “success” should attempt to determine the cause and create an action plan for improvement.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Erika	Olinger	Oklahoma School Psychological Association	Section II, D.3 The entry-level degree for School Psychology is at the specilist-level, which typically exceeds requirements for a traditional Master's degree. This will create dissonance between the APA and the NASP Standards for Graduate Preparation of School Psychologists (2020), with the potential to affect students, but also stakeholders.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Emily	Klein	Delaware Association of School Psychologists	The Delaware Association of School Psychologists (DASP) wishes to thank the Commission on Accreditation (CoA) for all its thoughtful and hard work on behalf of the education and training of professional psychologists who deliver health service psychological services. We appreciate the CoA’s efforts to address the shortage of mental health professionals by considering accreditation of non-doctoral level programs. With all due respect to the high level of professionalism and the hard work evident in the CoA’s draft standards and processes for accrediting Masters’ degree programs in Health Service Psychology, DASP wishes to submit the following comments/recommendations for consideration. All of these comments/recommendations are specific to the School Psychology branch of Health Services Psychology, in keeping with our area of expertise. D.3. In our review of the proposed accreditation standards, it does not appear that the terms “Masters’ degree” or “Masters’ level” are defined in thi...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Mary	Satchwell	Illinois School Psychologists Association	II.D.3 - Documenting and Achieving Outcomes Demonstrating Program’s Effectiveness Further definition of “master’s degree” / “master’s level” is necessary. Without expanding language to articulate that the specialist level degree (beyond a masters) is the entry level requirement for some fields, graduate students could be extremely misled. It is disingenuous to recruit students into graduate programs that are inconsistent with credentialing standards in most states.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Stephanie	Barbre	Texas Association of School Psychologists	School psychologists must obtain a minimum of 60 graduate semester hours in coursework outlined in the NASP Standards for Graduate Preparation of School Psychologists. As mental health professionals with specialist-level training, we possess the expertise, competency, and skill set necessary to provide comprehensive services to students, families, and schools. Further, our state credentialing standards for licensure to practice school psychology align with the NASP Standards for Graduate Preparation of School Psychologists, and therefore individuals with less than 60 graduate semester hours would be ineligible to apply for licensure. We recommend upholding the specialist-level training required as the standard entry to practice school psychology.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Julene	Robbins	Arizona Association of School Psychologists	The proposed master's level training will result in creating a sub-standard level of training in the field of school psychology. The NASP Practice Model accurately describes required competencies in school psychology practice. It is simply not feasible to provide necessary training in a typical master's level training. Given the established approval process for training programs set by NASP, we encourage the APA CoA to work closely with the NASP Program Approval Board and consider the reciprocity in the program accreditation/approval process. Currently, the NASP accepts the APA accreditation for doctoral programs. A similar reciprocity should be considered.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Jim	Deni		If adopted by current school psychology graduate programs and credentialing bodies, the proposed changes for accreditation by the APA would negatively affect and potentially undermine well-established standards in school psychology and the graduate preparation of school psychologists. School psychology graduate preparation is specialized in its focus and comprehensive in its coverage of domains required for school psychology practice. The SoA document would potentially allow lesser qualified individuals to enter the field as school psychologists, which in turn affects children, families, and school practice. Indeed, the negative implications of the SoA document cannot be overstated - schools, students, families, and many other stakeholders would be impacted given the expanded reliance on schools to provide comprehensive services to an increasingly diverse student population. The SoA document also has no requirement that training is provided by program faculty that have specific trainin...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Jessica	Carranza	Montana Association of School Psychologists (MASP)	D.3. - Evaluation of Students and Program: Documenting and Achieving Outcomes Demonstrating Program’s Effectiveness The requirement for preparing students for practice at the “master’s level” is inconsistent with NASP’s established entry-level at the specialist-level for school psychological practice. A specialist-level degree is unique from a traditional master’s degree and therefore, a set of standards that does not explicitly differentiate from a specialist-level degree has the potential to create confusion within the field and among stakeholders. Further, without consistent requirements for graduate preparation within the field of school psychology, the Standards, as currently proposed, will create undue confusion for potential students choosing graduate preparation programs in school psychology and may potentially result in inconsistencies between requirements for accrediting program and credentialing standards at the state level.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Michelle	Krieger	APAGS	? Page 10 (D, 1. Evaluation of Students’ Competencies) might be strengthened by the addition of guidance around minimum standards for data collection to ensure the outcomes are accurately reflected. For example, that programs aim to collect data for at least 25% of graduates and strive to include a representative sample of students (i.e., that reflects the demographics of the cohort). Guidelines such as these could help ensure that sufficient and representative data is collected, as poor data collection (e.g., only a few students or only single white men) may present an incomplete picture of program outcomes for all students. At a minimum, the guidelines could be strengthened by explicitly stating that programs must be transparent about how the data was collected and its representativeness so potential students or trainees can make informed decisions. ? Page 10 (D, 1, b. Evaluation of Students’ Competencies). We are in strong support of programs documenting students’ outcomes, parti...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Jessica	Mefford	Kansas Association of School Psychologist	The Kansas Association of School Psychologists (KASP) has reviewed the standards for accreditation of Master’s level Health Service Psychologists (HSP) as it relates to the training of potential School Psychologists and HSPs who seek to work in school settings. KASP is concerned that “entry level practice at the master’s level” is not consistent with training and practice in school psychology and will create confusion between master’s and specialist level training. The requirements of a psychology Masters degree in Kansas higher education institutions do not hold to an entry level for school psychology practice. In Kansas, all graduate training programs in school psychology and the credentialing body, KSDE, currently require the specialist degree as the entry level degree, which is more in depth and extensive than requirements for a master’s degree in terms of graduate coursework, field experience requirements and supervision in school settings with regard to practicum and internship, ...	See Full Comment
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	June	Preast	University of Alabama, School Psychology Program	Greater clarity is needed for preparedness for “entry-level practice.” A traditional master’s degree is not the entry level for practice as a school psychologist, while the much more rigorous and comprehensive specialist level training is. It is challenging to assess competencies without a defined scope of practice. This needs to be more clearly defined in the implementing regulations so programs can develop appropriate training experiences and mechanisms for assessing competence. HSP programs preparing for practice in school psychology should require a minimum of 1,200 hour internship in the specialty area of school psychology, with a minimum of 600 hours in a school setting. Direct experience in a school setting remains paramount to effective preparation in school psychology.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	UMMP	Board	Group	D.2: UMMP supports outcome tracking and measures for programs to ensure they are appropriately preparing graduates for independent practice, licensure and the ability to earn a living. Measures and outcomes should be a requirement to provide to prospective students. There needs to be minimum standards set for “success rates” which are not yet specified. There should be a standard in place for reporting measures so there is consistency in the presentation and reporting of the data. UMMP also believes that institutions conferring degrees have a responsibility to monitor matters impacting curricula and licensing. There is a responsibility to further advise prospective students, current students, and graduates/alumni of potential impact and changes to their education and/or licensure.
SoA for Masters Degree	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Shawna	Kelly		The section related to ethics code should also recognize the unique issues that arise in various disciplines within the profession of psychology and reference discipline-specific ethical principles. It would be remiss not to also recognize the HSP specialty area’s current ethics code.
SoA for Masters Degree	III. Students	A. Student Selection Processes and Criteria	Francine	Conway	NCSPP	Although the standards allow a program’s training delivery and design to be part-time, distributed, or predominantly online, the language appears to strongly emphasize having a year of traditional on-ground, full-time delivery of education and training. If it is envisioned that these other delivery systems are a viable option, then the language should more clearly indicate that. However, if this is not envisioned, then the question is the viability and relevance of this program as it does not meet the needs of non-traditional students (who might need the part-time or online delivery).
SoA for Masters Degree	III. Students	A. Student Selection Processes and Criteria	Kristen	DeYorio		I fully support the push for a diverse student body. I am concerned however, that student interest may be difficult to address as HSP is a broader approach to the field of psychology.
SoA for Masters Degree	III. Students	B. Supportive Learning Environment	Jackie	Tyson	Board of Educational Affairs	16. Standard III.B Related to “Supportive Learning Environment,” do faculty role models need to include a master’s-level licensed individual?
SoA for Masters Degree	III. Students	C. Plans to Maximize Student Success	Michelle	Krieger	APAGS	? We appreciate the emphasis on recruitment and retention of diverse students and faculty (Plans to Maximize Student Success, p. 12 & 5. Cultural and Individual Differences and Diversity, p. 15), specifically the distinction between institution level and program level efforts. It may be helpful to provide examples of “specific activities, approaches, and initiatives” that programs can implement. One example that comes to mind for us, includes ongoing training for faculty and external practicum supervisors to examine personal biases or gaps in their own training on cultural diversity, such as training students from a different racial background, or supervising transgender or nonbinary students.
SoA for Masters Degree	III. Students	C. Plans to Maximize Student Success	UMMP	Board	Group	C.3: Feedback is essential to facilitate successful completion of the program. Once per year would not facilitate timely input to make needed adjustments. We recommend that feedback be provided at least bi-annually. Self-assessment should be included as part of this process.
SoA for Masters Degree	IV. Faculty	A. Program Leadership, Administration, and Management	Jackie	Tyson	Board of Educational Affairs	17. We appreciate that in Standard IV.A-B (Program Leadership, Administration and Management /Faculty Qualifications and Role Modeling) that the commission did not specify a requirement for program leadership or program faculty. This flexibility allows programs to have faculty trained at the master’s level. This is important role modeling or master’s students.
SoA for Masters Degree	IV. Faculty	A. Program Leadership, Administration, and Management	Samuel	Song	Council of Directors of School Psychology Programs (CDSPP)	We appreciate that there is not a requirement for program leadership or program faculty. This flexibility allows programs to have faculty trained at the master’s level. This is important role modeling or master’s students.
SoA for Masters Degree	IV. Faculty	A. Program Leadership, Administration, and Management	June	Preast	University of Alabama, School Psychology Program	Greater specificity is needed with regards to faculty credentials, program administration, and faculty sufficiency.
SoA for Masters Degree	IV. Faculty	B. Faculty Qualifications and Role Modeling	Tammy	McClain		I am concerned that requiring diversity among the faculty will be difficult for areas that are primarily rural and have less ethnic diversity, smaller programs, and fewer candidates from which to choose. Rural WV (and probably other states) have their own culture which is quite distinct but often not recognized for its diversity, for example. Because of the shortage of psychologists and the limited funding, attracting candidates is difficult. Requiring diversity in gender, gender identity, sexual orientation, race, ethnicity, age, disability, language, national origin, religion, and socioeconomic status may eliminate strong programs from being accredited since finding qualified applicants willing to move to these more rural areas is already difficult without the requirement to recruit from underrepresented areas of diversity in the state.
SoA for Masters Degree	IV. Faculty	B. Faculty Qualifications and Role Modeling	Shawna	Rader Kelly	National Association of School Psychologists	B.4 – Faculty Sufficiency It would be helpful if the Commission provided an acceptable faculty-to-student ratio.
SoA for Masters Degree	IV. Faculty	B. Faculty Qualifications and Role Modeling	Shawna	Rader Kelly	National Association of School Psychologists	B.4.c – Faculty Sufficiency When describing the need for at least one faculty to hold a license as a psychologist – this should include “and/or an appropriate credential to provide school psychological services in school settings, including the Nationally Certified School Psychologist (NCSP) credential.”
SoA for Masters Degree	IV. Faculty	B. Faculty Qualifications and Role Modeling	Peggy	Brady-Amoon	Alliance for Professional Counselors	IV - We appreciate the inclusive definition of core faculty in this draft. In closing, we extend our sincere appreciation to all involved and thank you for your consideration of our recommendations.
SoA for Masters Degree	IV. Faculty	B. Faculty Qualifications and Role Modeling	Kelley	Fillion		B.4 – Add a faculty-to-student ratio. B.4.c – When describing the need for at least one faculty to hold a license as a psychologist – this should include “and/or an appropriate credential to provide school psychological services in school settings, including the Nationally Certified School Psychologist (NCSP) credential.”
SoA for Masters Degree	IV. Faculty	B. Faculty Qualifications and Role Modeling	Jana	Aupperlee		•The requirements for supervisors are inappropriate. Supervisors need to be trained in their area of specialty (school, counseling, or clinical) AND appropriately credentialed for the work they do. In the case of school psychology, only credentialed school psychologists should supervise students (either state-level credentialing or the NCSP would be acceptable).
SoA for Masters Degree	IV. Faculty	B. Faculty Qualifications and Role Modeling	Pamela	August	Missouri Association of School Psychologists	NASP has specified a minimum faculty to student ratio and that would be helpful to have clarified here as well.
SoA for Masters Degree	IV. Faculty	B. Faculty Qualifications and Role Modeling	Pamela	August	Missouri Association of School Psychologists	In regard to 4c- in addition to professional licensure, faculty in school psychology programs should also be required to hold certification as a school psychologist in their state and/or hold the Nationally Certified School Psychologist credential.
SoA for Masters Degree	IV. Faculty	B. Faculty Qualifications and Role Modeling	Holly	Yoke	West Virginia School Psychologists	B.4 – Faculty Sufficiency WVSPA would appreciate the inclusion of an acceptable faculty to student ratio. B.4.c – Faculty Sufficiency WVSPA believes that when discussing the need for faculty to licensure as a psychologist, this should be expanded to include: “or the appropriate credential to provide school psychological services within school settings.” Many states, such as West Virginia, require credentialing for school psychologists through their state departments of education. Having a license from the state board of examiners of psychology alone may not be sufficient to practice within schools.
SoA for Masters Degree	IV. Faculty	B. Faculty Qualifications and Role Modeling	Karah	Chapman		B.4 – Faculty Sufficiency NASP has specified a minimum faculty to student ratio which would be helpful to have clarified here as well to ensure adequate training to students and ensure trainers provide their service without burnout leading to them leaving the field and thus a lack of available trainers. B.4.c – Faculty Sufficiency In addition to professional licensure, faculty in school psychology programs should also be required to hold certification as a school psychologist in their state and/or hold the Nationally Certified School Psychologist credential.
SoA for Masters Degree	IV. Faculty	B. Faculty Qualifications and Role Modeling	Kristen	DeYorio		I would suggest that programs are required to have faculty with significant experience in each of the three fields that HSP broadly covers. Doing so could help ensure that students are better prepared for all three fields.
SoA for Masters Degree	IV. Faculty	B. Faculty Qualifications and Role Modeling	Jackie	Tyson	Board of Educational Affairs	18. Standard IV.B.4 (Faculty Sufficiency): It would be helpful if the Commission provided an acceptable student-to-faculty ratio.
SoA for Masters Degree	IV. Faculty	B. Faculty Qualifications and Role Modeling	Amy	Balmanno	California Association of School Psychologists	B.4 We would like to see an acceptable faculty-to-student ratio provided by the Commission so that student and program needs are adequately supported. For example, NASP has proposed a ratio of no more than 1:12. Please define an acceptable ratio.
SoA for Masters Degree	IV. Faculty	B. Faculty Qualifications and Role Modeling	Amy	Balmanno	California Association of School Psychologists	B.4.c. In California, the CTC indicates that "qualified" school psychology faculty members "have a minimum of three years of professional practice and are assigned and available to advise applicants and candidates about their academic, professional and personal development, and to assist each candidate’s professional placement." Again, to practice school psychology in CA, one must hold a credential rather than a license. When describing the need for at least one faculty to hold a license as a psychologist, we recommend including "and/or an appropriate credential to provide school psychological services in school settings, including the Nationally Certified School Psychologist (NCSP) credential.
SoA for Masters Degree	IV. Faculty	B. Faculty Qualifications and Role Modeling	Jim	Deni		Again there is no requirement that Core faculty have any training in school psychology. Core faculty having specific degrees and training offer the necessary skill sets to prepare graduates to entry the file of school psychology. In addition such faculty become role models for students entering the file of school psychology.
SoA for Masters Degree	IV. Faculty	B. Faculty Qualifications and Role Modeling	Shawna	Kelly		B.4.c. There is a need for at least one faculty to hold a license as a psychologist but this should include an appropriate credential to practice in a given specialty area, ensuring that training is provided by those with discipline specific knowledge and experience in the settings in which they are training students to practice. For example, in the area of school psychology, the faculty should be trained and credentialed to provide services in a school setting.
SoA for Masters Degree	IV. Faculty	B. Faculty Qualifications and Role Modeling	UMMP	Board	Group	B.4.c: One member is insufficient. A percentage minimum should be established for core faculty having licensure in the jurisdiction(licensure including both at the Master’s and Doctorate level). In general, add measurable/minimum standards for faculty who are supervising clinical training in terms of their years of experience with clinical practice. Minimum standards for supervisory training experience, should also be established.
SoA for Masters Degree	V. Communication Practices	A. Public Disclosure	Amy	Cannava		Public Disclosure should go beyond communication between a graduate program and its students. How will the APA, if master's level credentialing is approved, communicate with State Boards of Psychology so that HSP graduates are able to obtain masters' level state licensure? Having a graduate program HSP credential is meaningless if individual state licensing boards do not accept the credential for private practice.
SoA for Masters Degree	V. Communication Practices	A. Public Disclosure	Lee	Cooper	Association for Behavioral and Cognitive Therapies	Section V.A.1.b. Communication-General Disclosures, programs should state whether they are for-profit vs. not-for-profit status in addition to accreditation status.
SoA for Masters Degree	V. Communication Practices	A. Public Disclosure	Kristen	DeYorio		Comment regarding 2b: By nature of the broad objectives of a degree in HSP, I do not believe that any program will be able to accurately describe its program to students. While the premise of a broader degree makes sense, my experience actually working within one of the specified fields covered under the umbrella of HSP is that this degree will not be widely accepted as adequate training. Based on Alaska State Certification Criteria, which requires that, in order to obtain initial certification in school psychology, an individual must complete 1200 hours of internship in school psychology, with at least 600 of those hours completed on site in preschool or Kindergarten-12th grade programs. As I stated in a previous comment regarding internship training, I believe it will be difficult for students pursuing a degree in Health Service Psychology to secure the appropriate internships needed in order to meet this criteria.
SoA for Masters Degree	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Jana	Aupperlee		•Specialist level programs in school psychology have the potential to be subjected to approval/accreditation from THREE groups: NASP, CAEP, and now APA. This is TOO MUCH regulation and necessitates far too much disparate data collection, reporting, and monitoring. It also poses a huge administrative and financial burden on programs.
SoA for Masters Degree	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Kristen	DeYorio		Accrediting Body should include the national organizations associated with all three professional areas covered by the umbrella of Health Service Psychology.
SoA for Masters Degree	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Janine	Kane		School psychologists are uniquely prepared to provide services to students in SCHOOLS and consult with school personnel and parents in order to design interventions and support instruction for student-specific educational needs, e.g., academics, behavior, etc. in SCHOOL settings. The APA draft for SOA Health Service Psychology Masters Degree should not be considered equivalent to the NASP Standards for school psychologists. The 60-credit specialist level degree is the standard requirement in school psychology, which as a practicing school psychologist I fully support. This degree includes at least 1200 hours of direct supervision by a licensed school psychologist, at least 600 of these hours in SCHOOLS. The number of years required to complete a program is irrelevant – the training required to be an effective school psychologist is above and beyond the level of a masters degree. The HSP Masters Degree does not meet the NASP standards, and will not prepare students in those progr...	See Full Comment
SoA for Masters Degree	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Jim	Deni		The SoA document may also create added confusion to the public, the state board of education licensing and credentialing bodies, school districts, and graduate training programs in school psychology. In North Carolina specifically, there is no Masters’s level entry into school psychology. All specialist-level programs in North Carolina have a nonterminal master’s degree due to state education policies related to practice, salaries, and internship requirements. Such programs would create a tired system of service school psychologist employed at the Masters, specialist and doctoral which would cause confusion by certification and licensure bodies school districts and consumers. The M-HSP would have M-HSP in the field with lesser training.