Accreditation Public Comment System
This project is now closed for new comments.
Document
Section
Item
First Name
Last Name
Group Name
Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Sarah
Getch
The PWCs and the specific behaviors associated with each of them should be bulleted as they are for the internship and postdoc. It seems that APA is resisting using the competency benchmark document to ground the field in level appropriate expectations. It would make sense to standardize the behaviors expected at each level and provide all programs with the same language. Programs can always add behaviors specific to their program, but a baseline would be more than appropriate here.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Nancy
Burke
Psychotherapy Action Network
The APA’s proposed IRs aim to delineate, specify and distinguish those competencies that students in psychology programs must attain at each level of training in order to assure their readiness to encounter and assist actual people in distress. Yet there are glaring omissions in the lists of principles, requirements and outline curricula the document enumerates. The IR regarding profession-wide competency makes clear that its central concern is “a scientific orientation toward psychological knowledge and methods (p. 5).” Knowledge, skills, competence, problem-solving ability and “substantial knowledge of scientific methods, procedures, and practices” are highlighted as foundational benchmarks for clinical capacity. Yet despite this respect for science and research, there is virtually no scientific research to demonstrate that skills-trained, research-experienced students become exemplary clinicians. Meanwhile, the foundational skills of empathy, theoretical sophistication...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Linda
Michaels
I endorse the comments of the Psychotherapy Action Network.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Scott
Pytluk
I fully agree with and endorse the Psychotherapy Action Network's (PsiAn) comment.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Albert
Galves
I am concerned that persons in the age cohort of current doctoral students have a misconception about the nature of the states of being and behaviors that are associated with diagnoses of mental disorders. They believe that such states of being and behaviors are different from reactions to life circumstances and concerns that people have about themselves and their lives. They have been convinced by the advertising of pharmaceutical companies and the ideology of mainstream psychiatry that something extra is going on, that there are chemical imbalances, brain disorders and genetic anomalies that are somehow causing such states of being and behaviors. But there is no scientific evidence that such is the case. There is evidence that such states of being and behaviors are associated with different biochemistry and brain function but that is correlation not causation. It is going to be very difficult for psychologists to help people who are suffering from mental disorders if they don't ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Nancie
Senet
These comments also apply to C-8 I and C-9P APA is succeeding in obliterating the mind from psychology and clinical psychology practice. These new rules for SoA put into place several more pieces of APA’s “losing psychology’s mind”. Psychology has had a long distinguished history as a science of the mind that dates back, in Western culture, to those ancient Greek philosophers who eloquently grappled with the questions about the nature of the human mind and human life within culture. Rather than continuing to expand and build upon our historical roots, APA is shunting to the side the richly elaborated trove of existing knowledge of the mind, as though embarrassed by our philosophical heritage. What the proposed Standards of Accreditation for Health Service Psychology (SoA) training requirements for programs at the doctoral, doctoral internship, and postdoctoral levels does is to eliminate psychology as a study of the mind. It instead instates psychology as the study of behavior,...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Monica
Carsky
I endorse the comments of the Psychotherapy Action Network, and those of Nancie Senet.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Herert
Gross
It is extremely discouraging to see the APA return to classic behaviorism. As a psychiatric resident in 1962-3 I was involved in the so called cognitive revolution participating in a seminar organized by Lyle Jones then editor of Psychometrica, hardly a scientific light-weight. Later at Walter Reed, in 1964, I was asked by a prominent behaviorist to lead a ward using tokens as a way to reinforce non-psychotic behavior. I said I would agree if he got permission to keep the patients at 80% of their body weight because all of his work was based on pigeons kept at 80% of their body weight. The standards seem part of a group-think dedicated to transforming psychology into nomothetic science ignoring the vast clinical history of idiographic research. We now have the power to aggregate studies of individuals and demonstrate that attending to the subjective is a powerful therapeutic method. To "objectify" psychology squares a circle by fiat. These standards ignore the vast unknown subjectiv...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Anne
Alvarez
These comments refer to sections C-8 D, C-8 I, and C-9 P Colleagues have suggested that APA is succeeding in obliterating the mind from psychology and clinical practice. I would add that the over-emphasis on behaviour at the cost of mental and emotional factors contains further great costs. What else is lost is the detailed observation of subtle changes in mood, mental state, in level of severity of depression/despair/ paranoia, of the difference between say, minute flickers of a light in the eye, or in a subjective report. We note the difference, we hope, between manic flight and genuine green shoots of hope, between genuine helplessness and lack of agency versus exploitation of one’s own passivity, and so on. Philip Roth in his novel, I Married a Communist, suggested that politics and literature are not only in an inverse relationship to each other, they are antagonistic. The same could be said of the psychologists’ research and diagnostic skills, their observation of large...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Diana
Concannon
NCSPP
NCSPP appreciates the opportunity to provide feedback to the proposed revisions to IR C-8 D, C-8 I, and C-9 P. The most significant change of IR C-8 D is the removal of elements within each of the PWCs, instead combining these within the narrative paragraph. This is a significant step backwards, and adversely impacts programs. One key step forward with the SoA is the clear bulleted elements, which provide well-defined operational definitions for the competencies that support inter-rater reliability in the reviews and prevents some of the subjectivity that occurred under the G&P. The bullets also allow programs the flexibility to expand beyond these threshold definitions, defining and distinguishing individual programs without compromising the specific knowledge, skills, and attitudes expected of all graduates of doctoral psychology programs. It is notable that the bulleted elements remain for internship and postdoctoral PWCs. We recommend keeping the clear bulleted articulation of the...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Loring
Ingraham
I endorse the NCSPP response.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jerry
Kernes
I endorse the NCSPP response.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jerry
Kernes
I endorse the NCSPP response.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jerry
Kernes
I endorse the NCSPP response.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Laura
Prescott
I endorse the NCSPP response.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Monique
Bowen
I strongly support the comments of both the Psychotherapy Action Network and NCSPP.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Leah
Horvath
I endorse the NCSPP response.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Amanda
Rickard
I fully endorse the comments of the Psychotherapy Action Network, Albert Galves, Nancie Senet, Hevert Gross, and Anne Alvarez. I would like to add that as an early career psychologist I felt completely underprepared to be a clinician (therapy and assessment) from my APA-accredited PsyD program, as the program focused on short-term manualized treatment that I later came to learn is not actually supported by research, especially for long-term improvement. Additionally, the only personality theory taught in the program was the Big Five, so I had to seek out additional postdoctoral training in personality theory and assessment, as well as how it applies to therapy in order to learn what has been omitted from graduate training programs. These proposed changes continue to ignore and devalue important profession-wide foundational skills necessary for therapy and assessment (as delineated by the Psychotherapy Action Network comments). Through my current involvement in training graduate student...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
noemi
ford
I endorse the comments of the Psychotherapy Action Network, and those of Nancie Senet.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Laura
Harvey
I endorse the comments of the Psychotherapy Action Network.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Alyssa
Choi
The CoA must implement clear guidelines regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to huge variability for such training across the country, and programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, we are currently not being adequately trained to be culturally competent. We urge the CoA to provide basic benchmarks for each of the profession-wise competencies and to reevaluate how programs are being assessed in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Allison
Splaun
I endorse the comments made by PsiAn and hope they are fully considered: The APA’s proposed IRs aim to delineate, specify and distinguish those competencies that students in psychology programs must attain at each level of training in order to assure their readiness to encounter and assist actual people in distress. Yet there are glaring omissions in the lists of principles, requirements and outline curricula the document enumerates. The IR regarding profession-wide competency makes clear that its central concern is “a scientific orientation toward psychological knowledge and methods (p. 5).” Knowledge, skills, competence, problem-solving ability and “substantial knowledge of scientific methods, procedures, and practices” are highlighted as foundational benchmarks for clinical capacity. Yet despite this respect for science and research, there is virtually no scientific research to demonstrate that skills-trained, research-experienced students become exemplary clinicians. ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Stephanie
Torres
Having clinical training committee faculty, who do not regularly engage in diversity, equity, inclusivity, and social justice continuing education courses, is an ethical problem. Given that cultural competency is a dynamic and ongoing process, a lack of consistent training perpetuates poor and/or inaccurate clinical assessment, interventions, and services with historically oppressed or marginalized groups. The significance of this is underlined by research demonstrating that historically oppressed and marginalized groups are in the most need of psychological services.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Steen
halling
I share the concerns of the Psychotherapy Actions Network re the deemphasis on the relational and psychodynamic aspects of psychotherapy and the apparent overconfidence in "science." Effective psychotherapy requires, at least at times, creativity and responsiveness beyond what anyone of us have found in texts. Yes, openness to self-awareness and to supervision are certainly critical, so it great that you emphasize these dimensions, and knowledge of literature and research is also important, but the definition of the above should include case studies and qualitative research which is more experientially relevant
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Steen
halling
I share the concerns of the Psychotherapy Actions Network re the deemphasis on the relational and psychodynamic aspects of psychotherapy and the apparent overconfidence in "science." Effective psychotherapy requires, at least at times, creativity and responsiveness beyond what anyone of us have found in texts. Yes, openness to self-awareness and to supervision are certainly critical, so it great that you emphasize these dimensions, and knowledge of literature and research is also important, but the definition of the above should include case studies and qualitative research which is more experientially relevant
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Enrico
Gnaulati
In what the OPCA means by "grounded in the empirical literature", (as far as approved clinical treatments candidates are required to show proficiency in) gives central credence to clinical relationship building and client improvement based (not on symptom reduction) on overall social and emotional well-being, this would be ethical because the literature substantiates these as strong client preferences (and therefore solidly ethical). Anything short of this means the OPCA runs the risk of promoting unethical practice: See my article in the Journal of Humanistic Psychology: E. Gnaulati: Overlooked Ethical Problems Associated With the Research and Practice of Evidence-Based Treatments
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Todd
DuBose
I applaud the move to consistent diversity in intervention (e.g., "Interventions may be derived from a variety of theoretical orientations or approaches), but, as typical, the DSKs are psychometrically biased, ironically, and definitions of science, evidence, empiricism, method, measurement and outcomes, to be both consistent with diversity and "scientific" competency, must be plural and diverse themselves: scienceS, evidenceS, empiricismS, methodS, outcomeS. Competency in interpreting lived meaning must have equal respect as does stats. What psychologist face in everyday clinical encounters are issues of lived meaning, and we YET have a profession wide honoring of this reality (statistic and lived).
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Michelle
Schultz
I support the comments of both the Psychotherapy Action Network and NCSPP.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Amber
Fox
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. S...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Emma
Parrish
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Emma
Parrish
There is a significant need for the development and dissemination of clinical research within historically oppressed and marginalized groups, especially BIPOC individuals. Given this need, research methodology and statistical courses within training programs should focus on how to recruit, work alongside, develop relevant research questions, utilize the appropriate research methodology and statistics, accurately interpret the data and disseminate research within BIPOC communities. Such skills are rarely discussed compared to research methodology used with conventional samples, like undergraduate or WEIRD (Western, educated, industrialized, rich, and democratic) samples (which have been used in the majority of psychology research studies). As it stands now, training programs largely develop graduate student researchers who primarily work with undergraduate/WEIRD rather than marginalized populations, despite there being greater need for the latter. Further, we encourage the CoA to articu...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Emma
Parrish
Programs should be required to report diversity initiatives. While programs are likely to start new diversity initiatives prior to a program evaluation, they should be listed by stage of implementation (e.g., planning vs. completed stages). This would allow site visitors to systematically evaluate the program’s environment for commitment towards diversity, equity, inclusivity and social justice.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Emma
Parrish
The CoA should explicitly include cultural competency and cultural humility as professional values. Doctoral students should also be required to complete specific trainings examining their own biases, culture, and values that influence their interactions with clients, with the goal of eliminating beliefs that their perspectives are universal. In addition, doctoral students should be required to engage in trainings or activities to increase their cultural competency/humility, and trainings and activities should be made available to students by their training programs.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Emma
Parrish
Communication and interpersonal styles vary by cultural background. As the national psychological graduate student and faculty bodies increase in BIPOC representation, faculty involved in clinical training of doctoral students will need cultural humility training more than ever. Additionally, current ideas of professional language and concepts, which is dominated by a white perspective, will need to be re-examined. Faculty will need to obtain additional training on the significant stress of “code-switching” that BIPOC trainees and faculty experience when expected to be “professional”, how “professionalism” has been used against BIPOC trainees and faculty, how a clinician’s “professional” communication style may impact the recruitment of BIPOC participants and how BIPOC individuals may be deterred in seeking out services in program clinics. Finally, the CoA needs to develop a system of evaluating how students will demonstrate knowledge and implementation of culturally competent communic...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Emma
Parrish
Doctoral students must also demonstrate competency in how cultural factors impact human behavior and, therefore, the role of culture in assessments (e.g., cross-cultural validity) and the interpretation of results. Programs must outline how doctoral students are being trained in assessing human behaviour across people of different cultural backgrounds and ethnicities. This should be a requirement for all trainees and not just those who are interested in cross-cultural psychology. All trainees at some point in their career will provide psychological services to populations different from their own and, therefore, competency in cross-cultural assessment should be an expectation and requirement for APA accredited programs.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Emma
Parrish
The CoA should explicitly define “culturally-informed”. Doctoral students should demonstrate competency in incorporating cultural factors when deriving interventions for clients. Doctoral students should also be trained to implement interventions that have been validated among individuals from the same cultural groups as the clients. Doctoral students should demonstrate understanding of the role of cultural factors in the client’s response to the intervention, and they should implement routine evaluation of this throughout treatment.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Emma
Parrish
As an integral part of a trainee’s clinical skills and competency, all faculty serving as clinical training supervisors should be held to the same if not higher cultural competency and humility training standards and benchmarks as their trainees. Supervisors should be culturally competent, per benchmarks set forth by the CoA, on how to implement culturally-informed assessments, interventions, and supervision practices. Given that the second required element for meeting the Supervision profession-wide competency (PWC) is not standardized and is at the discretion of each individual program (thus creating variability in training), the CoA should require that the second element of the Supervision PWC to be the following: Doctoral students should demonstrate knowledge of diversity considerations in supervision. Directors of Clinial Training need to be trained on how to advocate for students if an externship is not meeting diversity training benchmarks or if an externship is demonstrating bi...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jack
Andrews
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Kaitlyn
Dillon
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Nancy
Dang
I agree with Amber Fox's comment.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Nancy
Dang
I agree with Emma Parrish's comment.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jeannie
Ahn
I endorse all of Emma Parrish's comments.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Aashna
Aggarwal
I endorse Amber Fox's comments. Sincerely, A doctoral student in an APA-accredited program.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Erika
Trent
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Alexandra
Convertino
I agree with and endorse Emma Parrish’s comments.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Zachary
Greth
I agree with/endorse the Psychotherapy Action Networks’s comment. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Rachael
Tillman
I endorse all of the comments from Emma Parrish, Kaitlyn Dillon, Amber Fox, Stephanie Torres, and Alyssa Choi. To repeat the global sentiment: The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. As Stephanie Torres noted, this becomes an ethical...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Claire
Kaplan
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Rose
O'Brien
I agree with the comments of Jack Andrews, Erika Trent, Rachael Tilman, Claire Kaplan, Alyssa Choi, Amber Fox, Emma Parish, and Kaitlyn Dillon. Seconding these sentiments, doctoral students must demonstrate competency in how cultural factors impact human behavior and, therefore, the role of culture in assessments (e.g., cross-cultural validity) and the interpretation of results. Programs must outline how doctoral students are being trained in assessing human behavior across people of different cultural backgrounds and ethnicities. This should be a requirement for all trainees and not just those who are interested in cross-cultural psychology. All trainees at some point in their career will provide psychological services to populations different from their own and, therefore, competency in cross-cultural assessment should be an expectation and requirement for APA accredited programs. Furthermore, The CoA should explicitly define “culturally-informed”. Doctoral students should demonstrat...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Colleen
Kase
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Colleen
Kase
The CoA should explicitly include cultural competency and cultural humility as professional values. Doctoral students should also be required to complete specific trainings examining their own biases, culture, and values that influence their interactions with clients, with the goal of eliminating beliefs that their perspectives are universal. In addition, doctoral students should be required to engage in trainings or activities to increase their cultural competency/humility, and trainings and activities should be made available to students by their training programs. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Haley
Bell
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Haley
Bell
There is a significant need for the development and dissemination of clinical research within historically oppressed and marginalized groups, especially BIPOC individuals. Given this need, research methodology and statistical courses within training programs should focus on how to recruit, work alongside, develop relevant research questions, utilize the appropriate research methodology and statistics, accurately interpret the data and disseminate research within BIPOC communities. Such skills are rarely discussed compared to research methodology used with conventional samples, like undergraduate or WEIRD (Western, educated, industrialized, rich, and democratic) samples (which have been used in the majority of psychology research studies). As it stands now, training programs largely develop graduate student researchers who primarily work with undergraduate/WEIRD rather than marginalized populations, despite there being greater need for the latter. Further, we encourage the CoA to articu...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Haley
Bell
With the ever increasing diversity of patients and clinicians, ethics courses need to be taught from a multicultural perspective. For example, when teaching APA ethics codes, topics needing a multicultural lens include boundary issues, self-disclosure, touch, bartering, and multiple relationships. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Haley
Bell
Programs should be required to report diversity initiatives. While programs are likely to start new diversity initiatives prior to a program evaluation, they should be listed by stage of implementation (e.g., planning vs. completed stages). This would allow site visitors to systematically evaluate the program’s environment for commitment towards diversity, equity, inclusivity and social justice. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Haley
Bell
The CoA should explicitly include cultural competency and cultural humility as professional values. Doctoral students should also be required to complete specific trainings examining their own biases, culture, and values that influence their interactions with clients, with the goal of eliminating beliefs that their perspectives are universal. In addition, doctoral students should be required to engage in trainings or activities to increase their cultural competency/humility, and trainings and activities should be made available to students by their training programs. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Haley
Bell
Doctoral students must also demonstrate competency in how cultural factors impact human behavior and, therefore, the role of culture in assessments (e.g., cross-cultural validity) and the interpretation of results. Programs must outline how doctoral students are being trained in assessing human behaviour across people of different cultural backgrounds and ethnicities. This should be a requirement for all trainees and not just those who are interested in cross-cultural psychology. All trainees at some point in their career will provide psychological services to populations different from their own and, therefore, competency in cross-cultural assessment should be an expectation and requirement for APA accredited programs. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Haley
Bell
The CoA should explicitly define “culturally-informed”. Doctoral students should demonstrate competency in incorporating cultural factors when deriving interventions for clients. Doctoral students should also be trained to implement interventions that have been validated among individuals from the same cultural groups as the clients. Doctoral students should demonstrate understanding of the role of cultural factors in the client’s response to the intervention, and they should implement routine evaluation of this throughout treatment. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Haley
Bell
As an integral part of a trainee’s clinical skills and competency, all faculty serving as clinical training supervisors should be held to the same if not higher cultural competency and humility training standards and benchmarks as their trainees. Supervisors should be culturally competent, per benchmarks set forth by the CoA, on how to implement culturally-informed assessments, interventions, and supervision practices. Given that the second required element for meeting the Supervision profession-wide competency (PWC) is not standardized and is at the discretion of each individual program (thus creating variability in training), the CoA should require that the second element of the Supervision PWC to be the following: Doctoral students should demonstrate knowledge of diversity considerations in supervision. Directors of Clinial Training need to be trained on how to advocate for students if an externship is not meeting diversity training benchmarks or if an externship is demonstrating bi...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Basanti
Prince
I fully endorse the comments by the NCSPP and the Psychotherapy Action Network.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Greta
Jankauskaite
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Vargas
Jacob
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Amy
Violante
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Molly
Wilkinson
I endorse Emma Parrish's comment. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Alonzo
Howard
No one individual will be an expert in all cultural groups and culturally informed assessments and interventions. Therefore, CoA should develop a widespread network of consultants who are experts in evidence-based and culturally competent training practices (i.e., for both intervention and assessment). These consultants should develop training videos and offer recorded webinars that will be freely accessible to all students, faculty, and staff of all APA-accredited programs. APA should also allocate funds/develop a budget for these consultants, who likely will be primarily BIPOC, for this service. If faculty serve as consultants, consultations should be required by CoA as part of their official faculty duties and integrated into their paid time (i.e., not an additional voluntary task), and when possible and under their supervision, trainees should be given opportunities to also serve as consultants. Such efforts would simultaneously improve care for BIPOC clients, train students in con...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Shelley
Kind
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training S...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jennifer
Mazzola
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Melissa
Liu
No one individual will be an expert in all cultural groups and culturally informed assessments and interventions. Therefore, CoA should develop a widespread network of consultants who are experts in evidence-based and culturally competent training practices (i.e., for both intervention and assessment). These consultants should develop training videos and offer recorded webinars that will be freely accessible to all students, faculty, and staff of all APA-accredited programs. APA should also allocate funds/develop a budget for these consultants, who likely will be primarily BIPOC, for this service. If faculty serve as consultants, consultations should be required by CoA as part of their official faculty duties and integrated into their paid time (i.e., not an additional voluntary task), and when possible and under their supervision, trainees should be given opportunities to also serve as consultants. Such efforts would simultaneously improve care for BIPOC clients, train students in con...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Lissa
Mandell
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. S...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Monica
Dennis
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Monica
Dennis
he CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. Si...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Christie
Pickel
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Christie
Pickel
As a doctoral student of an APA-accredited program, I strongly endorse Alexandra Convertino's comment about voluntary exit interviews with students who prematurely leave their programs.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Summer
Millwood
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Summer
Millwood
he CoA should explicitly include cultural competency and cultural humility as professional values. Doctoral students should also be required to complete specific trainings examining their own biases, culture, and values that influence their interactions with clients, with the goal of eliminating beliefs that their perspectives are universal. In addition, doctoral students should be required to engage in trainings or activities to increase their cultural competency/humility, and trainings and activities should be made available to students by their training programs. Sincerely, A doctoral student of color in an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Samantha
Hoffman
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. S...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Alexander
Cao
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Alyssa
Choi
There is a significant need for the development and dissemination of clinical research within historically oppressed and marginalized groups, especially BIPOC individuals. Given this need, research methodology and statistical courses within training programs should focus on how to recruit, work alongside, develop relevant research questions, utilize the appropriate research methodology and statistics, accurately interpret the data and disseminate research within BIPOC communities. Such skills are rarely discussed compared to research methodology used with conventional samples, like undergraduate or WEIRD (Western, educated, industrialized, rich, and democratic) samples (which have been used in the majority of psychology research studies). As it stands now, training programs largely develop graduate student researchers who primarily work with undergraduate/WEIRD rather than marginalized populations, despite there being greater need for the latter. Further, we encourage the CoA to articu...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Alyssa
Choi
With the ever increasing diversity of patients and clinicians, ethics courses need to be taught from a multicultural perspective. For example, when teaching APA ethics codes, topics needing a multicultural lens include boundary issues, self-disclosure, touch, bartering, and multiple relationships. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Alyssa
Choi
Programs should be required to report diversity initiatives. While programs are likely to start new diversity initiatives prior to a program evaluation, they should be listed by stage of implementation (e.g., planning vs. completed stages). This would allow site visitors to systematically evaluate the program’s environment for commitment towards diversity, equity, inclusivity and social justice. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Samantha
Hoffman
There is a significant need for the development and dissemination of clinical research within historically oppressed and marginalized groups, especially BIPOC individuals. Given this need, research methodology and statistical courses within training programs should focus on how to recruit, work alongside, develop relevant research questions, utilize the appropriate research methodology and statistics, accurately interpret the data and disseminate research within BIPOC communities. Such skills are rarely discussed compared to research methodology used with conventional samples, like undergraduate or WEIRD (Western, educated, industrialized, rich, and democratic) samples (which have been used in the majority of psychology research studies). As it stands now, training programs largely develop graduate student researchers who primarily work with undergraduate/WEIRD rather than marginalized populations, despite there being greater need for the latter. Further, we encourage the CoA to articu...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Alyssa
Choi
The CoA should explicitly include cultural competency and cultural humility as professional values. Doctoral students should also be required to complete specific trainings examining their own biases, culture, and values that influence their interactions with clients, with the goal of eliminating beliefs that their perspectives are universal. In addition, doctoral students should be required to engage in trainings or activities to increase their cultural competency/humility, and trainings and activities should be made available to students by their training programs. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Alyssa
Choi
Communication and interpersonal styles vary by cultural background. As the national psychological graduate student and faculty bodies increase in BIPOC representation, faculty involved in clinical training of doctoral students will need cultural humility training more than ever. Additionally, current ideas of professional language and concepts, which is dominated by a white perspective, will need to be re-examined. Faculty will need to obtain additional training on the significant stress of “code-switching” that BIPOC trainees and faculty experience when expected to be “professional”, how “professionalism” has been used against BIPOC trainees and faculty, how a clinician’s “professional” communication style may impact the recruitment of BIPOC participants and how BIPOC individuals may be deterred in seeking out services in program clinics. Finally, the CoA needs to develop a system of evaluating how students will demonstrate knowledge and implementation of culturally competent communic...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Samantha
Hoffman
With the ever increasing diversity of patients and clinicians, ethics courses need to be taught from a multicultural perspective. For example, when teaching APA ethics codes, topics needing a multicultural lens include boundary issues, self-disclosure, touch, bartering, and multiple relationships. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Samantha
Hoffman
Programs should be required to report diversity initiatives. While programs are likely to start new diversity initiatives prior to a program evaluation, they should be listed by stage of implementation (e.g., planning vs. completed stages). This would allow site visitors to systematically evaluate the program’s environment for commitment towards diversity, equity, inclusivity and social justice. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Samantha
Hoffman
The CoA should explicitly include cultural competency and cultural humility as professional values. Doctoral students should also be required to complete specific trainings examining their own biases, culture, and values that influence their interactions with clients, with the goal of eliminating beliefs that their perspectives are universal. In addition, doctoral students should be required to engage in trainings or activities to increase their cultural competency/humility, and trainings and activities should be made available to students by their training programs. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Alyssa
Choi
Doctoral students must also demonstrate competency in how cultural factors impact human behavior and, therefore, the role of culture in assessments (e.g., cross-cultural validity) and the interpretation of results. Programs must outline how doctoral students are being trained in assessing human behaviour across people of different cultural backgrounds and ethnicities. This should be a requirement for all trainees and not just those who are interested in cross-cultural psychology. All trainees at some point in their career will provide psychological services to populations different from their own and, therefore, competency in cross-cultural assessment should be an expectation and requirement for APA accredited programs. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Samantha
Hoffman
Communication and interpersonal styles vary by cultural background. As the national psychological graduate student and faculty bodies increase in BIPOC representation, faculty involved in clinical training of doctoral students will need cultural humility training more than ever. Additionally, current ideas of professional language and concepts, which is dominated by a white perspective, will need to be re-examined. Faculty will need to obtain additional training on the significant stress of “code-switching” that BIPOC trainees and faculty experience when expected to be “professional”, how “professionalism” has been used against BIPOC trainees and faculty, how a clinician’s “professional” communication style may impact the recruitment of BIPOC participants and how BIPOC individuals may be deterred in seeking out services in program clinics. Finally, the CoA needs to develop a system of evaluating how students will demonstrate knowledge and implementation of culturally competent communic...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Samantha
Hoffman
Doctoral students must also demonstrate competency in how cultural factors impact human behavior and, therefore, the role of culture in assessments (e.g., cross-cultural validity) and the interpretation of results. Programs must outline how doctoral students are being trained in assessing human behaviour across people of different cultural backgrounds and ethnicities. This should be a requirement for all trainees and not just those who are interested in cross-cultural psychology. All trainees at some point in their career will provide psychological services to populations different from their own and, therefore, competency in cross-cultural assessment should be an expectation and requirement for APA accredited programs. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Samantha
Hoffman
The CoA should explicitly define “culturally-informed”. Doctoral students should demonstrate competency in incorporating cultural factors when deriving interventions for clients. Doctoral students should also be trained to implement interventions that have been validated among individuals from the same cultural groups as the clients. Doctoral students should demonstrate understanding of the role of cultural factors in the client’s response to the intervention, and they should implement routine evaluation of this throughout treatment. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Samantha
Hoffman
As an integral part of a trainee’s clinical skills and competency, all faculty serving as clinical training supervisors should be held to the same if not higher cultural competency and humility training standards and benchmarks as their trainees. Supervisors should be culturally competent, per benchmarks set forth by the CoA, on how to implement culturally-informed assessments, interventions, and supervision practices. Given that the second required element for meeting the Supervision profession-wide competency (PWC) is not standardized and is at the discretion of each individual program (thus creating variability in training), the CoA should require that the second element of the Supervision PWC to be the following: Doctoral students should demonstrate knowledge of diversity considerations in supervision. Directors of Clinial Training need to be trained on how to advocate for students if an externship is not meeting diversity training benchmarks or if an externship is demonstrating bi...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Samantha
Hoffman
No one individual will be an expert in all cultural groups and culturally informed assessments and interventions. Therefore, CoA should develop a widespread network of consultants who are experts in evidence-based and culturally competent training practices (i.e., for both intervention and assessment). These consultants should develop training videos and offer recorded webinars that will be freely accessible to all students, faculty, and staff of all APA-accredited programs. APA should also allocate funds/develop a budget for these consultants, who likely will be primarily BIPOC, for this service. If faculty serve as consultants, consultations should be required by CoA as part of their official faculty duties and integrated into their paid time (i.e., not an additional voluntary task), and when possible and under their supervision, trainees should be given opportunities to also serve as consultants. Such efforts would simultaneously improve care for BIPOC clients, train students in con...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Alyssa
Choi
The CoA should explicitly define “culturally-informed”. Doctoral students should demonstrate competency in incorporating cultural factors when deriving interventions for clients. Doctoral students should also be trained to implement interventions that have been validated among individuals from the same cultural groups as the clients. Doctoral students should demonstrate understanding of the role of cultural factors in the client’s response to the intervention, and they should implement routine evaluation of this throughout treatment. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Alyssa
Choi
As an integral part of a trainee’s clinical skills and competency, all faculty serving as clinical training supervisors should be held to the same if not higher cultural competency and humility training standards and benchmarks as their trainees. Supervisors should be culturally competent, per benchmarks set forth by the CoA, on how to implement culturally-informed assessments, interventions, and supervision practices. Given that the second required element for meeting the Supervision profession-wide competency (PWC) is not standardized and is at the discretion of each individual program (thus creating variability in training), the CoA should require that the second element of the Supervision PWC to be the following: Doctoral students should demonstrate knowledge of diversity considerations in supervision. Directors of Clinial Training need to be trained on how to advocate for students if an externship is not meeting diversity training benchmarks or if an externship is demonstrating bi...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Alyssa
Choi
No one individual will be an expert in all cultural groups and culturally informed assessments and interventions. Therefore, CoA should develop a widespread network of consultants who are experts in evidence-based and culturally competent training practices (i.e., for both intervention and assessment). These consultants should develop training videos and offer recorded webinars that will be freely accessible to all students, faculty, and staff of all APA-accredited programs. APA should also allocate funds/develop a budget for these consultants, who likely will be primarily BIPOC, for this service. If faculty serve as consultants, consultations should be required by CoA as part of their official faculty duties and integrated into their paid time (i.e., not an additional voluntary task), and when possible and under their supervision, trainees should be given opportunities to also serve as consultants. Such efforts would simultaneously improve care for BIPOC clients, train students in con...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Catherine
Sumida
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Catherine
Sumida
Competency 1-Research: There is a significant need for the development and dissemination of clinical research within historically oppressed and marginalized groups, especially BIPOC individuals. Given this need, research methodology and statistical courses within training programs should focus on how to recruit, work alongside, develop relevant research questions, utilize the appropriate research methodology and statistics, accurately interpret the data and disseminate research within BIPOC communities. Such skills are rarely discussed compared to research methodology used with conventional samples, like undergraduate or WEIRD (Western, educated, industrialized, rich, and democratic) samples (which have been used in the majority of psychology research studies). As it stands now, training programs largely develop graduate student researchers who primarily work with undergraduate/WEIRD rather than marginalized populations, despite there being greater need for the latter. Further, we enco...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Catherine
Sumida
Competency 2- With the ever increasing diversity of patients and clinicians, ethics courses need to be taught from a multicultural perspective. For example, when teaching APA ethics codes, topics needing a multicultural lens include boundary issues, self-disclosure, touch, bartering, and multiple relationships.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Catherine
Sumida
Competency 3- Effectiveness in health service psychology requires that doctoral students develop the ability to conduct all professional activities with sensitivity to human diversity, including the ability to deliver high quality services to an increasingly diverse population. Therefore, doctoral students must demonstrate knowledge, awareness, sensitivity, and skills when working with diverse individuals and communities who embody a variety of cultural and personal background and characteristics across all professional activities. Students must also have an understanding of how their own personal/cultural history, attitudes, and biases may affect how they understand and interact with people different from themselves. The Commission on Accreditation defines cultural and individual differences and diversity as including, but not limited to, age, disability, ethnicity, gender, gender identity, language, national origin, race, religion, culture, sexual orientation, and socioeconomic statu...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Catherine
Sumida
Competency 4- The CoA should explicitly include cultural competency and cultural humility as professional values. Doctoral students should also be required to complete specific trainings examining their own biases, culture, and values that influence their interactions with clients, with the goal of eliminating beliefs that their perspectives are universal. In addition, doctoral students should be required to engage in trainings or activities to increase their cultural competency/humility, and trainings and activities should be made available to students by their training programs.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Catherine
Sumida
Competency 5- Communication and interpersonal styles vary by cultural background. As the national psychological graduate student and faculty bodies increase in BIPOC representation, faculty involved in clinical training of doctoral students will need cultural humility training more than ever. Additionally, current ideas of professional language and concepts, which is dominated by a white perspective, will need to be re-examined. Faculty will need to obtain additional training on the significant stress of “code-switching” that BIPOC trainees and faculty experience when expected to be “professional”, how “professionalism” has been used against BIPOC trainees and faculty, how a clinician’s “professional” communication style may impact the recruitment of BIPOC participants and how BIPOC individuals may be deterred in seeking out services in program clinics. Finally, the CoA needs to develop a system of evaluating how students will demonstrate knowledge and implementation of culturally comp...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Catherine
Sumida
Competency 6- Doctoral students must also demonstrate competency in how cultural factors impact human behavior and, therefore, the role of culture in assessments (e.g., cross-cultural validity) and the interpretation of results. Programs must outline how doctoral students are being trained in assessing human behaviour across people of different cultural backgrounds and ethnicities. This should be a requirement for all trainees and not just those who are interested in cross-cultural psychology. All trainees at some point in their career will provide psychological services to populations different from their own and, therefore, competency in cross-cultural assessment should be an expectation and requirement for APA accredited programs.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Catherine
Sumida
Competency 7 - The CoA should explicitly define “culturally-informed”. Doctoral students should demonstrate competency in incorporating cultural factors when deriving interventions for clients. Doctoral students should also be trained to implement interventions that have been validated among individuals from the same cultural groups as the clients. Doctoral students should demonstrate understanding of the role of cultural factors in the client’s response to the intervention, and they should implement routine evaluation of this throughout treatment.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Catherine
Sumida
Competency 8 - As an integral part of a trainee’s clinical skills and competency, all faculty serving as clinical training supervisors should be held to the same if not higher cultural competency and humility training standards and benchmarks as their trainees. Supervisors should be culturally competent, per benchmarks set forth by the CoA, on how to implement culturally-informed assessments, interventions, and supervision practices. Given that the second required element for meeting the Supervision profession-wide competency (PWC) is not standardized and is at the discretion of each individual program (thus creating variability in training), the CoA should require that the second element of the Supervision PWC to be the following: Doctoral students should demonstrate knowledge of diversity considerations in supervision. Directors of Clinial Training need to be trained on how to advocate for students if an externship is not meeting diversity training benchmarks or if an externship is d...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Catherine
Sumida
Competency 9 - No one individual will be an expert in all cultural groups and culturally informed assessments and interventions. Therefore, CoA should develop a widespread network of consultants who are experts in evidence-based and culturally competent training practices (i.e., for both intervention and assessment). These consultants should develop training videos and offer recorded webinars that will be freely accessible to all students, faculty, and staff of all APA-accredited programs. APA should also allocate funds/develop a budget for these consultants, who likely will be primarily BIPOC, for this service. If faculty serve as consultants, consultations should be required by CoA as part of their official faculty duties and integrated into their paid time (i.e., not an additional voluntary task), and when possible and under their supervision, trainees should be given opportunities to also serve as consultants. Such efforts would simultaneously improve care for BIPOC clients, train ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Gregory
Keiser
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Babetta
Mathai
I agree with and endorse comments made by Alyssa Choi, Emma Parrish, and Amber Fox.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Madeline
Brodt
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Leigh
Andrews
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Luisa
Mader
As an integral part of a trainee’s clinical skills and competency, all faculty serving as clinical training supervisors should be held to the same if not higher cultural competency and humility training standards and benchmarks as their trainees. Supervisors should be culturally competent, per benchmarks set forth by the CoA, on how to implement culturally-informed assessments, interventions, and supervision practices. Given that the second required element for meeting the Supervision profession-wide competency (PWC) is not standardized and is at the discretion of each individual program (thus creating variability in training), the CoA should require that the second element of the Supervision PWC to be the following: Doctoral students should demonstrate knowledge of diversity considerations in supervision. Directors of Clinial Training need to be trained on how to advocate for students if an externship is not meeting diversity training benchmarks or if an externship is demonstrating bi...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Luisa
Mader
There is a significant need for the development and dissemination of clinical research within historically oppressed and marginalized groups, especially BIPOC individuals. Given this need, research methodology and statistical courses within training programs should focus on how to recruit, work alongside, develop relevant research questions, utilize the appropriate research methodology and statistics, accurately interpret the data and disseminate research within BIPOC communities. Such skills are rarely discussed compared to research methodology used with conventional samples, like undergraduate or WEIRD (Western, educated, industrialized, rich, and democratic) samples (which have been used in the majority of psychology research studies). As it stands now, training programs largely develop graduate student researchers who primarily work with undergraduate/WEIRD rather than marginalized populations, despite there being greater need for the latter. Further, we encourage the CoA to articu...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Elisa
Dumett
There is a significant need for the development and dissemination of clinical research within historically oppressed and marginalized groups, especially BIPOC individuals. Given this need, research methodology and statistical courses within training programs should focus on how to recruit, work alongside, develop relevant research questions, utilize the appropriate research methodology and statistics, accurately interpret the data and disseminate research within BIPOC communities. Such skills are rarely discussed compared to research methodology used with conventional samples, like undergraduate or WEIRD (Western, educated, industrialized, rich, and democratic) samples (which have been used in the majority of psychology research studies). As it stands now, training programs largely develop graduate student researchers who primarily work with undergraduate/WEIRD rather than marginalized populations, despite there being greater need for the latter. Further, we encourage the CoA to articu...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Laura
Long
No one individual will be an expert in all cultural groups and culturally informed assessments and interventions. Therefore, CoA should develop a widespread network of consultants who are experts in evidence-based and culturally competent training practices (i.e., for both intervention and assessment). These consultants should develop training videos and offer recorded webinars that will be freely accessible to all students, faculty, and staff of all APA-accredited programs. APA should also allocate funds/develop a budget for these consultants, who likely will be primarily BIPOC, for this service. If faculty serve as consultants, consultations should be required by CoA as part of their official faculty duties and integrated into their paid time (i.e., not an additional voluntary task), and when possible and under their supervision, trainees should be given opportunities to also serve as consultants. Such efforts would simultaneously improve care for BIPOC clients, train students in con...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Elizabeth
Raines
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic, measurable benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Laura
Harvey
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jennifer
Pearlstein
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jennifer
Pearlstein
There is a significant need for the development and dissemination of clinical research within historically oppressed and marginalized groups, especially BIPOC individuals. Given this need, research methodology and statistical courses within training programs should focus on how to recruit, work alongside, develop relevant research questions, utilize the appropriate research methodology and statistics, accurately interpret the data and disseminate research within BIPOC communities. Such skills are rarely discussed compared to research methodology used with conventional samples, like undergraduate or WEIRD (Western, educated, industrialized, rich, and democratic) samples (which have been used in the majority of psychology research studies). As it stands now, training programs largely develop graduate student researchers who primarily work with undergraduate/WEIRD rather than marginalized populations, despite there being greater need for the latter. Further, we encourage the CoA to articu...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jennifer
Pearlstein
With the ever increasing diversity of patients and clinicians, ethics courses need to be taught from a multicultural perspective. For example, when teaching APA ethics codes, topics needing a multicultural lens include boundary issues, self-disclosure, touch, bartering, and multiple relationships.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jennifer
Pearlstein
Programs should be required to report diversity initiatives. While programs are likely to start new diversity initiatives prior to a program evaluation, they should be listed by stage of implementation (e.g., planning vs. completed stages). This would allow site visitors to systematically evaluate the program’s environment for commitment towards diversity, equity, inclusivity and social justice.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jennifer
Pearlstein
The CoA should explicitly include cultural competency and cultural humility as professional values. Doctoral students should also be required to complete specific trainings examining their own biases, culture, and values that influence their interactions with clients, with the goal of eliminating beliefs that their perspectives are universal. In addition, doctoral students should be required to engage in trainings or activities to increase their cultural competency/humility, and trainings and activities should be made available to students by their training programs.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jennifer
Pearlstein
Communication and interpersonal styles vary by cultural background. As the national psychological graduate student and faculty bodies increase in BIPOC representation, faculty involved in clinical training of doctoral students will need cultural humility training more than ever. Additionally, current ideas of professional language and concepts, which is dominated by a white perspective, will need to be re-examined. Faculty will need to obtain additional training on the significant stress of “code-switching” that BIPOC trainees and faculty experience when expected to be “professional”, how “professionalism” has been used against BIPOC trainees and faculty, how a clinician’s “professional” communication style may impact the recruitment of BIPOC participants and how BIPOC individuals may be deterred in seeking out services in program clinics. Finally, the CoA needs to develop a system of evaluating how students will demonstrate knowledge and implementation of culturally competent communic...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jennifer
Pearlstein
The CoA should explicitly define “culturally-informed”. Doctoral students should demonstrate competency in incorporating cultural factors when deriving interventions for clients. Doctoral students should also be trained to implement interventions that have been validated among individuals from the same cultural groups as the clients. Doctoral students should demonstrate understanding of the role of cultural factors in the client’s response to the intervention, and they should implement routine evaluation of this throughout treatment.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jennifer
Pearlstein
As an integral part of a trainee’s clinical skills and competency, all faculty serving as clinical training supervisors should be held to the same if not higher cultural competency and humility training standards and benchmarks as their trainees. Supervisors should be culturally competent, per benchmarks set forth by the CoA, on how to implement culturally-informed assessments, interventions, and supervision practices. Given that the second required element for meeting the Supervision profession-wide competency (PWC) is not standardized and is at the discretion of each individual program (thus creating variability in training), the CoA should require that the second element of the Supervision PWC to be the following: Doctoral students should demonstrate knowledge of diversity considerations in supervision. Directors of Clinial Training need to be trained on how to advocate for students if an externship is not meeting diversity training benchmarks or if an externship is demonstrating bi...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jennifer
Pearlstein
No one individual will be an expert in all cultural groups and culturally informed assessments and interventions. Therefore, CoA should develop a widespread network of consultants who are experts in evidence-based and culturally competent training practices (i.e., for both intervention and assessment). These consultants should develop training videos and offer recorded webinars that will be freely accessible to all students, faculty, and staff of all APA-accredited programs. APA should also allocate funds/develop a budget for these consultants, who likely will be primarily BIPOC, for this service. If faculty serve as consultants, consultations should be required by CoA as part of their official faculty duties and integrated into their paid time (i.e., not an additional voluntary task), and when possible and under their supervision, trainees should be given opportunities to also serve as consultants. Such efforts would simultaneously improve care for BIPOC clients, train students in con...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Paula
Floyd
I strongly agree with comments made by Emma Parrish above.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Tabitha
Sellers
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Tabitha
Sellers
Programs should be required to report diversity initiatives. While programs are likely to start new diversity initiatives prior to a program evaluation, they should be listed by stage of implementation (e.g., planning vs. completed stages). This would allow site visitors to systematically evaluate the program’s environment for commitment towards diversity, equity, inclusivity and social justice
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Tabitha
Sellers
The CoA should explicitly include cultural competency and cultural humility as professional values. Doctoral students should also be required to complete specific trainings examining their own biases, culture, and values that influence their interactions with clients, with the goal of eliminating beliefs that their perspectives are universal. In addition, doctoral students should be required to engage in trainings or activities to increase their cultural competency/humility, and trainings and activities should be made available to students by their training programs.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Maria
Jimenez-Salazar
I endorse Emma Parrish's comment. Sincerely, a doctoral student of an APA-accredited program.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Anny
Reyes
I agree with endorse Catherine Sumida’s comments. Sincerely, a doctoral student of an APA-accredited program.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Sarah
Curtis
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Sarah
Curtis
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Shirley
Segarra
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. S...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Dominique
Reminick
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Aurora
Brinkman
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. I...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Aurora
Brinkman
With the ever increasing diversity of patients and clinicians, ethics courses need to be taught from a multicultural perspective. For example, when teaching APA ethics codes, topics needing a multicultural lens include boundary issues, self-disclosure, touch, bartering, and multiple relationships. In addition, information about communication with individuals with disabilities must also be taught. People with disabilities are often talked down to or assumptions are made about their abilities. Addressing this in ethics class and framing this communication as a dignity and ethical issue is vital.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Aurora
Brinkman
Programs should be required to report diversity initiatives. While programs are likely to start new diversity initiatives prior to a program evaluation, they should be listed by stage of implementation (e.g., planning vs. completed stages). This would allow site visitors to systematically evaluate the program’s environment for commitment towards diversity, equity, inclusivity and social justice. Students and faculty must be encouraged to collaborate and communicate about initiatives to support and uplift individuals of diverse identities and backgrounds.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Aurora
Brinkman
The CoA should explicitly include cultural competency and cultural humility as professional values. Doctoral students should also be required to complete specific trainings examining their own biases, culture, and values that influence their interactions with clients, with the goal of eliminating beliefs that their perspectives are universal. In addition, doctoral students should be required to engage in trainings or activities to increase their cultural competency/humility, and trainings and activities should be made available to students by their training programs. In addition, students and faculty must be required to undergo training about mental illness and disability stigma and how this may affect their perceptions and interactions with their clients.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Aurora
Brinkman
Communication and interpersonal styles vary by cultural background. As the national psychological graduate student and faculty bodies increase in BIPOC representation, faculty involved in clinical training of doctoral students will need cultural humility training more than ever. Additionally, current ideas of professional language and concepts, which is dominated by a white perspective, will need to be re-examined. Faculty will need to obtain additional training on the significant stress of “code-switching” that BIPOC trainees and faculty experience when expected to be “professional”, how “professionalism” has been used against BIPOC trainees and faculty, how a clinician’s “professional” communication style may impact the recruitment of BIPOC participants and how BIPOC individuals may be deterred in seeking out services in program clinics. Finally, the CoA needs to develop a system of evaluating how students will demonstrate knowledge and implementation of culturally competent communic...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Aurora
Brinkman
Strength-based assessment and case conceptualization should be taught and encouraged. Clients are typically viewed through a deficit model. Valuing an individual's strengths encourages their growth, dignity, and worth. Understanding how assessment perpetuates the medical model of disability and is ableist is also vital. Doctoral students must also demonstrate competency in how cultural factors impact human behavior and, therefore, the role of culture in assessments (e.g., cross-cultural validity) and the interpretation of results. Programs must outline how doctoral students are being trained in assessing human behaviour across people of different cultural backgrounds and ethnicities. This should be a requirement for all trainees and not just those who are interested in cross-cultural psychology. All trainees at some point in their career will provide psychological services to populations different from their own and, therefore, competency in cross-cultural assessment should be an expe...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Aurora
Brinkman
It is important to recognize systemic injustice and oppression and how that may affect an individual's mental and physical health and their access or response to interventions. Rather than seeing race or disability as a barrier to treatment, racism and ableism must be identified as the barriers. The CoA should explicitly define “culturally-informed”. Doctoral students should demonstrate competency in incorporating cultural factors when deriving interventions for clients. Doctoral students should also be trained to implement interventions that have been validated among individuals from the same cultural groups as the clients. Doctoral students should demonstrate understanding of the role of cultural factors in the client’s response to the intervention, and they should implement routine evaluation of this throughout treatment.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Aurora
Brinkman
As an integral part of a trainee’s clinical skills and competency, all faculty serving as clinical training supervisors should be held to the same if not higher cultural competency and humility training standards and benchmarks as their trainees. Supervisors should be culturally competent, per benchmarks set forth by the CoA, on how to implement culturally-informed assessments, interventions, and supervision practices. Given that the second required element for meeting the Supervision profession-wide competency (PWC) is not standardized and is at the discretion of each individual program (thus creating variability in training), the CoA should require that the second element of the Supervision PWC to be the following: Doctoral students should demonstrate knowledge of diversity considerations in supervision. Directors of Clinial Training need to be trained on how to advocate for students if an externship is not meeting diversity training benchmarks or if an externship is demonstrating bi...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Aurora
Brinkman
No one individual will be an expert in all cultural groups and culturally informed assessments and interventions. Therefore, CoA should develop a widespread network of consultants who are experts in evidence-based and culturally competent training practices (i.e., for both intervention and assessment). These consultants should develop training videos and offer recorded webinars that will be freely accessible to all students, faculty, and staff of all APA-accredited programs. APA should also allocate funds/develop a budget for these consultants, who likely will be primarily BIPOC, for this service. If faculty serve as consultants, consultations should be required by CoA as part of their official faculty duties and integrated into their paid time (i.e., not an additional voluntary task), and when possible and under their supervision, trainees should be given opportunities to also serve as consultants. Such efforts would simultaneously improve care for BIPOC clients, train students in con...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Dean
Mark
My concern about many of the changes that are being implemented by the APA generally are that they are continuing a problematic trend that becomes evident when supervising therapists that have emerged from institutions promoting "evidence-based" and "scientifically supported" approaches to the therapeutic encounter. Such approaches emphasize "technique" over personal competency in being able to respond to the client in the immediacy of the therapeutic encounter. Graduates of such institutions as are following such guidelines appear to be being taught the art of psychotherapy by statistical researchers who, in compliance with the APA's emphasis on a scientific basis, are emphasizing annualized approaches to the therapy process in seeming accordance with the evidence-based and scientifically oriented mandates. Unfortunately when the highly scripted approaches fail, as they invariably can and will, such graduates appear at a complete loss to handle cases. One of the inevitable results of ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Kristopher
Benke
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Rebecca
Denson
There is a significant need for the development and dissemination of clinical research within historically oppressed and marginalized groups, especially BIPOC individuals. Given this need, research methodology and statistical courses within training programs should focus on how to recruit, work alongside, develop relevant research questions, utilize the appropriate research methodology and statistics, accurately interpret the data and disseminate research within BIPOC communities. Such skills are rarely discussed compared to research methodology used with conventional samples, like undergraduate or WEIRD (Western, educated, industrialized, rich, and democratic) samples (which have been used in the majority of psychology research studies). As it stands now, training programs largely develop graduate student researchers who primarily work with undergraduate/WEIRD rather than marginalized populations, despite there being greater need for the latter. Further, we encourage the CoA to articu...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jessica
Mandell
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Kate
Hull
I endorse the comment left by several individuals, most recently Emma Parrish, regarding the necessity of developing and disseminating clinical research within historically oppressed and marginalized groups, especially BIPOC communities.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Julia
Thomas
There is a significant need for the development and dissemination of clinical research within historically oppressed and marginalized groups, especially BIPOC individuals. Given this need, research methodology and statistical courses within training programs should focus on how to recruit, work alongside, develop relevant research questions, utilize the appropriate research methodology and statistics, accurately interpret the data and disseminate research within BIPOC communities. Such skills are rarely discussed compared to research methodology used with conventional samples, like undergraduate or Western, educated, industrialized, rich, and democratic samples (which have been used in the majority of psychology research studies). As it stands now, training programs largely develop graduate student researchers who primarily work with these groups rather than marginalized populations, despite there being greater need for the latter. Further, we encourage the CoA to articulate clear stan...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Ellora
Vilkin
I endorse the comments of my colleagues who have urged the CoA to implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to re...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Ellora
Vilkin
Echoing my colleagues, There is a significant need for the development and dissemination of clinical research within historically oppressed and marginalized groups, especially BIPOC individuals. Given this need, research methodology and statistical courses within training programs should focus on how to recruit, work alongside, develop relevant research questions, utilize the appropriate research methodology and statistics, accurately interpret the data and disseminate research within BIPOC communities. Such skills are rarely discussed compared to research methodology used with conventional samples, like undergraduate or WEIRD (Western, educated, industrialized, rich, and democratic) samples (which have been used in the majority of psychology research studies). As it stands now, training programs largely develop graduate student researchers who primarily work with undergraduate/WEIRD rather than marginalized populations, despite there being greater need for the latter. Further, we enco...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Ellora
Vilkin
I agree with the comments of others here that programs should be required to report diversity initiatives. While programs are likely to start new diversity initiatives prior to a program evaluation, they should be listed by stage of implementation (e.g., planning vs. completed stages). This would allow site visitors to systematically evaluate the program’s environment for commitment towards diversity, equity, inclusivity and social justice. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Ellora
Vilkin
I agree with my colleagues who have stated that The CoA should explicitly include cultural competency and cultural humility as professional values. Doctoral students should also be required to complete specific trainings examining their own biases, culture, and values that influence their interactions with clients, with the goal of eliminating beliefs that their perspectives are universal. In addition, doctoral students should be required to engage in trainings or activities to increase their cultural competency/humility, and trainings and activities should be made available to students by their training programs. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Ellora
Vilkin
In order to better understand the reasons why students prematurely leave APA accredited PhD programs and to improve attrition rates within programs, CoA should develop a subcommittee that provides and conducts voluntary exit interviews with all students. CoA should also develop a document explaining the purpose of such exit interviews. DCTs should be required to provide this document to students and obtain a signature from the student stating that they understand the opportunity. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Lia
Smith
This is a very important issue and I am thankful for the opportunity to publicly comment. With regards to research competencies, there is a significant need for the development and dissemination of clinical research within historically oppressed and marginalized groups, especially BIPOC individuals. Given this need, research methodology and statistical courses within training programs should focus on how to recruit, work alongside, develop relevant research questions, utilize the appropriate research methodology and statistics, accurately interpret the data and disseminate research within BIPOC communities. Such skills are rarely discussed compared to research methodology used with conventional samples, like undergraduate or WEIRD (Western, educated, industrialized, rich, and democratic) samples (which have been used in the majority of psychology research studies). As it stands now, training programs largely develop graduate student researchers who primarily work with undergraduate/WEI...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Lia
Smith
As a doctoral student in an APA-accredited program, I believe that the CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these be...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Eliza
Davidson
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Hannah
Becker
I endorse Emma Parrish's comments. Sincerely, a doctoral student of an APA-accredited program.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jacob
Smith
The CoA should explicitly include cultural competency and cultural humility as professional values. Doctoral students should also be required to complete specific trainings examining their own biases, culture, and values that influence their interactions with clients, with the goal of eliminating beliefs that their perspectives are universal. In addition, doctoral students should be required to engage in trainings or activities to increase their cultural competency/humility, and trainings and activities should be made available to students by their training programs.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
A
N
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Neda
Neshat
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Caitlin
Knudsen
Programs should be required to report diversity initiatives. While programs are likely to start new diversity initiatives prior to a program evaluation, they should be listed by stage of implementation (e.g., planning vs. completed stages). This would allow site visitors to systematically evaluate the program’s environment for commitment towards diversity, equity, inclusivity and social justice.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jennifer
Rios
I endorse the comments of the Psychotherapy Action Network, and those of Nancie Senet.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Evan
Mayo-Wilson
I’d consider a broader approach, which is that training should equip practitioners to understand and apply the principles of evidence-based practice (i.e., incorporate best current evidence, client values and preferences, practitioner expertise) and to appraise the methods used to generate evidence (e.g., clinical trials, systematic reviews of clinical trials). Although this might be beyond the scope of what you’re asking today, I’d replace fuzzy terms like “empirical literature” (which includes many things that aren’t reliable evidence) and indicate that trainees should know how to critically appraise evidence about the causal effects of the interventions they might provide/prescribe. The last point (B.ii.) comes close, but it should clarify that we’re trying to make “causal inferences” and it should replace “meta-analyses” with “systematic reviews and meta-analyses of intervention effects” (because meta-analysis should normally be done as a component of a systematic review, and empha...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Bruce
Bobbitt
APA Measurement-Based Care and Mental & Behavioral Health Registry Advisory Committee
As the Chair of the APA Measurement-Based Care and Mental & Behavioral Health Registry advisory committee, I present these comments on behalf of the entire committee. Charted by APA in 2017, the committee currently consists of 10 psychologists with extensive experience in clinical care, measurement, and the use of outcomes in practice (our initial work is summarized in Wright et. al. (2020)). While the use of routine monitoring of critical clinical measures is becoming the norm across many areas of healthcare and medicine, adoption of routine outcome monitoring is slow to develop in behavioral health and psychology despite our long history of distinction in measurement and psychological assessment. Because the use of outcome monitoring will become an expected part of all healthcare, we believe that measurement based care should be a required component of all APA programs. Thus, we see the inclusion of measurement based care in the doctoral level curriculum as well as formal HSP cl...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Margarita
Torres
“In order to better understand the reasons why students prematurely leave APA accredited PhD programs and to improve attrition rates within programs, CoA should develop a subcommittee that provides and conducts voluntary exit interviews with all students. CoA should also develop a document explaining the purpose of such exit interviews. DCTs should be required to provide this document to students and obtain a signature from the student stating that they understand the opportunity. ”
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Margarita
Torres
“In addition to monitoring the attrition rate of each program, CoA should separately monitor the diversity factors of the students who leave the program. For example, programs should be required to report the proportion of students from minority backgrounds out of all students who leave their program. CoA needs to develop a system for programs that protects the identity of students who leave when reporting this information. Further, CoA should monitor how programs address diversity concerns in attrition as stated in section III.C.1. of APA Accreditation Self-Study (e.g., flawed admission procedures or unsupportive learning environments).”
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Theodore
Ellenhorn
I strongly support the comments of the Psychotherapy Action Network and NCSPP
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Anne
Malkoff
I strongly endorse Alyssa Choi's comment. Sincerely, a doctoral student of an APA-accredited program.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Magro
Sophia
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Magro
Sophia
Programs should be required to report diversity initiatives. While programs are likely to start new diversity initiatives prior to a program evaluation, they should be listed by stage of implementation (e.g., planning vs. completed stages). This would allow site visitors to systematically evaluate the program’s environment for commitment towards diversity, equity, inclusivity and social justice.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Magro
Sophia
Communication and interpersonal styles vary by cultural background. As the national psychological graduate student and faculty bodies increase in BIPOC representation, faculty involved in clinical training of doctoral students will need cultural humility training more than ever. Additionally, current ideas of professional language and concepts, which is dominated by a white perspective, will need to be re-examined. Faculty will need to obtain additional training on the significant stress of “code-switching” that BIPOC trainees and faculty experience when expected to be “professional”, how “professionalism” has been used against BIPOC trainees and faculty, how a clinician’s “professional” communication style may impact the recruitment of BIPOC participants and how BIPOC individuals may be deterred in seeking out services in program clinics. Finally, the CoA needs to develop a system of evaluating how students will demonstrate knowledge and implementation of culturally competent communic...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Magro
Sophia
Doctoral students must also demonstrate competency in how cultural factors impact human behavior and, therefore, the role of culture in assessments (e.g., cross-cultural validity) and the interpretation of results. Programs must outline how doctoral students are being trained in assessing human behaviour across people of different cultural backgrounds and ethnicities. This should be a requirement for all trainees and not just those who are interested in cross-cultural psychology. All trainees at some point in their career will provide psychological services to populations different from their own and, therefore, competency in cross-cultural assessment should be an expectation and requirement for APA accredited programs.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Magro
Sophia
Interdisciplinary research is likely the best available methodology capable of achieving health equity. For this reason, CoA should collaborate with different researcher teams currently conducting interdisciplinary work and develop training videos that can be disseminated by Directors of Clinical Training to students, staff, and faculty. The CoA should develop a benchmark for what constitutes an interdisciplinary team.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Orlowski
Edmund
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jacob
Marzalik
Advisory Steering Committee for Development of Clinical Practice Guidelines
Clinical practice guidelines provide specific recommendations about treatment for particular disorders and conditions, are based on a systematic review of the available quality evidence and include an evaluation of the benefits versus potential harms of treatment. Clinical practice guidelines have become an increasingly important part of healthcare. In 2010, APA began an initiative to develop these clinical practice guidelines with the first guideline development panel forming in 2012. APA now has multiple clinical practice guidelines with more underway (https://www.apa.org/about/offices/directorates/guidelines/clinical-practice). Clinical practice guidelines are an essential part of evidence based practice in psychology, as they help the busy provider to quickly understand the available quality evidence about potential treatments while the provider also uses their clinical expertise in the context of patients’ values, culture, and preferences. We recommend that familiarit...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jamie
Smith
I endorse Elizabeth Bownes's comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Lauren
Eales
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. S...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Elisa
Carsten
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Sarah
Boland
There is a significant need for the development and dissemination of clinical research within historically oppressed and marginalized groups, especially BIPOC individuals. Given this need, research methodology and statistical courses within training programs should focus on how to recruit, work alongside, develop relevant research questions, utilize the appropriate research methodology and statistics, accurately interpret the data and disseminate research within BIPOC communities. Such skills are rarely discussed compared to research methodology used with conventional samples, like undergraduate or WEIRD (Western, educated, industrialized, rich, and democratic) samples (which have been used in the majority of psychology research studies). As it stands now, training programs largely develop graduate student researchers who primarily work with undergraduate/WEIRD rather than marginalized populations, despite there being greater need for the latter. Further, we encourage the CoA to articu...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Victoria
Atzl
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. S...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Emily
Wilson
No one individual will be an expert in all cultural groups and culturally informed assessments and interventions. Therefore, CoA should develop a widespread network of consultants who are experts in evidence-based and culturally competent training practices (i.e., for both intervention and assessment). These consultants should develop training videos and offer recorded webinars that will be freely accessible to all students, faculty, and staff of all APA-accredited programs. APA should also allocate funds/develop a budget for these consultants, who likely will be primarily BIPOC, for this service. If faculty serve as consultants, consultations should be required by CoA as part of their official faculty duties and integrated into their paid time (i.e., not an additional voluntary task), and when possible and under their supervision, trainees should be given opportunities to also serve as consultants. Such efforts would simultaneously improve care for BIPOC clients, train students in con...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Matthew
Murray
I endorse all of the comments from Emma Parrish, Kaitlyn Dillon, Amber Fox, Stephanie Torres, and Alyssa Choi. There is significant variability in diversity and inclusion training across doctoral programs and further, significant access barriers for students of marginalized identities to apply to, accept positions in, and succeed in doctoral programs. Benchmarks need to be established and evaluated systematically to ensure that cultural humility becomes both a point of education as well as a foundation of equitable culture across doctoral programs and the professional sphere. It is insufficient to rely on research and educational materials that are primarily construed from the same lens that upholds these systemic barriers across programs. Guidelines for programs and subsequent commitments must be made to first diversify the field and then provide education around sensitivity, self-awareness, and socially just clinical research and practice to shape and advance equity, which is related...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Mary
MacLennan
The CoA must specify how it evaluates student performance, and the minimum level of achievement or performance that is required of the student to demonstrate competency. Programs must demonstrate how their evaluation methods and minimum levels of achievement are appropriate for the measurement of each competency. The level of achievement expected must reflect the current standards for the profession.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Juan
Peña
Competency IV: The CoA should explicitly include cultural competency and cultural humility as professional values. Doctoral students should also be required to complete specific trainings examining their own biases, culture, and values that influence their interactions with clients, with the goal of eliminating beliefs that their perspectives are universal. In addition, doctoral students should be required to engage in trainings or activities to increase their cultural competency/humility, and trainings and activities should be made available to students by their training programs. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Andrea
Ochoa Lopez
I agree with Alyssa Choi's comment. The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Mariam
Hussain
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Caitlin
McCann
I am deeply concerned with the lack of consistency in the DEI training in doctoral programs, as well as the lack of accountability that doctoral programs seem to have in terms of meeting these demands. The APA claims that they are holding programs to these requirements as a part of their APA accreditation but in reality, there are many institutions who are maintaining APA accreditation when their faculty and adjunct professors are not appropriately trained to teach from a DEI and culturally aware lens, and don't appear to be seeking out that training in any meaningful way. I implore the APA to hold themselves to their own standards and to consider withholding ongoing APA accreditation from institutions who are not meeting ethical standards of teaching and training with regard to a culturally-informed lens. Lastly, how is the APA ensuring that an institution is in fact creating a safe and supportive environment for BIPOC students when they are conducting their APA accreditation review? ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jason
Washburn
Council of University Directors of Clinical Psychology
The CUDCP Board greatly appreciates the opportunity to comment on the proposed changes to doctoral, internship, and postdoctoral competencies in IRs C-8 D, C-8 I, and C-9 P. Given the focus of the CUDCP Board on doctoral level training, our comments will be focused exclusively on C-8 D. The lack of a red-line version of the modified IRs made review of the changes difficult. The CUDCP Board requests that future proposed changes be provided to the public for comment with an additional red-line version to avoid the need to compare documents line-by-line. It is the CUDCP Board’s understanding that the CoA is proposing to keep the “Level-appropriate training” focused specifically on doctoral-level training, rather than on doctoral- and internship-level training. It is also our understanding that the new version removes the “bullet” lists and aims to make the expectations within the PWCs more concise. The CUDCP Board also noted that the revision defines readiness for internship a...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Melanie
Tran
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Munazza
Abraham
"The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training" ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Annemarie
Slobig
I fully endorse the comments by the NCSPP and the Psychotherapy Action Network
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Christina
Verzijl
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Munazza
Abraham
I. ON Research- "There is a significant need for the development and dissemination of clinical research within historically oppressed and marginalized groups, especially BIPOC individuals. Given this need, research methodology and statistical courses within training programs should focus on how to recruit, work alongside, develop relevant research questions, utilize the appropriate research methodology and statistics, accurately interpret the data and disseminate research within BIPOC communities. Such skills are rarely discussed compared to research methodology used with conventional samples, like undergraduate or WEIRD (Western, educated, industrialized, rich, and democratic) samples (which have been used in the majority of psychology research studies). As it stands now, training programs largely develop graduate student researchers who primarily work with undergraduate/WEIRD rather than marginalized populations, despite there being greater need for the latter. Further, we encourage ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Morgan
M
"The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training"
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Greg
Chasson
As the DCT of Illinois Tech, I strongly endorse and echo CUDCP's statement re IR C-8 D.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Melissa
LaCelle
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Ilex
Beltran-Najera
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. S...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jenny
Phan
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 D. Profession-Wide Competencies
Jenny
Phan
Competency 1: There is a significant need for the development and dissemination of clinical research within historically oppressed and marginalized groups, especially BIPOC individuals. Given this need, research methodology and statistical courses within training programs should focus on how to recruit, work alongside, develop relevant research questions, utilize the appropriate research methodology and statistics, accurately interpret the data and disseminate research within BIPOC communities. Such skills are rarely discussed compared to research methodology used with conventional samples, like undergraduate or WEIRD (Western, educated, industrialized, rich, and democratic) samples (which have been used in the majority of psychology research studies). As it stands now, training programs largely develop graduate student researchers who primarily work with undergraduate/WEIRD rather than marginalized populations, despite there being greater need for the latter. Further, we encourage the...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Kurt
Freeman
Thank you for the opportunity to provide public comment to proposed revisions to IR C-8I. With this proposed revision, the CoA appears to be attempting greater specificity regarding expected performance. 1. Defining MLA: This revision includes explicit definition of Readiness for Entry Level Practice". With the statement of "Ability to independently function in a broad range of clinical and professional activities." the CoA is encouraged to consider whether more nuance to this statement is needed given that most internships continue to occur within jurisdictions that require supervised postdoctoral experiences prior to licensure. While it is true that the number of jurisdictions that allow for licensure upon completion of doctoral degree (inclusive of internship), it is not even yet 1/2 of states. I suspect internship programs will struggle with how to reconcile CoA's definition of "independence" with state licensure laws (and statements in the Standards that an internship program...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Diana
Concannon
NCSPP
NCSPP agrees with separating the doctoral and internship elements from C-8 D and C-8 I, as it makes both logical sense and improves clarity. This revision of C-8 D does not address two problems within the doctoral PWCs. The relationship element is listed across two PWCs (communication and interpersonal, and intervention) and the supervision PWC only has one element (but the CoA expectation is that there will be two elements).
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Leah
Horvath
I endorse the NCSPP response.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Kirk
Schneider
I support in principle the critique of PsiAN (the Psychotherapy Action Network) which calls for a deeper, more inclusive scope of criteria for training effectiveness, based on a very prominent base of psychotherapeutic outcome research as evinced by investigators such as Wampold, Norcross, Brown, Courtois, and Shedler that emphasizes contextual-relational factors as integral to therapeutic effectiveness. This means that there is an over-reliance on medical-like methodologies (e.g., RCT's) for the evaluation of treatments and by implication training protocols to the neglect of our own psychologically based effectiveness data to characterize "evidence-based" in these proposed guidelines. The result is that highly important therapeutic dimensions, such as the trainee's capacity to be present to, empathize with, ally with, provide hope for, and be genuine with clients is conspicuously missing, along with bona fide therapeutic orientations such as existential-humanism and psychoanalysis...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Michelle
Schultz
I strongly support the comments of NCSPP.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Sue
Darnley
There is a significant need for the development and dissemination of clinical research within historically oppressed and marginalized groups, especially BIPOC individuals. Given this need, research methodology and statistical courses within training programs should focus on how to recruit, work alongside, develop relevant research questions, utilize the appropriate research methodology and statistics, accurately interpret the data and disseminate research within BIPOC communities. Such skills are rarely discussed compared to research methodology used with conventional samples, like undergraduate or WEIRD (Western, educated, industrialized, rich, and democratic) samples (which have been used in the majority of psychology research studies). As it stands now, training programs largely develop graduate student researchers who primarily work with undergraduate/WEIRD rather than marginalized populations, despite there being greater need for the latter. Further, we encourage the CoA to articu...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Amelia
Pellegrini
The CoA should explicitly include cultural competency and cultural humility as professional values. Doctoral students should also be required to complete specific trainings examining their own biases, culture, and values that influence their interactions with clients, with the goal of eliminating beliefs that their perspectives are universal. In addition, doctoral students should be required to engage in trainings or activities to increase their cultural competency/humility, and trainings and activities should be made available to students by their training programs.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Kristen
Regenauer
There is a significant need for the development and dissemination of clinical research within historically oppressed and marginalized groups, especially BIPOC individuals. Given this need, research methodology and statistical courses within training programs should focus on how to recruit, work alongside, develop relevant research questions, utilize the appropriate research methodology and statistics, accurately interpret the data and disseminate research within BIPOC communities. Such skills are rarely discussed compared to research methodology used with conventional samples, like undergraduate or WEIRD (Western, educated, industrialized, rich, and democratic) samples (which have been used in the majority of psychology research studies). As it stands now, training programs largely develop graduate student researchers who primarily work with undergraduate/WEIRD rather than marginalized populations, despite there being greater need for the latter. Further, we encourage the CoA to articu...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Cassandra
Jensen
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Emmett
Larsen
I endorse the comments made by Emma Parish. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Sari
Rosenberg
Shared Vision Psychological Services, Inc.
Our organization fully agrees with and endorses the Psychotherapy Action Network's (PsiAn) comment.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Alexandra
Tabachnick
The CoA should explicitly include cultural competency and cultural humility as professional values. Doctoral students should also be required to complete specific trainings examining their own biases, culture, and values that influence their interactions with clients, with the goal of eliminating beliefs that their perspectives are universal. In addition, doctoral students should be required to engage in trainings or activities to increase their cultural competency/humility, and trainings and activities should be made available to students by their training programs.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Madeline
Brodt
There is a significant need for the development and dissemination of clinical research within historically oppressed and marginalized groups, especially BIPOC individuals. Given this need, research methodology and statistical courses within training programs should focus on how to recruit, work alongside, develop relevant research questions, utilize the appropriate research methodology and statistics, accurately interpret the data and disseminate research within BIPOC communities. Such skills are rarely discussed compared to research methodology used with conventional samples, like undergraduate or WEIRD (Western, educated, industrialized, rich, and democratic) samples (which have been used in the majority of psychology research studies). As it stands now, training programs largely develop graduate student researchers who primarily work with undergraduate/WEIRD rather than marginalized populations, despite there being greater need for the latter. Further, we encourage the CoA to articu...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Linnea
Sepe-Forrest
With the ever-increasing diversity of patients and clinicians, ethics courses need to be taught from a multicultural perspective. For example, when teaching APA ethics codes, topics needing a multicultural lens include boundary issues, self-disclosure, touch, bartering, and multiple relationships.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Linnea
Sepe-Forrest
The CoA should explicitly include cultural competency and cultural humility as professional values. Doctoral students should also be required to complete specific trainings examining their own biases, culture, and values that influence their interactions with clients, with the goal of eliminating beliefs that their perspectives are universal. In addition, doctoral students should be required to engage in trainings or activities to increase their cultural competency/humility, and trainings and activities should be made available to students by their training programs. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Jeffrey
Axelbank
The APA’s proposed IRs aim to delineate, specify and distinguish those competencies that students in psychology programs must attain at each level of training in order to assure their readiness to encounter and assist actual people in distress. Yet there are glaring omissions in the lists of principles, requirements and outline curricula the document enumerates. The IR regarding profession-wide competency makes clear that its central concern is “a scientific orientation toward psychological knowledge and methods (p. 5).” Knowledge, skills, competence, problem-solving ability and “substantial knowledge of scientific methods, procedures, and practices” are highlighted as foundational benchmarks for clinical capacity. Yet despite this respect for science and research, there is virtually no scientific research to demonstrate that skills-trained, research-experienced students become exemplary clinicians. Meanwhile, the foundational skills of empathy, theoretical sophistication, se...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Ritu
Verma
APAGS
Section I. Research (page 10) - The addition of the word “research” to the end of the sentence starting with “Demonstrate the substantially independent” would improve the clarity of the sentence (even though it is implied). Section III. Individual and cultural diversity (page 11) - We suggest that the inclusion of both “gender” and “gender identity” is a duplication, and as written may appear to create a false distinction between gender as historically used (i.e., referring to men and women) and gender identity, which does include men and women, but has emerged as a term more often used in discussions around the social construction of gender, such as in discussions gender diversity. We believe that this may be perceived by some as inaccurate and respectfully suggest stating gender and sexual identity. This is repeated in subsequent sections (e.g., page 18). Section III. Individual and cultural diversity (page 11) - We think that there is a missing bullet point at the beginning ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Catherine
Benoist
I fully agree with and endorse the Psychotherapy Action Network's (PsiAN) comment.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Catherine
Benoist
I fully agree with and endorse the Psychotherapy Action Network's (PsiAN) comment.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Catherine
Benoist
I fully agree with and endorse the Psychotherapy Action Network's (PsiAN) comment.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Catherine
Benoist
I fully agree with and endorse the Psychotherapy Action Network's (PsiAN) comment.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Catherine
Benoist
I fully agree with and endorse the Psychotherapy Action Network's (PsiAN) comment.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Neda
Neshat
As an integral part of a trainee’s clinical skills and competency, all faculty serving as clinical training supervisors should be held to the same if not higher cultural competency and humility training standards and benchmarks as their trainees. Supervisors should be culturally competent, per benchmarks set forth by the CoA, on how to implement culturally-informed assessments, interventions, and supervision practices. Given that the second required element for meeting the Supervision profession-wide competency (PWC) is not standardized and is at the discretion of each individual program (thus creating variability in training), the CoA should require that the second element of the Supervision PWC to be the following: Doctoral students should demonstrate knowledge of diversity considerations in supervision. Directors of Clinial Training need to be trained on how to advocate for students if an externship is not meeting diversity training benchmarks or if an externship is demonstrating bi...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Bruce
Bobbitt
APA Measurement-Based Care and Mental & Behavioral Health Registry Advisory Committee
As the Chair of the APA Measurement Based Care and Mental & Behavioral Health Registry advisory committee, I present these comments on behalf of the entire committee. Charted by APA in 2017, the committee currently consists of 10 psychologists with extensive experience in clinical care, measurement, and the use of outcomes in practice (our initial work is summarized in Wright et. al. (2020)). While the use of routine monitoring of critical clinical measures is becoming the norm across many areas of healthcare and medicine, adoption of routine outcome monitoring is slow to develop in behavioral health and psychology despite our long history of distinction in measurement and psychological assessment. Because the use of outcome monitoring will become an expected part of all healthcare, we believe that measurement based care should be a required component of all APA programs. Thus, we see the inclusion of measurement based care in the doctoral level curriculum as well as formal HSP cl...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Evan
Mayo-Wilson
I’d consider a broader approach, which is that training should equip practitioners to understand and apply the principles of evidence-based practice (i.e., incorporate best current evidence, client values and preferences, practitioner expertise) and to appraise the methods used to generate evidence (e.g., clinical trials, systematic reviews of clinical trials). Although this might be beyond the scope of what you’re asking today, I’d replace fuzzy terms like “empirical literature” (which includes many things that aren’t reliable evidence) and indicate that trainees should know how to critically appraise evidence about the causal effects of the interventions they might provide/prescribe. The last point (B.ii.) comes close, but it should clarify that we’re trying to make “causal inferences” and it should replace “meta-analyses” with “systematic reviews and meta-analyses of intervention effects” (because meta-analysis should normally be done as a component of a systematic review, and empha...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Theodore
Ellenhorn
I strongly support the comments of the Psychotherapy Action Network
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Jacob
Marzalik
Advisory Steering Committee for Development of Clinical Practice Guidelines
Clinical practice guidelines provide specific recommendations about treatment for particular disorders and conditions, are based on a systematic review of the available quality evidence and include an evaluation of the benefits versus potential harms of treatment. Clinical practice guidelines have become an increasingly important part of healthcare. In 2010, APA began an initiative to develop these clinical practice guidelines with the first guideline development panel forming in 2012. APA now has multiple clinical practice guidelines with more underway (https://www.apa.org/about/offices/directorates/guidelines/clinical-practice). Clinical practice guidelines are an essential part of evidence based practice in psychology, as they help the busy provider to quickly understand the available quality evidence about potential treatments while the provider also uses their clinical expertise in the context of patients’ values, culture, and preferences. We recommend that familiarity...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Jacob
Marzalik
Advisory Steering Committee for Development of Clinical Practice Guidelines
(Continue from previous comment): Below are resources for trainees related to clinical practice guidelines: • APA Clinical Practice Guideline Development: https://www.apa.org/about/offices/directorates/guidelines/clinical-practice • ECRI Guidelines Trust: https://guidelines.ecri.org/ • Guidelines International Network Library: https://guidelines.ebmportal.com/ We also recommend including a full definition of Evidence-Based Practice in Psychology and citing the full professional practice guideline that is being developed on evidence-based practice in psychology.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Andrea
Wiglesworth
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training. ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Annemarie
Slobig
I support the comments by NCSPP and the Psychotherapy Action Network
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
Munazza
Abraham
Clinical-Community dual track doctoral psychology students should be permitted, encouraged, and directly supported to attain community psychology/ community-based practicum rather than purely clinical placements. APPIC should explicitly expand what is considered acceptable hours to include community practice such as consulting for and employing community-based participatory research, facilitating focus groups, conducting needs assessments of marginalized populations, developing interventions, and other community psychology goals that could benefit from clinical psychology skills/experiences. Current APA and APPIC requirements force dual track students to learn from and practice from a purely clinical framework (that can be harmful in varying contexts) without the allotted time, support, and opportunities to engage with diverse communities. We should better equip scholars and practitioners to fulfill the career competencies they applied to grad school for: BOTH clinical and community...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-8 I. Profession-Wide Competencies
C
T
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-9 P. Postdoctoral Residency Competencies
Jon
Rose
I find the proposed postdoctoral residency standards for Geropsychology quite disappointing. Completion of a specialty postdoctoral training program should signify that a psychologist is competent to begin independent practice in all aspects of that specialty. The Pikes Peak competencies were developed to define what constitutes special knowledge and ability in geropsychology. To be fair, a few of the Pike’s Peak competencies are addressed, but it is done with less specificity than stated in the Pike's Peak Self Assessement Tool: APA’s Section I. Postdoctoral residents are expected to . . . Demonstrate knowledge of the negative impact of ageism. . . includes content in Pike’s Peak (PP) IIA3b Section II. Communication and Interpersonal Skills includes content in Pikes Peak (PP) PP V.A.3.b & c Section III. Assessment . . . Conducts differential diagnosis. . . relates to PP II.A4.4.c. Section III. Assessment . . . integrate knowledge of normal and pathological ag...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-9 P. Postdoctoral Residency Competencies
Monica
Carsky
As someone who participates in psychotherapy research and also trains doctoral and postdoctoral psychologists as well as therapists with other degrees, I must ask what happened to the term "clinical psychology"? Is it absolutely necessary to replace it with"cognitive and behavioral"? What of my colleagues who are studying brain functions during interpersonal tasks, or who study adult attachment and its impact on therapy alliance and outcome? Or those who study social-cognitive neuroscience or which borderline or schizophrenic patients will respond to which psychosocial therapies and why? why not "psychosocial, cognitive and behavioral," or just psychosocial? There is increasing stress on medical residents, not only trainees in psychiatry, to respond to the whole person, to study narrative medicine. The most recent developments in cognitive and behavioral therapies include attention to affect in the sessions (will they start to sound like relational psychoanalysts soon?) so why not ...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-9 P. Postdoctoral Residency Competencies
Diana
Concannon
NCSPP
Although NCSPP members primarily provide training and education at the doctoral level, rather than at the postdoctoral, we have concerns related to the specific articulation of PWCs for the various specialty practice areas. It seems premature for the CoA to provide such detailed articulation in some domains. Specifically, as of this writing, there are no accredited postdoctoral residencies in Behavioral and Cognitive Psychology, begging the question as to bases for these competencies. In other areas (Forensic Psychology and Geropsychology), there are three or fewer programs. Arguably, it is only within Clinical and Neuropsychology that there are there sufficient number of accredited postdoctoral residency that there would be a sizable agreement about the nature of the specialty areas’ PWCs.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-9 P. Postdoctoral Residency Competencies
Monique
Bowen
I agree with and support the comments of NCSPP and strongly endorse comments by Monica Carsky, PhD regarding postdoctoral residency competency.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-9 P. Postdoctoral Residency Competencies
Leah
Horvath
I endorse the NCSPP response.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-9 P. Postdoctoral Residency Competencies
Amanda
Rickard
I fully agree with Monica Carsky's comments.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-9 P. Postdoctoral Residency Competencies
Enrico
Gnaulati
The OPCA appears to be privileging CBT treatments in the training of candidates which not only diminishes diversity in our field, but goes against the bulk of psychotherapy research which empirically establishes "common factors" as central in psychotherapy outcome. CBT treatments overwhelmingly focus on symptom reduction as the measure of client change (which clients don't prefer, but do overall social and emotional well being/such that ethical issues arise). The literature also shows that clients prefer genuine/empathic/active listening in therapists, not specific techniques (raising other ethical issues). See my book: E. Gnaulati Saving Talk Therapy and recent articles I have written in Psychotherapy/Journal of Humanistic Psychology/Ethical Human Psychology and Psychiatry raising serious ethical concerns around the privileging of CBT treatments!!!
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-9 P. Postdoctoral Residency Competencies
Kevin
Larkin
Clinical Health Psychology Specialty Council
As members of the Task Force charged by the Clinical Health Psychology Specialty Council to review and submit competencies required for clinical health psychology postdoctoral programs to CoA, we have reviewed the revised competencies for postdoctoral residencies in clinical health psychology (IR C-9 P). In brief, we believe that the CoA has satisfactorily addressed all of our concerns. The important competencies associated with demonstrating skills in doing research, supervision, teaching, and consultation, rather than just using them or engaging in simulated practice, have been added to the list of essential competencies to be acquired during postdoctoral training in clinical health psychology. We were particularly pleased to see the removal of language suggesting that research competencies “per se” were not required in the section on the Integration of Science and Practice. Adding the phrase “as they pertain to the accredited area” to the descriptions of Level 1 competencies in t...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-9 P. Postdoctoral Residency Competencies
Ritu
Verma
APAGS
Behavioral and Cognitive Psychology - Section I. Research (page 19) - We believe the first bullet should read “...other forms of inquiry”. Clinical Child Psychology Specialty - Section IV. Assessment (page 22) - We recommend the addition of demonstrating knowledge of and accurate application of assessment findings in the school setting for accommodations. This can include information related to eligibility criteria for services, legal implications of service eligibility, etc. Geropsychology Specialty - Section III. Assessment (page 32-33) - In addition to “integrat[ing] knowledge of normal and pathological aging, including age related changes in cognitive abilities” we recommend also adding in demonstration of knowledge about appropriate referrals for health and/or cognitive concerns for older adults (e.g., referral to a gerontologist, neuropsychologist). Doctoral Program Achievement Thresholds. Percent of students leaving a program for any reason (page 40) - We wonder if there is...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-9 P. Postdoctoral Residency Competencies
Neda
Neshat
Interdisciplinary research is likely the best available methodology capable of achieving health equity. For this reason, CoA should collaborate with different researcher teams currently conducting interdisciplinary work and develop training videos that can be disseminated by Directors of Clinical Training to students, staff, and faculty. The CoA should develop a benchmark for what constitutes an interdisciplinary team
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-9 P. Postdoctoral Residency Competencies
Bruce
Bobbitt
APA Measurement-Based Care and Mental & Behavioral Health Registry Advisory Committee
As the Chair of the APA Measurement Based Care and Mental & Behavioral Health Registry advisory committee, I present these comments on behalf of the entire committee. Charted by APA in 2017, the committee currently consists of 10 psychologists with extensive experience in clinical care, measurement, and the use of outcomes in practice (our initial work is summarized in Wright et. al. (2020)). While the use of routine monitoring of critical clinical measures is becoming the norm across many areas of healthcare and medicine, adoption of routine outcome monitoring is slow to develop in behavioral health and psychology despite our long history of distinction in measurement and psychological assessment. Because the use of outcome monitoring will become an expected part of all healthcare, we believe that measurement based care should be a required component of all APA programs. Thus, we see the inclusion of measurement based care in the doctoral level curriculum as well as formal HSP cl...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-9 P. Postdoctoral Residency Competencies
Evan
Mayo-Wilson
I’d consider a broader approach, which is that training should equip practitioners to understand and apply the principles of evidence-based practice (i.e., incorporate best current evidence, client values and preferences, practitioner expertise) and to appraise the methods used to generate evidence (e.g., clinical trials, systematic reviews of clinical trials). Although this might be beyond the scope of what you’re asking today, I’d replace fuzzy terms like “empirical literature” (which includes many things that aren’t reliable evidence) and indicate that trainees should know how to critically appraise evidence about the causal effects of the interventions they might provide/prescribe. The last point (B.ii.) comes close, but it should clarify that we’re trying to make “causal inferences” and it should replace “meta-analyses” with “systematic reviews and meta-analyses of intervention effects” (because meta-analysis should normally be done as a component of a systematic review, and empha...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-9 P. Postdoctoral Residency Competencies
Lori
Hauser
Council of Specialties in Professional Psychology-Forensic
We, the members of the Forensic Council of Specialties in Professional Psychology (COSPP-Forensic) have reviewed the revised competencies for postdoctoral residencies in forensic psychology (IR C-9 P). We appreciate the efforts of CoA throughout this initiative and, in general, are satisfied with a number of the revisions to the competencies. In most instances, the competencies we drafted as a specialty are included in the revised document, in spirit if not verbatim. However, there are a few areas of concern that remain, specifically with the Level 3 Competencies. A few involve minor (though not insignificant) wordsmithing of existing competencies, and there are two additional competencies that were omitted in this revision that we feel strongly should be included. Therefore, we respectfully offer the following feedback and suggestion for further revision. Level 3-I. Professional Values, Attitudes, and Behaviors • 1st bullet: While we as forensic psychologists practice with a vigi...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-9 P. Postdoctoral Residency Competencies
Robin
Hilsabeck
Clinical Neuropsychology Specialty Council
Dear Members of the COA: I am writing you as Chair of the Clinical Neuropsychology Specialty Council, which represents the specialty of clinical neuropsychology on the Council of Specialties in Professional Psychology (CoS). The following comments are in response to the proposed revision to Implementing Regulation C-9 P. The CNS consists of representatives from the following organizations: Society for Clinical Neuropsychology (APA Division 40), National Academy of Neuropsychology, American Academy of Clinical Neuropsychology, Hispanic Neuropsychological Society, American Board of Professional Neuropsychology, American Board of Clinical Neuropsychology, Association of Post-Doctoral Programs in Clinical Neuropsychology, and Association for Internship Training in Clinical Neuropsychology. This response was primarily authored by the CNS Postdoctoral Competencies Workgroup, consisting of Amy Heffelfinger, Ph.D., ABPP-CN (Co-chair), Brad L. Roper, Ph.D., ABPP-CN (Co-chair), Karin J. McCo...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-9 P. Postdoctoral Residency Competencies
Jacob
Marzalik
Advisory Steering Committee for Development of Clinical Practice Guidelines
Clinical practice guidelines provide specific recommendations about treatment for particular disorders and conditions, are based on a systematic review of the available quality evidence and include an evaluation of the benefits versus potential harms of treatment. Clinical practice guidelines have become an increasingly important part of healthcare. In 2010, APA began an initiative to develop these clinical practice guidelines with the first guideline development panel forming in 2012. APA now has multiple clinical practice guidelines with more underway (https://www.apa.org/about/offices/directorates/guidelines/clinical-practice). Clinical practice guidelines are an essential part of evidence based practice in psychology, as they help the busy provider to quickly understand the available quality evidence about potential treatments while the provider also uses their clinical expertise in the context of patients’ values, culture, and preferences. We recommend that familiarity...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-9 P. Postdoctoral Residency Competencies
Richard
Seime
Council of Specialties in Professional Psychology (CoS)
Council of Specialties in Professional Psychology (CoS) comments for draft of IR C-9 P, Postdoctoral Residency Competencies In 2017, each CoA recognized specialty submitted their postdoctoral competencies with the understanding that CoA would “rework” the submitted competencies so that they could be readily used for accreditation decisions. The specialties in health service psychology identified the competencies and their behavioral referents that were judged to be necessary for residents to achieve by the completion of a postdoctoral training program. In collaboration with CoA, CoS provided guidance to the specialties prior to submission as to the suggested number of competencies and the essential elements within each to assess attainment of the competencies. The submitted competencies are posted on the CoS website (www.cospp.org ) along with a narrative of the process for the development of each specialty’s competencies. The current draft of IR-C-9 Postdoctoral Residenc...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
C-9 P. Postdoctoral Residency Competencies
Brian
Carpenter
Society of Clinical Geropsychology
The Society of Clinical Geropsychology (APA Div. 12 Section 2) endorses the comments regarding postdoctoral programs that have been submitted by the Council of Specialities in Professional Psychology (CoS) and by the Geropsychology Specialty Council.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Diana
Concannon
NCSPP
During the current pandemic, it appears shortsighted to suggest lowering the attrition number. Given the unusual and exceptional circumstances, we recommend delaying any revision of this number for at least one year. Additionally, there is an unresolved issue as to whether the threshold should be a single number across all programs. A student in a fully-funded Ph.D. program (tuition and stipend provided) is different from a student who is financing their education through student loans. If a student in the funded program drops out, it is likely a program problem (poor program or poor student selection). If a student paying their own way decides to leave (perhaps after earning a Master's degree in a jurisdiction with Master's licensing) it seems less of a program problem. CoA might say "we will just ask programs to explain their attrition" but the 6% rule seems to work against Psy.D. programs or non-endowed programs.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Leah
Horvath
I endorse the NCSPP response.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Penny
Rosen
I concur with comments made by Psychotherapy Action Network (PsiAN) submitted by Nancy Burke
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Michelle
Schultz
I strongly support the comments of NCSPP.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Emma
Parrish
In addition to monitoring the attrition rate of each program, CoA should separately monitor the diversity factors of the students who leave the program. For example, programs should be required to report the proportion of students from minority backgrounds out of all students who leave their program. CoA needs to develop a system for programs that protects the identity of students who leave when reporting this information. Further, CoA should monitor how programs address diversity concerns in attrition as stated in section III.C.1. of APA Accreditation Self-Study (e.g., flawed admission procedures or unsupportive learning environments).
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Jack
Andrews
In addition to monitoring the attrition rate of each program, CoA should separately monitor the diversity factors of the students who leave the program. For example, programs should be required to report the proportion of students from minority backgrounds out of all students who leave their program. CoA needs to develop a system for programs that protects the identity of students who leave when reporting this information. Further, CoA should monitor how programs address diversity concerns in attrition as stated in section III.C.1. of APA Accreditation Self-Study (e.g., flawed admission procedures or unsupportive learning environments)
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Alexandra
Convertino
In order to better understand the reasons why students prematurely leave APA accredited PhD programs and to improve attrition rates within programs, CoA should develop a subcommittee that provides and conducts voluntary exit interviews with all students. CoA should also develop a document explaining the purpose of such exit interviews. DCTs should be required to provide this document to students and obtain a signature from the student stating that they understand the opportunity.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Colleen
Kase
In addition to monitoring the attrition rate of each program, CoA should separately monitor the diversity factors of the students who leave the program. For example, programs should be required to report the proportion of students from minority backgrounds out of all students who leave their program. CoA needs to develop a system for programs that protects the identity of students who leave when reporting this information. Further, CoA should monitor how programs address diversity concerns in attrition as stated in section III.C.1. of APA Accreditation Self-Study (e.g., flawed admission procedures or unsupportive learning environments). Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
robert
eme
I fully agree with the threshold changes.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Elizabeth
Bownes
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to reevaluate programs in their cross-cultural training
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Samantha
Hoffman
In addition to monitoring the attrition rate of each program, CoA should separately monitor the diversity factors of the students who leave the program. For example, programs should be required to report the proportion of students from minority backgrounds out of all students who leave their program. CoA needs to develop a system for programs that protects the identity of students who leave when reporting this information. Further, CoA should monitor how programs address diversity concerns in attrition as stated in section III.C.1. of APA Accreditation Self-Study (e.g., flawed admission procedures or unsupportive learning environments). Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Alyssa
Choi
In addition to monitoring the attrition rate of each program, CoA should separately monitor the diversity factors of the students who leave the program. For example, programs should be required to report the proportion of students from minority backgrounds out of all students who leave their program. CoA needs to develop a system for programs that protects the identity of students who leave when reporting this information. Further, CoA should monitor how programs address diversity concerns in attrition as stated in section III.C.1. of APA Accreditation Self-Study (e.g., flawed admission procedures or unsupportive learning environments). Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Samantha
Hoffman
In order to better understand the reasons why students prematurely leave APA accredited PhD programs and to improve attrition rates within programs, CoA should develop a subcommittee that provides and conducts voluntary exit interviews with all students. CoA should also develop a document explaining the purpose of such exit interviews. DCTs should be required to provide this document to students and obtain a signature from the student stating that they understand the opportunity. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Alyssa
Choi
In order to better understand the reasons why students prematurely leave APA accredited PhD programs and to improve attrition rates within programs, CoA should develop a subcommittee that provides and conducts voluntary exit interviews with all students. CoA should also develop a document explaining the purpose of such exit interviews. DCTs should be required to provide this document to students and obtain a signature from the student stating that they understand the opportunity. Sincerely, a doctoral student of an APA-accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Catherine
Sumida
In addition to monitoring the attrition rate of each program, CoA should separately monitor the diversity factors of the students who leave the program. For example, programs should be required to report the proportion of students from minority backgrounds out of all students who leave their program. CoA needs to develop a system for programs that protects the identity of students who leave when reporting this information. Further, CoA should monitor how programs address diversity concerns in attrition as stated in section III.C.1. of APA Accreditation Self-Study (e.g., flawed admission procedures or unsupportive learning environments).
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Alexandra
Tabachnick
In addition to monitoring the attrition rate of each program, CoA should separately monitor the diversity factors of the students who leave the program. For example, programs should be required to report the proportion of students from minority backgrounds out of all students who leave their program. CoA needs to develop a system for programs that protects the identity of students who leave when reporting this information. Further, CoA should monitor how programs address diversity concerns in attrition as stated in section III.C.1. of APA Accreditation Self-Study (e.g., flawed admission procedures or unsupportive learning environments).
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Tabitha
Sellers
In addition to monitoring the attrition rate of each program, CoA should separately monitor the diversity factors of the students who leave the program. For example, programs should be required to report the proportion of students from minority backgrounds out of all students who leave their program. CoA needs to develop a system for programs that protects the identity of students who leave when reporting this information. Further, CoA should monitor how programs address diversity concerns in attrition as stated in section III.C.1. of APA Accreditation Self-Study (e.g., flawed admission procedures or unsupportive learning environments)
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Aurora
Brinkman
In order to better understand the reasons why students prematurely leave APA accredited PhD programs and to improve attrition rates within programs, CoA should develop a subcommittee that provides and conducts voluntary exit interviews with all students. CoA should also develop a document explaining the purpose of such exit interviews. DCTs should be required to provide this document to students and obtain a signature from the student stating that they understand the opportunity. Understanding how systemic racism, ableism, sexism, and classism contribute to the likelihood a student will leave the program is also important.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Lia
Smith
Data reported from doctoral programs from the APA is a very important resource and provides critical information about APA accredited programs across the country. In addition to monitoring the attrition rate of each program, I believe that CoA should separately monitor the diversity factors of the students who leave programs. For example, programs should be required to report the proportion of students from minority backgrounds out of all students who leave their program. Given small cohort sizes - and even smaller numbers of minority students - for many programs, CoA needs to develop a system for programs that protects the identity of students who leave when reporting this information. Further, CoA should monitor how programs address diversity concerns in attrition as stated in section III.C.1. of APA Accreditation Self-Study (e.g., flawed admission procedures or unsupportive learning environments). Furthermore, in order to better understand the reasons why students prematurely le...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Neda
Neshat
In order to better understand the reasons why students prematurely leave APA accredited PhD programs and to improve attrition rates within programs, CoA should develop a subcommittee that provides and conducts voluntary exit interviews with all students. CoA should also develop a document explaining the purpose of such exit interviews. DCTs should be required to provide this document to students and obtain a signature from the student stating that they understand the opportunity.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Dumett
Elisa
No one individual will be an expert in all cultural groups and culturally informed assessments and interventions. Therefore, CoA should develop a widespread network of consultants who are experts in evidence-based and culturally competent training practices (i.e., for both intervention and assessment). These consultants should develop training videos and offer recorded webinars that will be freely accessible to all students, faculty, and staff of all APA-accredited programs. APA should also allocate funds/develop a budget for these consultants, who likely will be primarily BIPOC, for this service. If faculty serve as consultants, consultations should be required by CoA as part of their official faculty duties and integrated into their paid time (i.e., not an additional voluntary task), and when possible and under their supervision, trainees should be given opportunities to also serve as consultants. Such efforts would simultaneously improve care for BIPOC clients, train students in con...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Magro
Sophia
In order to better understand the reasons why students prematurely leave APA accredited PhD programs and to improve attrition rates within programs, CoA should develop a subcommittee that provides and conducts voluntary exit interviews with all students. CoA should also develop a document explaining the purpose of such exit interviews. DCTs should be required to provide this document to students and obtain a signature from the student stating that they understand the opportunity.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Orlowski
Edmund
In addition to monitoring the attrition rate of each program, CoA should separately monitor the diversity factors of the students who leave the program. For example, programs should be required to report the proportion of students from minority backgrounds out of all students who leave their program. CoA needs to develop a system for programs that protects the identity of students who leave when reporting this information. Further, CoA should monitor how programs address diversity concerns in attrition as stated in section III.C.1. of APA Accreditation Self-Study (e.g., flawed admission procedures or unsupportive learning environments).
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
A
R
The CoA must implement clear benchmarks regarding the inclusion of diversity and cross-cultural issues as they pertain to competencies for doctoral students. As it stands, there are no basic benchmarks for the inclusion of training and teaching in cross-cultural issues. This has led to substantial variability in such training across the country, with some programs providing minimal and inadequate training. Although ethnic minorities make up approximately 40% of the US population, currently only 16% of the psychology workforce is racially and ethnically diverse. Thus, in addition to a lack of psychologists who can offer psychological services to diverse populations, there is currently inadequate cultural competency/humility training to equip the incoming generally homogenous psychology workforce. As a doctoral student of an APA-accredited program, I urge the CoA to provide basic diversity training benchmarks for each of the profession-wide competencies and to use these benchmarks to ree...
See Full Comment
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
A
R
I agree with and endorse the comments of Stephanie Torres, Amber Fox, Emma Parrish, and Alyssa Choi. Echoing these comments, doctoral students must demonstrate knowledge, awareness, sensitivity, and skills when working with diverse individuals and communities who embody a variety of cultural and personal background and characteristics across all professional activities. Students must also have an understanding of how their own personal/cultural history, attitudes, and biases may affect how they understand and interact with people different from themselves.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Jason
Washburn
Council of University Directors of Clinical Psychology
The CUCDP Board has no concerns or comments with the recalculation of thresholds in D.4-7(b), as articulated in the proposed revision.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Lauren
Fournier
In addition to monitoring the attrition rate of each program, CoA should separately monitor the diversity factors of the students who leave the program. For example, programs should be required to report the proportion of students from minority backgrounds out of all students who leave their program. CoA needs to develop a system for programs that protects the identity of students who leave when reporting this information. Further, CoA should monitor how programs address diversity concerns in attrition as stated in section III.C.1. of APA Accreditation Self-Study (e.g., flawed admission procedures or unsupportive learning environments).
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Munazza
Abraham
“In addition to monitoring the attrition rate of each program, CoA should separately monitor the diversity factors of the students who leave the program. For example, programs should be required to report the proportion of students from minority backgrounds out of all students who leave their program. CoA needs to develop a system for programs that protects the identity of students who leave when reporting this information. Further, CoA should monitor how programs address diversity concerns in attrition as stated in section III.C.1. of APA Accreditation Self-Study (e.g., flawed admission procedures or unsupportive learning environments).” -I endorse this comment. Sincerely, A doctoral student from an APA accredited program
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs
Melissa
LaCelle
In addition to monitoring the attrition rate of each program, CoA should separately monitor the diversity factors of the students who leave the program. For example, programs should be required to report the proportion of students from minority backgrounds out of all students who leave their program. CoA needs to develop a system for programs that protects the identity of students who leave when reporting this information. Further, CoA should monitor how programs address diversity concerns in attrition as stated in section III.C.1. of APA Accreditation Self-Study (e.g., flawed admission procedures or unsupportive learning environments).
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
E.1-3. Commission on Accreditation Policy on Research Studies
Heidi
Levitt
It is important that all students develop a solid foundation in qualitative as well as quantitative methods. We are at a point in our discipline where reporting standards for qualitative and mixed methods research is incorporated into the APA Publication Manual. There are journals focused solely on Qualitative Health Research, and mixed methods research is increasingly valued by national granting agencies as strategies for developing knowledge. There are textbooks and plentiful resources that can be used to provide instruction at the graduate level. These methods are relevant to clinical practice, theory development, multicultural and critical research, and intervention development. They should be specified as a required area of learning within any accredited curriculum.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
E.1-3. Commission on Accreditation Policy on Research Studies
Elizabeth
Fein
I agree with the comment left by Heidi Levitt, above, regarding the importance of training in qualitative research methods.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
E.1-3. Commission on Accreditation Policy on Research Studies
Diana
Concannon
NCSPP
We support the CoA’s effort to update and revise the IR to eliminate the G&P language and update it to the SoA. However, we are unclear why the CoA is proposing to halt looking at agreement between what site visitors see and what CoA reviewers decide. It seems that one would want to know if there were high degrees of disagreement to investigate the source of/reason for the disagreement. We suggest that this be revisited.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
E.1-3. Commission on Accreditation Policy on Research Studies
Michelle
Schultz
I strongly support the comments of NCSPP.
Implementing_Regulations_PWCs_Doctoral_Internship_Postdoctoral D_4-7b_and E_1-3
E.1-3. Commission on Accreditation Policy on Research Studies
Jason
Washburn
Council of University Directors of Clinical Psychology
The CUDCP Board has no concerns or comments with the proposed changes to the CoA’s policy on research studies (Implementing Regulation E.1-3)