Accreditation Public Comment System

This project is now closed for new comments.

Document	Section	Item	First Name	Last Name	Group Name	Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Joan	Simon		To begin, I do not understand the value or true purpose of having APA become involved in accreditation of Masters programs. My area of doctoral training is School Psychology. As you are well aware, the history of School Psychology is plagued with the battle between NASP and APA over the appropriate level of entry into our profession. Why, after all these decades, would APA involve itself in accrediting programs that are already accredited by NASP? Furthermore, the widely accepted entry level into our profession is the EdS degree, which means there is even LESS reason or rationale for APA to include School Psychology programs into an accreditation process for MS programs.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Rosalyn	Davis		After having reviewed the entire document I would be highly in favor of the APA broaching this for programs that are housed in psychology departments that are better suited for APA than CACREP. There are of course questions that would be had for me about the process and the way in which this would work for different campuses but I would be intrigued.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Larry	Hess		Th practice of psychology should be at the doctoral level. The field is too complex for other types of training, in my view. APA likely will lose many doctoral level members by supporting this new accreditation. The doctoral degree also promotes a certain cachet with patients and other providers. If there are too few practitioners in some areas then let other fields fill the gap.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	CARRIE	LEWIS		“Some areas of pre-doctoral specialization, such as school psychology, may require training beyond that required for an accreditation HSP Master’s program to qualify for entry-level practice in those areas.” - confusing language; perhaps,”Entry-level practice in some specialty areas of HSP require training beyond master’s level training.” Consider making “These programs can apply for accreditation at the Master’s level, even if they offer a graduate degree beyond a terminal Master’s degree (e.g., Specialist),” item e. versus d-I i. And rewarding to: “Graduate programs can apply for HSP accreditation at the Master’s level, even if they offer a graduate degree beyond a terminal Master’s degree (e.g., Doctoral level training).
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Amber	Boykin		As a school psychologist, I hope that the APA understands the unique training needs for our field. I believe they should ensure that wording clearly states a Master's is not a terminal degree for work in this field. I appreciate the collaboration between APA and NASP in ensuring this is clearly communicated.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Meaghan	Guiney		It is critical that APA recognize that the specialist-level degree (e.g., EdS) represents the minimum standard for practice as a school psychologist. This degree typically requires more credits, not to mention far more supervised field experience (e.g., 1200-hour internship) than a master's degree in any area of psychology. NASP has developed comprehensive Standards for graduate preparation and credentialing that establish the minimum expectations for competency in school psychology practice, and these Standards should remain the basis for training and practice in school psychology. Accreditation of “master’s level programs” may result in programs that are not equivalent to NASP Standards and thus enable inadequately trained professionals to assume roles in school-based practice. Competently navigating the increasingly complex work of school psychologists, particularly at a time when students are experiencing trauma resulting from the COVID-19 pandemic, racial injustice protests...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	STEFAN	DOMBROWSKI		I am a doctoral level licensed psychologist and certified school psychologist. I also completed a post-doctoral fellowship in clinical child psychology at an APPIC approved university medical center. I have worked in a school, counseling center, and hospital setting. I am also a trainer of school psychologists for the past 20 years so I have a degree of authority on the topic of training school psychologists. APA's proposed minimum requirement of 36 graduate credit hours for a Master's degree in school psychology represents far too few credits to sufficiently cover all necessary training requirements. It may well even represent public peril if a subsequent step by APA is to advocate for credentialing of this degree type at the state level. If APA wishes to ultimately enter into the "business" of promoting the credentialing of non-doctoral school psychologists--a role competently undertaken by the National Association of School Psychologists-- then it would behoove the organizatio...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Sara	Witmer		The current minimum degree for practice as a school psychologist is an Ed.S. degree that typically requires far more credits and supervised practice-based experience than masters degrees in psychology. This level of training is necessary to ensure graduates are able to effectively serve in school settings. What is outlined in APA's proposed standards is far below what is necessary for preparation as a school psychologist. The NASP standards are much more rigorous, and necessary. They should continue to be the minimum requirements for school psychology program approval and accreditation.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Chuck	Archer		I would emphasize the wording that says, "...Some areas of pre-doctoral specialization, such as School Psychology, may require training beyond that required for accreditation HSP Master's program to qualify for entry-level practice in those areas." Credentialing for entry-level practice varies by state and is the goal of any student entering into graduate studies. Students should know that eventual employment as a School Psychologist according to the National Association of School Psychologists (NASP), which has been endorsing university training programs for years, assumes more hours of graduate level instruction and a closely supervised school year of experience as an intern in the field before the granting a Specialist's Degree - a post-Master's, pre-doctoral accomplishment. This set of requirements has been recognized as the entry level for most every state in the country where employment as a School Psychologist is sought. Either APA should emphasize to students that the current p...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Joseph	Prus		Thank you for the opportunity to comment on the proposed master’s level accreditation in Health Services Psychology. Accreditation standards should foster high quality preparation, and provide prospective students and the public with a degree of confidence in the outcomes of such preparation (i.e., the capabilities of graduates). Although the proposed standards for master’s level accreditation in Health Services Psychology might further such goals for master’s level mental health services providers in such specialties as clinical and counseling psychology, they would likely have the opposite effect for school psychology. The proposed standards fall far short of the specialist degree level standards of the National Association of School Psychologists (NASP) that are already in place at the national level, and in the great majority of states for graduate preparation in school psychology. Thus, the proposed master’s level standards, if enacted, threaten decades of progress in assuring tha...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Jason	Kaplan		It is critical that APA recognizes that the specialist-level degree (e.g., EdS) represents the minimum standard for practice as a school psychologist. This degree typically requires more credits, not to mention far more supervised field experience (e.g., 1200-hour internship) than a master's degree in any area of psychology. NASP has developed comprehensive Standards for graduate preparation and credentialing that establish the minimum expectations for competency in school psychology practice, and these Standards should remain the basis for training and practice in school psychology. Accreditation of “master’s level programs” may result in programs that are not equivalent to NASP Standards and thus enable inadequately trained professionals to assume roles in school-based practice. Competently navigating the role of a school psycholoigst, -requires a standard of training beyond the master's level. The Levels of Complexity outlined in APA’s proposed competencies for HSP programs ...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Mark	Swerdlik		Thank you for the opportunity to comment on the proposed master’s level accreditation in Health Services Psychology. Accreditation standards should foster high quality preparation and provide prospective students and the public with a degree of confidence in the outcomes of such preparation (i.e., the capabilities of graduates). Although the proposed standards for master’s level accreditation in Health Services Psychology might further such goals for master’s level mental health services providers in such specialties as clinical and counseling psychology, they are likely to have the opposite effect for school psychology. The proposed standards are far less than the specialist degree level standards promulgated by the National Association of School Psychologists (NASP) that are already being implemented at the national level, and in the great majority of states for graduate preparation in school psychology. Thus, the proposed master’s level standards, if enacted, threaten decades of p...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Diana	Concannon	NCSPP	NCSPP respectfully suggests that comments on the specific Standards that might be associated with a proposed accredited Master's in Psychology is premature and must be proceeded by fundamental determinations on a number of issues that will be key to ensuring the success and integrity of any such degree program, and well as to same in relation to our doctoral programs. These fundamental issues include but are not limited to: (1): Will doctoral programs be able to obtain accreditation for the (currently) non-terminal master's programs within their doctoral programs? (2) Given the PWC and DSK domains within the proposed master's program parallel those within the doctoral program, will graduates of the former be permitted to transfer additional units into a doctoral program should they subsequently decide to pursue the advanced degree (i.e., will CoA allow waiving of traditional transfer limits for these students)? (3) If this master's program is to be competitive with CACREP and COAMFTE ...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Leah	Horvath		I endorse the NCSPP response for all areas related to the Accreditation of Master's programs.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Peter	Faustino		Although the proposed standards for master’s level accreditation in Health Services Psychology might further such goals for master’s level mental health services providers in such specialties as clinical and counseling psychology, they are likely to have the opposite effect for school psychology. The proposed standards are far less than the specialist level degree standards promulgated by the National Association of School Psychologists (NASP) that are already being implemented at the national level, and in the great majority of states for graduate preparation in school psychology. Thus, the proposed master’s level standards, if enacted, threaten decades of progress in assuring that school psychologists are prepared to provide the variety of educational and psychological services needed by children, youth, and families. I know that APA would not want to enact standards that reduce the quality of service to those of greatest need. I urge APA to either a) adopt standards for school psych...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Nancy	Burke	Psychotherapy Action Network	The APA’s proposal for the accreditation of master’s degree programs in psychology reflects the same problematic constriction in clinical training as is apparent in its criteria for doctoral, internship and post-doctoral training, although amplified in this case due to the far shorter duration of master’s programs in general. The discipline-specific knowledge it prescribes, to be acquired through courses either at the graduate OR the undergraduate level, covers territory similar to that prescribed for doctoral programs – a territory devoid of the study of the inner lives and psyches of patients in favor of neuropsychological, biological and cognitive approaches. The study of these approaches is bolstered by an emphasis in graduate programs upon research design and data analysis, nearly all of which is quantitative in nature, with a passing nod to qualitative and mixed methods. (Adding “single-case design” to the list of research methods the program teaches, it should be emphasized, ...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Amy	Leibowitz		For this and all sections below, I agree with the comments of the Psychotherapy Action Network (PSIAN).
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Jana	Aupperlee		Master’s level programs in school psychology are NOT sufficient for school-based practice; the EdS must remain the minimum degree for school-based practice. This degree requires more credits (60) and far more supervised field experience (600 hours practicum and a 1200 hour internship) than most MA level programs. Establishing a lower level of training expectations for school-based practitioners is potentially problematic for multiple reasons. First, this could lead to students completing an MA level program in school psychology and still not meeting state level standards for credentialing. Second, school psychology requires knowledge and skills beyond those typically covered in a basic psychology program. For instance, topics like systems theory, instruction, curriculum development, positive behavior interventions and supports, racial injustice, and special education law may not be adequately covered in the APA’s discipline specific knowledge and nine profession-wide competencies. Thir...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Kristen	Kyriacou		I appreciate the opportunity to provide feedback on this issue. I am a doctoral level school psychologist and have worked in urban public school settings for 31 years. My intensive training, including practicums and internship, has been invaluable in addressing the vast level of student needs that I have seen across the course of my career. It is inconceivable that APA would consider accreditation of individuals who have anything less than a specialist degree in school psychology. While there is a shortage of school psychologists across the country, I have significant concerns about reducing the level of training and quality of school psychological providers. With the level of student needs being very high due to trauma, poverty, immigrant status, language and cultural differences, etc. school psychologists must possess the skills and training to address these needs. A person with fewer than 60 hours of training, and no internship experience would not be adequately prepared to se...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Shawna	Kelly	National Association of School Psychologists	NASP appreciates the inclusion in I.A.d, specifically the reference to school psychology. While previous comments represent potential “downstream” issues that may emerge within school psychology given the nature of licensing and certification of school psychologists within state departments of education across the country, the addition of language referencing the specialist-level degree as entry into the field is a helpful addition. If in fact the APA does endorse specialist-level training and NASP approval and accreditation in the Implementation Regulations, this would mitigate concerns related to accreditation of school psychology programs at the “Master’s level” with standards that do not meet the well-established NASP Standards for Graduate Preparation of School Psychologists (NASP, 2020). Suggested edits/additions in I.A.d. are as follows: HSP Master’s programs prepare students for practice at the Master’s level. Some areas of predoctoral specialization, such as school psycholo...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Shawna	Kelly	National Association of School Psychologists	While the comments note that the standards do not preclude a doctoral program from offering a master’s degree, and the comment later alludes more broadly to a “post-master’s degree”, we suggest including “specialist-level” in addition to doctoral, consistent with the description in Standard I.A.d.i. Please note that NASP standards for graduate preparation and credentialing refer to “specialist-level” training for entry to practice as a school psychologist rather than the “specialist degree” or EdS. Specialist-level graduate preparation, as defined by NASP Standards, require the following: a) A minimum 3 years of graduate study, consisting of 60 hours of graduate credit or the equivalent and b) a supervised internship experience with a minimum of 1,200 clock hours that culminates in institutional (university) documentation of program completion. Due to varied higher education practices and restrictions, school psychology programs that meet these criteria confer a range of degree...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Marsha	Spencer		Thank you for specifically referencing the specialist degree, the entry level degree for school psychologists. The description of specialist-level would be more inclusive of long-standing programs that meet specialist standards, but have historically used a different name.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Emilie	Ney		Throughout the standards I encourage that reference be made to the "specialist level" degree, which is the entry level degree for school psychology. A specialist-level degree may be named many different things, but must involve: • A minimum 3 years of graduate study, consisting of 60 hours of graduate credit or the equivalent. • A supervised internship experience with a minimum of 1,200 clock hours that culminates in institutional (university) documentation of program completion. I appreciate that the comments in response to draft 1 1. recognize the specialist-level degree as the entry level degree for practice in the area of school psychology and 2. indicate intent to include the specialist-level requirement and NASP approval/accreditation in the Implementation Regulations
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	McKevitt	Brian	University of Nebraska at Omaha School Psychology Program	As graduate educators in a school psychology program, we believe it is imperative that section A.1.d. indicate that school psychology training should or must (not may) require training beyond that required for an accreditation HSP Master's program to qualify for entry-level practice. As many comments have indicated, school psychology training requires a minimum of 3 years of graduate study and a supervised internship, which is well above the standard proposed here. Our program requires 4 years of study and 72 credit hours for the entry level credential. If the HSP standard does not clearly address well-established training standards in school psychology, we are concerned that under-qualified or non-qualified individuals could seek credentialing.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Bohan	Kathy	Arizona Association of School Psychologists	NASP requires school psychologists to have a specialist-level or above training that includes a minimum of 60 graduate credit hours, as well as a supervised minimum of 1,200 hours of internship. Arizona’s requirements for a school psychology certificate reflect similar criteria. It is critical that credentialing into entry level positions in school psychology align with the decades of well-established professional training endorsed by NASP. The scope of practice and required competencies needed in today’s complex school environments demands that school psychologists be well-equipped to meet the complex needs of students, families, teachers, and communities.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Julene	Robbins		As a former lead psychologist in Arizona responsible for hiring school psychologists as well as a licensed trainer earlier in my career, I would encourage APA to simply remove the reference to school psychology altogether from their description of HSP program possibilities. Candidates for employment as a school psychologist in Arizona as well as other states following NASP practice standards for entry certification would find themselves disappointed at not being able to enter the work force as a school psychologist. Entry level for school psychologists in Arizona must be trained at the specialist level or its equivalent and an HSP program graduate would not meet that criteria.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	McLendon	Katie		It is vital that APA recognize that the specialist-level degree is the minimum standard for practice as a school psychologist. It should also be noted that the title of school psychologists only be used after meeting the minimum requirements (at the specialist-level) through a NASP-approved or NASP-accredited graduate training program in school psychology. NASP has developed comprehensive Standards for graduate preparation and credentialing that establish the minimum expectations for competency in school psychology practice, and these high-quality Standards should remain the basis for training and practice in school psychology.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Samara	Way		I appreciate the opportunity to comment on the proposed master’s level accreditation in Health Services Psychology. My state of residence requires a master’s or more advanced degree of 60+ graduate hours (i.e., specialist-level degree) from a school psychology program, along with a 1200 hour supervised internship for initial credentialing as a school psychologist. These minimum requirements, which are consistent with the standards of the National Association of School Psychologists, are critical in ensuring that school psychologists are adequately prepared to meet the wide-ranging mental, behavioral health and learning needs of children. Despite the addition of a statement indicating that “some areas of pre-doctoral specialization, such as school psychology, may require training beyond that required for an accreditation HSP Master’s program to qualify for entry-level practice in those areas”, I remain concerned that the proposed HSP accreditation standards as written may lead to pre...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Sharon	Berry	APA Division 38, Society for Health Psychology	Division 38 Society for Health Psychology: A. Additional clarity may be needed with regard to scope of practice somewhere in the document. We understand that the devil is in the details, but scope of practice was a huge question for many when moving forward with Master’s Accreditation, which was approved by CoR. Most important will be to highlight the distinction between HSP and the specialty of Clinical Health Psychology, and to outline the HSP definition used to guide these standards (e.g., Blueprint for the Future of Health Service Psychology, National Register, etc.). A1a. We recommend the following language to replace “Practice is evidence-based, and evidence is practice-informed.” Instead: Practice is evidence-based, and research is practice-informed. A.1.d.i: We recommend further clarity by indicating (e.g., Educational Specialist degree, Ed.S.) A.2.: Practice Area: Given that Master’s training programs are pre-doctoral, it will be important to focus solely on HSP pr...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Bradley	Petry	Maryland School Psychologists' Association	The Maryland School Psychologists' Association (MSPA) thanks The APA Commission on Accreditation for responding to public comments and suggestions from our national professional organization, the National Association of School Psychologists (NASP). In concert with NASP's current comments and suggestions, MSPA would also like for the Commission to consider the inclusion of specifically indicating “Specialist-level” in addition to doctoral, consistent with the description in Standard I.A.d.i. for the requirements of practicing school psychology. In addition to the label, please note that NASP has defined Specialist-level degrees standards for graduate preparation and credentialing refer to “specialist-level” training for entry to practice as a school psychologist rather than the “specialist degree” or EdS. Specialist-level graduate preparation, as defined by NASP Standards, require the following: • A minimum 3 years of graduate study, consisting of 60 hours of graduate credit or the ...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Laurie	Klose		Thank you for the clarifying remarks regarding specialist level training for school psychology.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Patrick	Ballard	Kentucky Association for Psychology in the Schools (KAPS)	On behalf of the Kentucky Association for Psychology in the Schools (KAPS), we feel that any language that reduces the minimum training to be called a school psychologist from a Specialist level to a Masters level to be a move that would set back gains made to show the importance of a well and thoroughly trained school psychologist in our state (as well as across the country). While I can appreciate the push to offer programs to be broader and thus open students who are participating in these programs to a wider range of job opportunities upon receiving a Master's Degree, as a practicing school psychologist for over 20 years and supervising countless practicum and internship level students, I worry that giving students the opportunity to obtain a degree that does not adhere to the high standards set forth over many decades by the National Association of School Psychologists and still being able to call themselves "school psychologists" is not only misleading to potential employers who ...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Misty	Lay		As a specialist-level school psychologist, I am not in agreement with the minimum standards outlined in this master’s degree in HSP proposal, specifically regarding school psychology. The National Association of School Psychologists (NASP) has established the minimal standards for graduate training of school psychologists. The specialist degree is the minimal training credential and typically requires a minimum of 60 graduate training hours, in addition to an internship that is at least 1,200 hours (with 600 of those hours being in a school setting). As a practitioner for 23 years, I understand the complex systems of education and schools. As outlined in the NASP Practice Model Standards, the amount of knowledge required to practice school psychology goes beyond the field of psychology. Extensive training in special education law, including policies and procedures, classroom management, multi-level systems of support (MTSS), prevention, crisis response, trauma, and family and comm...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	James	Loveless	Middle Tennessee State University Clinical Psychology Faculty	The clinical psychology faculty at Middle Tennessee State University thanks you for the opportunity to participate in this process. While we applaud the Commission on Accreditation’s (CoA’s) attempt at creating accreditation standards for master’s level health services psychology (HSP) programs, we find it difficult to evaluate the usefulness of these standards in the absence of clearly defined training competencies at the master’s level. Given that the commission intends on creating a unique set of implementing regulations for master’s level accreditation, there is an assumption that the competencies listed therein will be divergent in some way from those expected at the doctoral level. This appears at odds with the commission’s statement that, “the breadth and depth coverage for master’s degrees are designed to be comparable to that which is required in accredited doctoral level training.” Our clinical psychology master’s program exists within a state where the training of master’s l...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Ashley	Hudson		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards the well-established NASP standards, which govern the quality of school psychologists practicing in the field and sets minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, learn the best practices in program evaluation, progress monitoring, interventions and instructional support, as well as effectively collaborate and consult with school members, families and community members cannot b...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Jeannine	Topalian	CASP (California Association of School Psychologists)	As mentioned by other commentators, it is critical that APA recognizes that the specialist-level degree (e.g., EdS) represents the minimum standard for practice as a school psychologist. School psychologist's expertise in mental health and education systems requires extensive training beyond the master's level. Moreover, the role of school psychologists has evolved requiring high standards in training programs to address the unique and multifaceted needs of students in grades pre-k (including Infant/Early Start programs) through Adult Transition Programs (Age 22). School Psychology graduate students receive rigorous instructions and practice-based field/intern experiences to meet the needs of children, families, and the school community which is far more than a master's level psychology student receives. According to the California Commission on Teacher Credentialing, the governing body that issues the Pupil Personnel Services credential in School Psychology, a school psychology pro...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Amanda	Craven		School Psychologist should be required to have an accredited NASP approved Education Specialist degree to safely, justly, and with integrity practice as a school psychologist with children. A master's level degree is not adequate training to be labeled a "psychologist." This would be a great disservice to our schools, families, and to our children.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Diane	Herrick		As a specialist-level school psychologist, I am not in agreement with the minimum standards outlined in this master’s degree in HSP proposal, specifically regarding school psychology. The National Association of School Psychologists (NASP) has established the minimal standards for graduate training of school psychologists. The specialist degree is the minimal training credential and typically requires a minimum of 60 graduate training hours, in addition to an internship that is at least 1,200 hours (with 600 of those hours being in a school setting). As a practitioner for over 23 years, I understand the complex systems of education and schools. As outlined in the NASP Practice Model Standards, the amount of knowledge required to practice school psychology goes beyond the field of psychology. Extensive training in special education law, including policies and procedures, classroom management, multi-level systems of support (MTSS), prevention, crisis response, trauma, and family and...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Anna	Freeman		As a doctoral-level school psychologist, I do not agree with the minimum standards as outlined in the HSP master’s degree proposal regarding school psychology specifically. The National Association for School Psychologists (NASP) has established training standards for graduate preparation and credentialing for school psychologists. The HSP degree proposal including school psychologist does not meet the minimal standards set forth by NASP that is supported at a national level. The minimum training credential is the “specialist-level” to practice school psychology. Training programs require a minimum 3 years of graduate study, consisting of 60 hours of graduate credit or the equivalent. A supervised internship experience with a minimum of 1,200 clock hours that culminates in institutional (university) documentation of program completion is also required for the entry level to practice school psychology. School psychology programs provide extensive training in areas beyond the scope of ps...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Braydon	Schilling	Montana Association of School Psychologists (MASP)	The Montana Association of School Psychologists (MASP) thanks the APA Commission of Accreditation (CoA), specific to the Health Service Psychology (HSP) master’s degree program, for including the field of School Psychology and for providing an opportunity to collaborate. The MASP is also looking forward to further dialogue with respects to Implementation Regulations. As the efforts to establish more practitioners within the field of psychology as a whole is of upmost importance within our society, so to is making sure that these proposed servicers are adequately equipped with education and sufficient training experiences to provide them with such. It is being recommended that the inclusion of language specific to specialist-level degrees are implemented with your proposed standards. That is, including language to 1.A.d that better specifies the common requirements of proper licensure and credentialing to practice within the specialized field of School Psychology. Additionally, to en...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Betty	Dawson	Texas Assoc. of Psychological Associates	We do not see the benefit or purpose for APA to accredit Masters in Psychology programs when there are already established credentialing bodies which set rigorous standards for these programs.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Betty	Dawson	Texas Assoc. of Psychological Associates	A.1.a. We are glad to see the addition of “psychological science” which will remove any ambiguity in regard to what is permitted as the basis for practice.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Betty	Dawson	Texas Assoc. of Psychological Associates	A.1.d. There are additional areas of pre-doctoral specialization which may include training beyond the suggested standards for the HSP Masters for practice in the area. We are glad that APA recognizes this.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Betty	Dawson	Texas Assoc. of Psychological Associates	A.2. We concur with the inclusion of additional practice areas, including the possibility of some not mentioned.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Pamela	August	Missouri Association of School Psychologists	While the comments note that the standards do not preclude a doctoral program from offering a master’s degree, and the comment later alludes more broadly to a “post-master’s degree”, we suggest including “specialist-level” in addition to doctoral, consistent with the description in Standard I.A.d.i.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Shawna	Kelly		I appreciate the addition in A.1.d. which acknowledges that some areas, specifically school psychology, require training beyond that required in a traditional master's degree program. It is critical that APA recognize that the specialist-level degree represents the minimum standard for entry into practice as a school psychologist. This degree typically requires more training (as reflected in credit hours) and significant field experience (e.g., 1200-hour internship, 600 of which must occur in a school setting). It is also critical to recognize and acknowledge that NASP has developed comprehensive Standards, effective July 2020, for graduate preparation and credentialing that establish the minimum standard for competency in school psychology practice. These Standards should remain the minimum standard for training and practice in school psychology. This is incredibly important given the increasing demands in the field, as well as the expectations for practice in a broad-based role to a...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Rachel	Moss		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Jazmine	Rodriguez		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Callahan	McIlnay		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Sarah	McKee		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Debbieann	Santana		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Emily	Vulcano		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Randall	Horton	Faculty of the Master of Arts in Psychology program of Seattle University	As members of a Master’s degree program housed in a department of psychology that has for 39 years focused upon the task of training students to become effective clinicians, counselors, and therapists we applaud the decision of the APA to examine accreditation of master’s level clinical training programs. We believe that for far too long, the APA has stood by as professional advocacy organizations housed in related fields, such as counselling education and social work, have lobbied for influence in the process of health care regulation. The APA’s inaction has allowed these disciplines to shape licensing and educational standards to reflect the contours of their disciplines, while introducing barriers to the ability of programs based in departments of psychology, staffed by clinical and research psychologists, to provide a reliable, straightforward path for master’s level graduates to enter clinical practice and enjoy portability of licensure across state jurisdictions. We believe the d...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Randall	Horton	Faculty of the Master of Arts in Psychology program of Seattle University	While the document places essential weight upon the construct of “evidence-based practice”, it does nothing to define or offer explicit guidance as to how this term should be understood by programs or the auditing body. Further, through the limited scope of research methods and the framing of psychological science that it presents, the document seems to implicitly endorse a very narrow understanding of evidence-based practice, one that is in discord with the APA’s own (2006) definitions. We believe this is a very serious issue. The SoA M proposal document states: “a program that is accredited in health service psychology must demonstrate that it contains the following elements: a. Integration of psychological science and practice: Practice is evidence-based, and evidence is practice-informed.” This is an anchoring point of the document. It begs the question, what do “evidence-based practices” and “evidence that is practice-informed” actually consist of? How do we dist...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Emily	Klein	Delaware Association of School Psychologists	The Delaware Association of School Psychologists (DASP) wishes to thank the Commission on Accreditation (CoA) for all its thoughtful and hard work on behalf of the education and training of professional psychologists who deliver health service psychological services. We appreciate the CoA’s efforts to address the shortage of mental health professionals by considering accreditation of non-doctoral level programs. With all due respect to the high level of professionalism and the hard work evident in the CoA’s draft standards and processes for accrediting Masters’ degree programs in Health Service Psychology, DASP wishes to submit the following comments/recommendations for consideration. All of these comments/recommendations are specific to the School Psychology branch of Health Services Psychology, in keeping with our area of expertise. A.1. – Type of Program In this section, there is reference made to a “specialist degree.” This term may be inadvertently exclusive of specialist-leve...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Jared	Dart	Virginia Academy of School Psychologists	VASP supports the “specialist-level” degree as the entry level certification to work as a school psychologist. The “specialists-level” degree includes a minimum of 60 graduate semester hours, which includes a 1200-hour internship, with at least 600 hours in a school setting and is the minimum criteria to be employed in many states. VASP believes it is important for accredited programs in school psychology to prepare graduates who would be eligible for entry level certification.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Jason	Washburn	Council of University Directors of Clinical Psychology	The CUDCP Board greatly appreciates the opportunity to comment on the Final proposed Standards of Accreditation in Health Service Psychology: Master’s. We are pleased with the changes that were made to the SoA M and believe that the current document provides an excellent foundation on which to build a Master’s level HSP accreditation system. We are especially pleased to see that the focus on the integration of psychological science and practice is emphasized even further in this revision. We understand the Commission’s reluctance to define scope of practice, given their role as an accrediting body. The CUDCP Board believes, however, that it is important for the field to delineate the differences in the scope of practice between Master’s level and Doctoral level HSP. Indeed, the CUDCP Board is concerned with how the CoA will determine “sufficient and appropriate clinical training experiences” for Master’s level HSP programs (Standard IC4g) without delineation of the scope of practice...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Mary	O'Leary Wiley	SCP Division 17 Counseling Psychology	Society of Counseling Psychology (SCP) Comment on Standards of Evaluation of the Master’s Programs in Health Service Psychology (HSP) We believe it is important for the Standards of Accreditation: Master’s to reflect requirements for training at the master’s level which differentiate master’s training from doctoral training. In the document, this point particularly pertains to profession-wide competencies listed in II.B.b. Master’s level competence in contrast to doctoral level competence should be specified particularly in the areas of: i. Integration of psychological science and practice; vi. Assessment; vii. Intervention; viii. Supervision; and ix. Consultation and Interprofessional /interdisciplinary skills. Each of these areas of competency can be differentiated between the master’s and doctoral level. For instance, the supervision competency at the master’s level is gaining the ability to effectively participate in supervision in the supervisee role; in contrast, the doctoral ...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Kisten	Gillespie	WSPA	In the state of Wisconsin, our Department of Public Instruction requires that, at a minimum, to license as a school psychologist, one needs a specialist degree, doctorate, the equivalent, or higher. The Wisconsin School Psychologists Association feels that we need to be very clear on the importance of the intricate role of the psychologist in the school setting, and advocate that the minimum standard of practice remain at the Ed.S degree or higher in regards to licensing and certification of anyone practicing school psychology.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Nicki	Tornabene		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Robert	Rotunda		As a licensed clinical psychologist, faculty member, and graduate coordinator of a masters level counseling program for nearly 20 years, I applaud APA for undertaking this initiative to nationally accredit psychology programs such as ours...it is long overdue. I do suggest supplementing the current proposal in many ways, most importantly by adding specific requirements in the general areas of required credit hours (should be 60), faculty-students ratios, on-site practica/internship training hours (1,000 would cover unique licensure laws in all states), and number of hours of direct service provision under proper supervision (should be minimum of 250 direct client contact hours). I would be more than happy to assist APA in developing rigorous standards.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Alexis	Wageman		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	A. Type of Program	Taylor	Carroll		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	Joan	Simon		As a long-time program reviewer for NASP, I can attest that any NASP accredited school psychology program has these elements in place and does not need APA to further validate them.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	CARRIE	LEWIS		The standards draft includes some form of the word diversity at least 30 times. While a priority, the redundancy not only comes across as fear-based rather than substantive or a reflection of a genuine value of the APA, it is addressed at the exclusion of other important factors within a program’s curriculum, quality measurments, and student rights. Consider rewording item 2 to something such as: “Administrative Responsibilities Related to Cultural and Individual Differences and Diversity. The program recognizes the importance of cultural and individual differences and diversity in the training of psychologists. The Commission on Accreditation defines cultural and individual differences and diversity as including, but not limited to, age, ethnicity, gender, race, religion, sexual orientation, and socioeconomic status. Additionally, the Commission recognizes the intersection and fluidity of these and other aspects of diversity. The program has made objective efforts to attract and ret...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	James	Loveless	Middle Tennessee State University Clinical Psychology Faculty	Part I, Section B, Subsection 1, Point b: The commission specifies that HSP master’s programs should be integral to the missions of the institutions which house them, and then goes on to state that there should be evidence of steady and sufficient funding/support for programs by their respective parent institutions such that programmatic aims might be achieved. Given that all programs could likely use more money and support to better achieve programmatic aims, it would be helpful for the commission to operationally define sufficient support.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	Ashley	Hudson		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards the well-established NASP standards, which govern the quality of school psychologists practicing in the field and sets minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, learn the best practices in program evaluation, progress monitoring, interventions and instructional support, as well as effectively collaborate and consult with school members, families and community members cannot b...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	Amanda	Craven		School Psychologist should be required to have an accredited NASP approved Education Specialist degree to safely, justly, and with integrity practice as a school psychologist with children. A master's level degree is not adequate training to be labeled a "psychologist." This would be a great disservice to our schools, families, and to our children.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	Jackie	Tyson	Board of Educational Affairs	1.B.1.A. 3. We ask that the Commission be sensitive to the way it uses the word “diverse” throughout the document. Diverse refers to differences that exist within groups; however, when used to describe individuals, it is typically coded language to identify an individual holding minority status within a larger group (e.g., diverse referring to non-White individuals). Please be attentive to use diverse as a descriptor of groups (e.g., diverse faculty) instead of individuals (e.g., individuals who are diverse).
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	Rachel	Moss		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	Jazmine	Rodriguez		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	Jazmine	Rodriguez		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	Callahan	McIlnay		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	Sarah	McKee		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	Jill	Talley		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	Ritu	Verma	APAGS	We propose the following sentence be amended as “The program has made MEASURABLE systematic, coherent, and long-term efforts to attract and retain students and faculty from diverse backgrounds into the program.” We believe that in making these efforts “measurable”, programs will then have outcome data. This data could be used by APA in their accreditation evaluation processes to identify strengths, limitations, and problem areas in programs
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	Debbieann	Santana		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	Emily	Vulcano		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	Emily	Klein	Delaware Association of School Psychologists	The Delaware Association of School Psychologists (DASP) wishes to thank the Commission on Accreditation (CoA) for all its thoughtful and hard work on behalf of the education and training of professional psychologists who deliver health service psychological services. We appreciate the CoA’s efforts to address the shortage of mental health professionals by considering accreditation of non-doctoral level programs. With all due respect to the high level of professionalism and the hard work evident in the CoA’s draft standards and processes for accrediting Masters’ degree programs in Health Service Psychology, DASP wishes to submit the following comments/recommendations for consideration. All of these comments/recommendations are specific to the School Psychology branch of Health Services Psychology, in keeping with our area of expertise. DASP is appreciative of the inclusion of intersectionality in the administrative responsibilities related to cultural and individual differences and d...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	Nicki	Tornabene		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	Alexis	Wageman		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	B. Institutional and Administrative Structure	Taylor	Carroll		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Joan	Simon		There is absolutely NO NEED for APA to accredit a 2-year MS program in School Psychology when NASP accredits programs that are a minimum of 3 years of coursework and applied experience, and the 3 year program is entry level for licensure as a School Psychologist.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Helen	Brantley		I think the clarification on length of time of study is helpful.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Erich	Merkle		The HSP of school psychology master's programs continues to represent an awkward intersection of psychology and school psychology within the credentialing process of HSP master's programs. As countless comments have already revealed, school psychology is unique in that it exists in both the doctoral and non-doctoral level of practice, with approximately 70% of practitioners working in the non-doctoral level of training. School psychology is also distinct in that its occupational licensure is dictated not only by state psychological occupational boards but also state boards of education. Non-doctoral school psychology programs already exist under approval by NASP and represents the "specialist level of training," which includes both a master's and post-masters (eg EdS or PsyS) degree. HSP master's programs would not comport to the licensure requirements in any state for this specialist level of preparation. As a consequence, these HSP master's programs that emphasize school psychology w...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Vanessa	Brown		I'm not seeing the evidence related to length of program. There are excellent Master's degree training programs that are completed earlier than 2 years. In Michigan, a master's degree is sometimes earned as a part of a pursuing a doctoral degree whereby courses and practicum work are completed in a 12 month intensive program. These students are dedicated, motivated, and wonderful clinicians that I have both supervised and hired at my private practice.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Lisa	Spanierman	Faculty of Counseling and Counseling Psychology	The faculty of counseling and counseling psychology at Arizona State University welcome APA’s efforts to develop standards of accreditation at the master’s level. This is long overdue. Currently, psychology has little influence in the academic preparation of tens of thousands of master’s-level graduates each year, which is regulated primarily by CACREP. In 2018 for example, CACREP told us at ASU that we must use textbooks authored by counselor educators, not psychologists. Despite meeting their criteria, they refused to consider several of our counseling psychologists as core faculty for the master's program. CACREP aggressively is pushing counseling psychology out of universities and instead is proliferating new programs in online and for-profit institutions. At the same time, CACREP is lobbying states to license only those master’s-level clinicians that graduated from CACREP-accredited programs. With its strong reputation for promoting excellence in graduate training, APA is in ...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Sharon	Berry	APA Division 38, Society for Health Psychology	Division 38 Society for Health Psychology: C.1.a: Program Leadership: We recommend elimination of the final sentence in this section: This leadership position may be held by more than one individual. Unless clarified, this makes little sense given the historical expectation for a single Director of Training. C.4.f.g: We recommend further clarity regarding the definition and intent of “sufficient and appropriate” – possibly through an IR.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Titina	Brown	Association of School Psychologists of Pennsylvania	The Association of School Psychologists of Pennsylvania appreciate the opportunity to provide the viewpoint of hundreds of professionals from across the State of PA who work each day to ensure the highest quality of services are provided to our students and families. The current HSP Accreditation at the Masters Level fails to improve upon the existing state and national standards for School Psychology already in place. As pointed out by NASP’s response, standards for graduate preparation and credentialing require a minimum 3 years of graduate study, consisting of 60 hours of graduate credits AND a supervised internship experience with a minimum of 1,200 clock hours. Anything less than these standards would not adequately prepare a student to become a practicing professional in the field of School Psychology. It is the position of the Association of School Psychologists of Pennsylvania that APA endorsement of specialist-level training and NASP approval and accreditation in the Imple...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Ashley	Hudson		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards the well-established NASP standards, which govern the quality of school psychologists practicing in the field and sets minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, learn the best practices in program evaluation, progress monitoring, interventions and instructional support, as well as effectively collaborate and consult with school members, families and community members cannot b...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Amanda	Craven		School Psychologist should be required to have an accredited NASP approved Education Specialist degree to safely, justly, and with integrity practice as a school psychologist with children. A master's level degree is not adequate training to be labeled a "psychologist." This would be a great disservice to our schools, families, and to our children.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Betty	Dawson	Texas Assoc. of Psychological Associates	I.C.2.a. We appreciate the addition of wording which recognizes the value of requiring the graduate study needed for licensure in the jurisdiction.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Betty	Dawson	Texas Assoc. of Psychological Associates	I.C.4. We appreciate the additions in “f.” and “g.” which clarify and strengthen these required resources, making them more valuable for students.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Rachel	Moss		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Callahan	McIlnay		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Sarah	McKee		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Ritu	Verma	APAGS	On page 7 (C4. Resources) - We still encourage the consideration of specifying programmatic support for students seeking master’s level clinical placements (such as a practicum coordinator) who can provide administrative support, as well as support organizing requirements related to placement and application materials. This can be a particularly daunting process for master’s students who are located in cities with numerous doctoral programs, and designating resources to support students in obtaining a placement that meets the requirements of their degree is recommended. We believe that the identification of this staff person as a part of the requirements for accreditation would be beneficial for not only trainees, but also to ensure that programs that provide these resources for their students are recognized in the accreditation process. We suggest the following edit to explicitly state the needs which may otherwise compromise mental health needs of vulnerable students. Change “health”...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Ritu	Verma	APAGS	Part I, Section C: Program Contexts and Resources, item 4 Resources, part (b) clerical, technical, and electronic support. We think further clarification of this section will help protect student needs by clearly stating expectations from programs/universities. For example, some universities provide access to software, electronic course management systems and research databases while some others do not. In the latter scenario, additional burden and financial responsibility fall upon students to ensure academic success. Therefore, distinguishing the need to offer TECHNOLOGY PLATFORMS (word processing software, email, course management software, both qualitative and quantitative data analysis tools etc.) separate from offering “clerical, technical and electronic support” would help mitigate this issue. Hence, we suggest adding a new section to address technology needs of students.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Ritu	Verma	APAGS	Part I, Section C: Program Contexts and Resources, item 2 (b) of Length of Degree, Delivery Method, and Design. We think that the requirement for students to complete “half of the training (or the equivalent thereof)” reads as somewhat ambiguous, as it could indicate academic study, clinical training, or both. Depending on how the practicum and coursework are designed, this could also result in some students opting to take additional classes at one school and fulfilling practicum requirements at another school. We recommend that CoA clearly defines what aspects of academic requirements are and are not considered under “half of training (or the equivalent thereof).” We also recommend specifying these requirements in credit hours to reflect what is meant by half of the training (or the equivalent thereof)“.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Ritu	Verma	APAGS	We appreciate the attention paid to the need for programs to plan for the acquisition of services to support students with financial, health, and personal issues. We encourage the expansion of this guideline to include support for students experiencing food insecurity, housing insecurity, and insufficient access to childcare.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Debbieann	Santana		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Emily	Vulcano		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Nicki	Tornabene		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Alexis	Wageman		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	C. Program Context and Resources	Taylor	Carroll		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	D. Program Policies and Procedures	Joan	Simon		NASP sufficiently covers these areas in their accreditation process for EdS programs in School Psychology. There is NO NEED for APA to get involved in accreditation of MS programs in School Psychology.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	D. Program Policies and Procedures	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	D. Program Policies and Procedures	Sharon	Berry	APA Division 38, Society for Health Psychology	Division 38 Society for Health Psychology: D.1.a: We recommend elimination of the phrase “students who are diverse” or “faculty who are diverse” throughout the document. In general, we recommend “a diverse student body” or “a diverse group of faculty– but suggest the review all sections of the document to maintain consistency and accuracy.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	D. Program Policies and Procedures	Ashley	Hudson		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards the well-established NASP standards, which govern the quality of school psychologists practicing in the field and sets minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, learn the best practices in program evaluation, progress monitoring, interventions and instructional support, as well as effectively collaborate and consult with school members, families and community members cannot b...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	D. Program Policies and Procedures	Rachel	Moss		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	D. Program Policies and Procedures	Jazmine	Rodriguez		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	D. Program Policies and Procedures	Callahan	McIlnay		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	D. Program Policies and Procedures	Sarah	McKee		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	D. Program Policies and Procedures	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	D. Program Policies and Procedures	Ritu	Verma	APAGS	We again appreciate and support the mention of nondiscrimination (page 7, D. Program Policies and Procedures -1G). However, in addition to nondiscrimination policies, we recommend adding a statement regarding the importance of policies that promote diversity and inclusion, including a greater emphasis on, and accountability processes for, recruiting people of color. It would be helpful to highlight some specific actions that demonstrate understanding of cultural and individual diversity. For example, does this include having seminars on diversity, all gender restrooms, inclusive language, ongoing training on cultural diversity for staff? We believe this edit would strengthen the document to specify what programs should be doing to cultivate respect for diversity in particular (beyond recruitment of diverse students and faculty, which is already addressed in the proposed SoA), and rather specify that programs need to actively build in ways to be inclusive and accountable.
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	D. Program Policies and Procedures	Debbieann	Santana		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	D. Program Policies and Procedures	Emily	Vulcano		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	D. Program Policies and Procedures	Nicki	Tornabene		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	D. Program Policies and Procedures	Alexis	Wageman		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	I. Institutional and Program Context	D. Program Policies and Procedures	Taylor	Carroll		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Linda	Michaels		It's very unfortunate that the APA MA program seems to be focusing more on research, just as medical training is moving in the opposite direction -- away from basic science and research, and more into clinical skills of empathy, relationship-building and listening to patients. This represents huge losses for the field of psychology, for new therapists in training, and for the patients they will care for, as the vast majority of psychologists -- and surely even a greater percentage of MA graduates -- will become clinicians, not researchers. In addition, I endorse the comments of the Psychotherapy Action Network (PsiAN).
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Jeffrey	Axelbank		The APA’s proposal for the accreditation of master’s degree programs in psychology reflects the same problematic constriction in clinical training as is apparent in its criteria for doctoral, internship and post-doctoral training, although amplified in this case due to the far shorter duration of master’s programs in general. The discipline-specific knowledge it prescribes, to be acquired through courses either at the graduate OR the undergraduate level, covers territory similar to that prescribed for doctoral programs – a territory devoid of the study of the inner lives and psyches of patients in favor of neuropsychological, biological and cognitive approaches. The study of these approaches is bolstered by an emphasis in graduate programs upon research design and data analysis, nearly all of which is quantitative in nature, with a passing nod to qualitative and mixed methods. (Adding “single-case design” to the list of research methods the program teaches, it should be emphasized, ...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	James	Loveless	Middle Tennessee State University Clinical Psychology Faculty	Part II, Section A The wording of this section fails to include programmatic aims which are guided (or restricted) by existing state/jurisdictional laws and regulations with respect to the training and practice of psychology at the master’s level.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Ashley	Hudson		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards the well-established NASP standards, which govern the quality of school psychologists practicing in the field and sets minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, learn the best practices in program evaluation, progress monitoring, interventions and instructional support, as well as effectively collaborate and consult with school members, families and community members cannot b...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Amanda	Craven		School Psychologist should be required to have an accredited NASP approved Education Specialist degree to safely, justly, and with integrity practice as a school psychologist with children. A master's level degree is not adequate training to be labeled a "psychologist." This would be a great disservice to our schools, families, and to our children.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Betty	Dawson	Texas Assoc. of Psychological Associates	II. A. Programs purporting to be in the science of psychology should have measurable Goals, rather than Aims which are usually considered to be more aspirational and less measurable.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Rachel	Moss		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Jazmine	Rodriguez		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Callahan	McIlnay		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Sarah	McKee		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Jill	Talley		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Jill	Talley		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Jill	Talley		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Debbieann	Santana		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Emily	Vulcano		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Randall	Horton	Faculty of the Master of Arts in Psychology program of Seattle University	We are concerned that that the tone and language that frames these standards feels almost anti-humanistic. At key points in the document, the instructors and students seem to be framed as “consumers of scientific research” and the implicit model of clinical formation feels like that of training of technicians. While these can be helpful metaphors for thinking about some facets of clinical education and practice, by themselves, we feel they are insufficient to characterize the goals or formative ideals of clinical education. We believe that including a statement of intent with these standards, one cast in a more humanistic register, would be appropriate. Further, we believe that ideally, it should include an articulation of the APA’s ethical commitment to serving the needs of diverse individuals and communities. Here, for instance, is a statement modeled on that of the Duquesne University clinical doctoral program, that might serve as a template for what we are suggesting: “In...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Nicki	Tornabene		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Shannon	Chavez-Korell	Michigan School of Psychology	The formal recognition and licensing of Master’s-level psychology clinicians is essential, as this will greatly increase access to desperately needed psychological services across the U.S., and specifically in rural and marginalized communities. Although we support this effort, we have concerns about the proposed standards of accreditation. The required 2-years of training needs further clarification and flexibility, as not all institutions operate on the same academic calendar or with the same semester course load (e.g., trimesters vs. 2 semesters per academic year). It is unclear how the master’s domains of competence differentiate from doctoral training. The aims, competencies and curriculum reflect scientist-practitioner training models, as opposed to being inclusive of practitioner-scholar models. In addition, the DSKs are strongly focused on research as opposed to theory and practice. It is problematic that the research methodology identified within this document is exclusively q...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Alexis	Wageman		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	A. Aims of the Program	Taylor	Carroll		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Joan	Simon		NASP accreditation addresses the content needed for the EdS in School Psychology. Since the EdS is the entry level degree for our field, it makes no sense nor is there a need for APA to deal with School Psychology MS programs.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Helen	Brantley		The program competencies are inclusive.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	CARRIE	LEWIS		(a) Affective Aspects of Behavior, including topics such as affect, mood, and emotion. Psychopathology and mood disorders do not by themselves fulfill this category. -defining affective aspects with the words affect, mood, and emotion is redundant and vague. (d) Developmental Aspects of Behavior, including transitions, growth, and development across an individual’s life. A coverage limited to one developmental period (e.g., infancy, childhood, adolescence, adulthood, or late life) is not sufficient. -defining developmental aspects with words: transitions, growth, and development does not inform curriculum content. Developmental aspects should address typical development across the lifespan, including similarities and differences across time/place/culture/etc., the impact various environmental factors can have on development (e.g., trauma) including long-term trajectories and relationship to psychopathology. iii. Equity, diversity, inclusion, and social justice -Diversity i...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Andrew	Bland		I have strong reservations about qualitative methods having been removed from the description of research related to practice (Section B-1-a-ii). I encourage the authors to reintroduce an explicit reference to qualitative methods as a legitimate contribution to psychological science. In addition, I find it troubling that (a) the only mention of coursework pertaining directly to the practice of counseling/psychotherapy/school psychology is relegated to Section B-1-b and (b) in that section, there is no mention at all of knowledge/understanding of a variety of theoretical/philosophical perspectives as a specific competency. Both of these should be front and center of the training experience of helping professionals at the masters level. Moreover, I believe the authors should explicitly include therapeutic relationships (beyond merely "communication and interpersonal skills") as a competency in Section B-1-b, given that approximately 70 years of research has consistently demon...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Andrew	Bland		In Section B-1-a-i, it seems that the 5 knowledge domains (affective, biological, cognitive, developmental, and social aspects of behavior) should be expanded to include "experiencing" as well as behavior. Further, the "integration" of these aspects in the work of masters-level helping professionals--and in people's lives in general--needs to be explicitly emphasized; to treat them as isolated runs the risk of promoting a myopic curricular structure (i.e., "a mile wide and an inch deep").
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Carrie	Ball		It is critical that APA recognize that the specialist-level degree (e.g., EdS) represents the minimum standard for practice as a school psychologist. This is considered an advanced practice degree and typically requires far more credits (i.e., at least 60 semester hours) and far more supervised field experience (i.e., practicum plus a 1200-hour internship) than most master's degree programs in other areas of psychology. The National Association of School Psychologists (NASP) maintains comprehensive Standards for graduate preparation and credentialing that establish the minimum expectations for school psychology practice, and these Standards should remain the basis for training and practice in school psychology. Accreditation of “master’s level programs” through APA may result in programs that are not equivalent to NASP Standards and thus enable inadequately trained professionals -- particularly individuals with inadequate supervised clinical experiences -- to assume roles in schoo...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Daniel	McCleary		I'm concerned about individuals potentially becoming licensed with the limited coursework and fieldwork outlined herein. This move would devalue the field and would be ineffective at addressing any workforce shortages by elevating inadequately trained individuals.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Vanessa	Brown		It seems vital that students be aware of both qualitative and quantitative analysis. The exclusion of qualitative research would be a detriment to our profession.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	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
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Todd	DuBose		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).
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Michelle	Schultz		I support the comments of NCSPP.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Ryan	Blackstock		The requirement of 2 years of training will adversely impact programs that function on an "accelerated" timeline ( 1 year, 18 months, etc.). The 2 year time requirement seems like an unreasonable demand, and should rather be focused around what must be accomplished within a program. Also, half of the training to be completed in the program seems like a strange expectation. Are we now mandating how many hours can transfer? Can someone do a program online for the first half then transfer into another program because they prefer the practicum opportunities? This expectation seems potentially damaging. Is this the same for doctoral programs, that a doctoral student can do half of their program somewhere? The research requirements you have outlined are ALL QUANTITATIVE. If you are really interested in Equity, diversity, inclusion, and social justice, then QUALITATIVE research, and its facets, need to be included on that list in ii A and B.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Raskin	Jonathan	Society for Humanistic Psychology	We believe that the proposed accreditation standards for master’s programs inadequately prepare trainees to deliver effective, evidence-based, and sustainable therapeutic services. First, the scope of the 5 knowledge domains identified in Section B-1-a-i is precariously limited in that it overemphasizes observable, measurable “behavior” without also accounting for the numerous evidence-based dimensions of individuals’ inner lives. Accordingly, we believe that the language should be expanded to also include “experiencing.” Second, the current treatment of the 5 knowledge domains as isolated promotes both (a) a myopic curricular structure (i.e., "a mile wide and an inch deep”) and (b) a meagerly fragmented portrait of human nature. Accordingly, we believe that “integration” of these domains needs to be explicitly emphasized to better account for their holistic reality. Third, we believe that qualitative methods should be restored in the description of research related to pr...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Sharon	Berry	APA Division 38, Society for Health Psychology	Division 38 Society for Health Psychology B.1.a.i: We recommend further clarification of option “…meet the following areas of knowledge at either the undergraduate or graduate level (Category 1): How will programs operationalize the criteria for accepting relevant courses? If courses are taken at the undergraduate level, the knowledge gained should be comparable to a graduate-level course. Likewise, reducing the anticipated 2 year curriculum to less than this duration, is inconsistent with graduate training and implies that Psychology Master’s training does not exceed or excel compared to other non-psychology master’s degree programs. 1.a.i and 1.a.ii: We recommend further clarification of the confusing descriptions: Category 1 and Category 2. 1.a.ii.(b): We recommend additional categories for research options related to practice including: intervention design and analysis, human subjects research ethics to the section beginning with “Research related to practice…” ...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	REGINA	ULIANA		I read through this proposal. What should be ordered properly is the discipline specific knowledge: It is time that Psychology place that Cognition, cognitive studies, the mind is what governs or in behavioral terms "regulates all other aspects. It's time that Psychology study the mind and all its dimensions and realms, not from a behavioral perspective but a mind perspective, that is people have ideas, beliefs, opinions knowledge, understanding, these concepts need to be more carefully studied and how each affects the other aspects of behavior, social, affect, etc. We need to turn the glass up right rather than up side down which has been so for decades that is has been dominated by behaviorism influenced by the medical model and do what Psychology should be properly focused on The Mind, asking what is it, what are it's dimensions and what are the tools that would best be able to study and discover its parameters. The first tool should include dialogue, that is in every school ...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	James	Loveless	Middle Tennessee State University Clinical Psychology Faculty	Part II, Section B, Subsection 1 We appreciate and encourage the commission’s acknowledgement of the value of undergraduate training in the field of psychology. Allowing students the ability to demonstrate discipline-specific foundational knowledge via their undergraduate training allows graduate programs to focus their curricula and resources on more specified aspects of training.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	James	Loveless	Middle Tennessee State University Clinical Psychology Faculty	Part II, Section B, Subsection 1, Point a, Subpoint i(a) With respect to fulfilling the Affective Aspects of Behavior area of competency, the commission makes a point to note that, “psychopathology and mood disorders do not by themselves fulfill [the] category.” What additional courses would be sufficient to fulfill this category? Examples would be helpful.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	James	Loveless	Middle Tennessee State University Clinical Psychology Faculty	Part II, Section B, Subsection 1, Point a, Subpoint ii(a) We appreciate and encourage the commission’s use of language which specifies that master’s level trainees should be informed consumers, as opposed to producers, of research.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	James	Loveless	Middle Tennessee State University Clinical Psychology Faculty	Part II, Section B, Subsection 1, Point b We appreciate and encourage the commission’s use of language which specifies the central role of science and evidence-based practice in their articulation of what should be included in profession-wide curriculum elements.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	James	Loveless	Middle Tennessee State University Clinical Psychology Faculty	Part II, Section B, Subsection 1, Point b As written, the profession-wide competencies section fails to offer a clearly delineated competency area which directly addresses expertise in the types of presenting concerns likely to be experienced in practice. We would recommend that the commission add a point which specifies that students should demonstrate competence in, “psychopathology, learning disabilities, and/or other profession specific foci of clinical attention.”
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	James	Loveless	Middle Tennessee State University Clinical Psychology Faculty	Part II, Section B, Subsection 1, Point b As written, the profession-wide competencies section fails to offer a clearly delineated competency area which directly addresses expertise in the types of presenting concerns likely to be experienced in practice. We would recommend that the commission add a point which specifies that students should demonstrate competence in, “psychopathology, learning disabilities, and/or other profession specific foci of clinical attention.”
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	James	Loveless	Middle Tennessee State University Clinical Psychology Faculty	Part II, Section B, Subsection 1, Point b, Subpoints vi & bvii We recommend combining points vi and vii to read, “Assessment and/or intervention,” in order to allow programs in more restrictive jurisdictions the flexibility to tailor their programing accordingly.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	James	Loveless	Middle Tennessee State University Clinical Psychology Faculty	Part II, Section B, Subsection 3, Point a The commission states that clinical training, “must include supervised experience providing direct services to diverse individuals with a variety of presenting problems, diagnoses, and issues.” We might suggest changing the language to read, “strives to include supervised experiences…,” as there are likely programs which exist in areas where exposure to diverse populations might be difficult.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	James	Loveless	Middle Tennessee State University Clinical Psychology Faculty	Part II, Section B, Subsection 3, Point c The commission states that, “supervision must be provided by appropriately trained and credentialed individuals.” We find this language vague, and would encourage the commission to better define what constitutes an, “appropriately trained and credentialed,” supervisor.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	James	Loveless	Middle Tennessee State University Clinical Psychology Faculty	Part II, Section B, Subsection 3, Point d The language in this section is a bit vague. Who is able to provide the evaluation of students’ clinical abilities via direct observation: practicum supervisors, program core faculty, non-core program faculty, or all the aforementioned?
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Ashley	Hudson		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards the well-established NASP standards, which govern the quality of school psychologists practicing in the field and sets minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, learn the best practices in program evaluation, progress monitoring, interventions and instructional support, as well as effectively collaborate and consult with school members, families and community members cannot b...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Amanda	Craven		School Psychologist should be required to have an accredited NASP approved Education Specialist degree to safely, justly, and with integrity practice as a school psychologist with children. A master's level degree is not adequate training to be labeled a "psychologist." This would be a great disservice to our schools, families, and to our children.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Peggy	Brady-Amoon	Alliance for Professional Counselors	In II B ii (a), we recommend deleting the word "consumption" (does one really consume research?) and replacing that with “use and application of research including primary source…”. In (b), We question the applicability of logic models to master's level training and practice and suggest deleting that requirement. Thank you for your work on this important effort and consideration.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Betty	Dawson	Texas Assoc. of Psychological Associates	II.B.a.i. Classes taught at the undergraduate level are NOT sufficient for mastery of any of the core competencies of psychology. To receive graduate coursework credit, these core competencies MUST be taught only at the graduate level in order to have the depth and breadth needed to provide an adequate foundation for further training in the practice of psychology.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Betty	Dawson	Texas Assoc. of Psychological Associates	II.B.1.a.ii.(c) While it is critically important to understand everything mentioned here, there should also be instruction in the application of assessment instruments, including administration and interpretation.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Betty	Dawson	Texas Assoc. of Psychological Associates	II.B.1.b. i.thru x. As a science relying on the current evidence base, there should be direct instruction required in • Ethical and legal standards • Assessment • Intervention • Supervision and • Consultation A student will NOT be able to learn all of the information required to become competent in these areas without direct instruction. The other competencies may be acquired as an integral part of the students’ participation in academic and experiential activities required by the program.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Betty	Dawson	Texas Assoc. of Psychological Associates	II.B.3.c. Supervision MUST be provided by a professional licensed in Psychology for the clinical supervision to be truly appropriate and meaningful.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jackie	Tyson	Board of Educational Affairs	Under Discipline Specific Knowledge, the SoA notes that master’s programs must cover knowledge of “research related to practice.” While several topics are listed, there is no mention of qualitative research methodologies under this DSK nor in the previous one related to consumption of research. While we understand that all possible research modalities cannot be listed, the emphasis on quantitative research and the omission of qualitative research sends a message – intended or otherwise – devaluing the contribution of qualitative research in evaluating practice-based outcomes. We suggest that qualitative methods be added to DSK (B, 1, a, ii, (b)).
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jackie	Tyson	Board of Educational Affairs	Under Profession Wide Competencies, we suggest that PWC (B, 1, b, vi) be re-worded to state: “Assessment, appropriate to the scope of practice”
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jacob	Marzalik	Advisory Steering Committee for Development of Clinical Practice Guidelines	Thank you for the opportunity to comment on the draft document Standards of Accreditation in Health Service Psychology for Master’s Degree Programs. 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 wh...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Rachel	Moss		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jazmine	Rodriguez		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Callahan	McIlnay		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Sarah	McKee		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Ritu	Verma	APAGS	Part II, Section B, 1. (a), ii. Programs must cover the following areas of knowledge at the graduate level (Category 2): (b) Research related to practice, including topics such as single-case designs, quantitatively describing outcomes, statistical description, logic models, and basic inferential statistics. Most training programs in psychology do not train students in qualitative inquiry therefore produce practitioner-scientists who discount the value of qualitative perspective. We think that qualitative inquiry is an integral part of Health Services Psychology; as practitioners we spend the majority of our time trying to relate to subjective world views of those who we treat. Therefore, it is very important that subjective perspectives are reflected in research findings to deepen our understanding while contributing to the progression of the field. Therefore, we suggest the following edit: Research related to practice, including topics such as QUALITATIVE INQUIRY, single-case design...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Ritu	Verma	APAGS	We recommend that the authors consider the inclusion of an independent course on trauma (acute and perpetual, systemic, historical, racial, etc.) and the provision of trauma-informed clinical services. We recommend emphasizing the importance of integrating equity, inclusion, diversity and social justice throughout the courses (as opposed to these topics being delivered as a one-time lecture during a semester long courses) to facilitate competency building that will be meaningful in service delivery.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Debbieann	Santana		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Emily	Vulcano		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Randall	Horton	Faculty of the Master of Arts in Psychology program of Seattle University	The CoA is clearly concerned about issues of diversity, equity and inclusion in clinical education. We note that this draft document takes several laudable, concrete steps to encourage the programs it might accredit to recruit and retain racially, culturally, and socially diverse faculty and students. However, in terms of how it has framed its standards on curriculum, competencies and leaning objectives, the SoA M document does almost nothing to support curricular innovation or reform in the practice of clinical training. Over the last three decades the APA has made numerous public commitments to address the deep social, economic, and racial/ethnic disparities that exist in health care and mental health today. Yet still, we see the devastating effects of institutional racism on the health and well-being of Black Americans and communities of color. The work of examining and revising our practices to serve the needs of these communities requires that all of us, educators, resea...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jason	Washburn	Council of University Directors of Clinical Psychology	The CUDCP Board appreciates the clarification by CoA that foundational knowledge in the basic content areas (i.e., affective, biological, cognitive, developmental, and social) of psychological science can be obtained at the undergraduate level. Removing requirements for graduate-level evaluated educational experiences in these basic content areas will allow for Master’s HSP programs to focus on the implications of these basic content areas on the practice of health service psychology. We look forward to forthcoming IRs that will articulate a reasonable process for verifying undergraduate evaluated educational experiences in these basic content areas.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Jason	Washburn	Council of University Directors of Clinical Psychology	The CUDCP Board also greatly appreciates the revision of the SoA M to reflect the focus on the consumption of research and on how research directly relates to practice. We believe this change will sharpen the focus of Master’s level HSP program on their ultimate goal of preparing individuals to deliver science-based psychological services to the public. Finally, the CUDCP Board strongly supports the change from “individual and cultural diversity” to “equity, diversity, inclusion, and social justice” in the profession-wide competencies section.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Nicki	Tornabene		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Andrew	Bland	Society for Qualitiative Inquiry in Psychology (Section 3 of Division 5 of APA)	We are pleased that greater emphasis has been placed on cultural competence and social equity in the revised accreditation standards for master's training programs. With that said, we also find it both perplexing and troubling that, in the same breath, qualitative and mixed methods have been removed from the description of research in Section B-1-a-ii, given their utility for examining underresearched populations and for developing social justice-oriented programs of research (Fine, 2016). With its emphases on reflexivity and lived experience, qualitative inquiry in psychology is ideal for (a) systematically valuing and amplifying the natural language of the particularly vulnerable in a multicultural society; (b) honoring the complexities, nuances, and inequities of varying realities; and (c) uncovering possibilities for meaningful and sustainable changes—both individually and collectively. There has been a sharp increase in psychological research that relies on qualitative me...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Shannon	Chavez-Korell	Michigan School of Psychology	The formal recognition and licensing of Master’s-level psychology clinicians is essential, as this will greatly increase access to desperately needed psychological services across the U.S., and specifically in rural and marginalized communities. Although we support this effort, we have concerns about the proposed standards of accreditation. The required 2-years of training needs further clarification and flexibility, as not all institutions operate on the same academic calendar or with the same semester course load (e.g., trimesters vs. 2 semesters per academic year). It is unclear how the master’s domains of competence differentiate from doctoral training. The aims, competencies and curriculum reflect scientist-practitioner training models, as opposed to being inclusive of practitioner-scholar models. In addition, the DSKs are strongly focused on research as opposed to theory and practice. It is problematic that the research methodology identified within this document is exclusively q...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Alexis	Wageman		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	B. Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession	Taylor	Carroll		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Helen	Brantley		More specificity of competencies would be helpful.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	S. Kathleen	Krach		CACREP and NASP accredited / approved programs require a minimum of an Ed.S. degree (or equivalent) to receive approval. Why would a psychology program for practitioners require less than would be expected for any other HSP? As a licensed psychologist in Alabama, I have seen the confusion of the M.S.-level credential (Licensed Psych Associate). In addition, I've worked with individuals with this license, and they are simply not prepared to do the work needed upon graduation from an M.S. degree program. Please re-consider the M.S. degree as the minimum when the field of school psychology has successfully demonstrated that training at least at the Ed.S.-level is needed.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Kimberly	Sherman	Louisiana School Psychological Association	As in many states, entry level certification as a school psychologist in Louisiana requires a 60-credit graduate program, which includes a 1200-hour internship, with at least 600 hours in a school setting. It is important for accredited programs in school psychology to prepare graduates who are eligible for entry level certification and competent to practice in school settings.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Nikki	Sutton		The guidance will need to be extremely clear about what Master's level HSP's in the field of school psychology can and cannot do in practice. Delineating appropriate entry-level practices, knowledge, and skills will be important to avoid potential harm to students and families. Furthermore, it should also be noted that the title of school psychologists be limited to those completing the minimum requirements (at the specialist level) through a NASP-approved graduate training program in school psychology.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Elizabeth	Rizzi	NYASP	NYASP appreciates the inclusion in I.A.d, specifically the reference to school psychology. While previous comments represent potential issues that may emerge within school psychology given the nature of certification of school psychologists within state departments of education across the country, the addition of language referencing the specialist-level degree as entry into the field is a helpful addition. If in fact the APA does endorse specialist-level training and NASP approval and accreditation in the Implementation Regulations, this would mitigate concerns related to accreditation of school psychology programs at the “Master’s level” with standards that do not meet the well-established NASP Standards for Graduate Preparation of School Psychologists (NASP, 2020). Suggested edits/additions in I.A.d. are as follows: HSP Master’s programs prepare students for practice at the Master’s level. Some areas of predoctoral specialization, such as school psychology, should require training b...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Ashley	Hudson		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards the well-established NASP standards, which govern the quality of school psychologists practicing in the field and sets minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, learn the best practices in program evaluation, progress monitoring, interventions and instructional support, as well as effectively collaborate and consult with school members, families and community members cannot b...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Emily	Hines		I am a recent grad of an Ed.S school psychology program (graduated in 2018), and I am deeply upset by this potential change. Looking back on my coursework, there is ABSOLUTELY NO WAY I would have been prepared to be a practicing school psychologist after only having completed enough credits for an MA. There is no way I would be confident in my assessment skills let alone my counseling and crisis intervention skills. In my program we needed 150 hours of practicum I, 600 hours of practicum II, AND a full year internship on top of all of our credit hours. How is an MA going to offer the same level of preparedness and experience for someone to enter the school psychology profession ready to handle what the job requires? In my opinion, this is just an excuse for schools to try to cut corners with their budgets (since the government is not helping enough with public school funds) and hire SEVERELY under-qualified individuals to fill the roles of school psychologists. This is a disservice to ...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Jazmine	Rodriguez		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Callahan	McIlnay		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Sarah	McKee		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Sarah	McKee		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Debbieann	Santana		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Emily	Vulcano		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Nicki	Tornabene		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Alexis	Wageman		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	C. Program-Specific Elements – Degree Type, Competencies, and Related Curriculum	Taylor	Carroll		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	James	Loveless		Regarding outcome reporting discussed under Section 3 of Evaluation of Students and Program, specific language should be added about tracking the enrollment of former students in doctoral training programs as this could also be considered a strong indicator of quality masters training.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	CARRIE	LEWIS		Although there are measurable factors included in program evaluation standards, reliance on self-evaluation is opening the door to exploitation of students and diminishment of the reputation of psychology as a whole.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Sharon	Berry	APA Division 38, Society for Health Psychology	Division 38 Society for Health Psychology D.1.b.i: We recommend the addition of "and provide details regarding graduate placements in subsequent training programs (e.g., doctoral programs)" to the section beginning with “Two years after graduation, .The program must also provide data on students’ job placements and licensure, certification….” D.1.b.ii: We feel that use of “and/or” is problematic with regard to “licensure, certification, and/or employment…”; instead, we recommend that you use AND (and remove or); We also recommend that the outcome metric be the graduate’s professional responsibilities and employment function that is consistent with their program’s HSP training. The reference to “licensure” is problematic as it is unknown if or which states might create licensure at the Master’s level; this seems outside the scope of these Standards which should instead focus on the competencies expected at the Master’s Level. Instead, employment and Master’s level trainin...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Ashley	Hudson		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards the well-established NASP standards, which govern the quality of school psychologists practicing in the field and sets minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, learn the best practices in program evaluation, progress monitoring, interventions and instructional support, as well as effectively collaborate and consult with school members, families and community members cannot b...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Ashley	Hudson		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards the well-established NASP standards, which govern the quality of school psychologists practicing in the field and sets minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, learn the best practices in program evaluation, progress monitoring, interventions and instructional support, as well as effectively collaborate and consult with school members, families and community members cannot b...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Amanda	Craven		School Psychologist should be required to have an accredited NASP approved Education Specialist degree to safely, justly, and with integrity practice as a school psychologist with children. A master's level degree is not adequate training to be labeled a "psychologist." This would be a great disservice to our schools, families, and to our children.
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Rachel	Moss		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Jazmine	Rodriguez		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Callahan	McIlnay		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Callahan	McIlnay		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Sarah	McKee		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Ritu	Verma	APAGS	Page 13 (D, 1, b. Evaluation of Students’ Competencies). We are in strong support of programs documenting students’ outcomes, particularly as this relates to transparency in the admissions process. Again, as there is currently a subsection of students and programs whose primary goal is to obtain masters-level training for eventual admission into doctoral programs in HSP, the lack of inclusion or consideration of post-masters outcomes that include subsequent higher education may inadvertently put some programs at a disadvantage in the accreditation process due to skewed occupational/licensure outcomes used as a primary measure of programmatic success. As subsection b is written currently, outcome data only includes occupational and licensure outcomes and while there is some language in subsection a to suggest other “proximal and distal outcomes”, there is no explicit information about reporting on other placements aside from occupation/licensure. An example of an outcome measure that mi...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Debbieann	Santana		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Emily	Vulcano		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Nicki	Tornabene		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Alexis	Wageman		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	II. Aims, Competencies, Curriculum, and Outcomes	D. Evaluation of Students and Program	Taylor	Carroll		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	A. Student Selection Processes and Criteria	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	III. Students	A. Student Selection Processes and Criteria	Sharon	Berry	APA Division 38, Society for Health Psychology	Division 38 Society for Health Psychology A.1.b.i: we recommend (consistent with previous comments), that you replace “increase diversity” with “increase and maintain diversity.” In addition, we recommend adding the expectation that “The program must be intentional in implementing specific activities, approaches, and initiatives to increase and maintain diversity….” A.1.c: we recommend improved operationalization of this statement: "By interest and aptitude, students are prepared to meet the program’s aims." Replace with: "By interest and aptitude, students have appropriate foundational undergraduate training to be successful in the program" and are prepared to meet the program’s aims. B.2 & B.3: see also "students from diverse backgrounds" comment in D.1.a. B.2: We recommend that you be more transparent by including language such as: "due process, notice, and appeal”
Public Comment Intro_SoA M_Final.pdf	III. Students	A. Student Selection Processes and Criteria	Ashley	Hudson		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards the well-established NASP standards, which govern the quality of school psychologists practicing in the field and sets minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, learn the best practices in program evaluation, progress monitoring, interventions and instructional support, as well as effectively collaborate and consult with school members, families and community members cannot b...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	A. Student Selection Processes and Criteria	Amanda	Craven		School Psychologist should be required to have an accredited NASP approved Education Specialist degree to safely, justly, and with integrity practice as a school psychologist with children. A master's level degree is not adequate training to be labeled a "psychologist." This would be a great disservice to our schools, families, and to our children. School Psychologist in training MUST demonstrate cultural humility and anti-racist beliefs
Public Comment Intro_SoA M_Final.pdf	III. Students	A. Student Selection Processes and Criteria	Rachel	Moss		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	A. Student Selection Processes and Criteria	Jazmine	Rodriguez		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	A. Student Selection Processes and Criteria	Callahan	McIlnay		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	A. Student Selection Processes and Criteria	Sarah	McKee		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	A. Student Selection Processes and Criteria	Jill	Talley		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	A. Student Selection Processes and Criteria	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	A. Student Selection Processes and Criteria	Ritu	Verma	APAGS	We appreciate the emphasis on recruitment and retention of diverse students and faculty (Student Selection Process, p. 14. Cultural and Individual Differences and Diversity, p. 17 & 18), specifically the distinction between institution level and program level efforts. We still believe that it may be helpful to provide examples in the Implementing Regulations of “specific activities, approaches, and initiatives” that programs can implement. One example that comes to mind for us, includes ongoing training for faculty and external practicum supervisors to examine personal biases or gaps in their own training on cultural diversity, such as training students from a different racial background, or supervising transgender or nonbinary students.
Public Comment Intro_SoA M_Final.pdf	III. Students	A. Student Selection Processes and Criteria	Debbieann	Santana		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	A. Student Selection Processes and Criteria	Emily	Vulcano		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	A. Student Selection Processes and Criteria	Nicki	Tornabene		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	A. Student Selection Processes and Criteria	Alexis	Wageman		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	A. Student Selection Processes and Criteria	Taylor	Carroll		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	B. Supportive Learning Environment	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	III. Students	B. Supportive Learning Environment	Ashley	Hudson		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards the well-established NASP standards, which govern the quality of school psychologists practicing in the field and sets minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, learn the best practices in program evaluation, progress monitoring, interventions and instructional support, as well as effectively collaborate and consult with school members, families and community members cannot b...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	B. Supportive Learning Environment	Amanda	Craven		School Psychologist should be required to have an accredited NASP approved Education Specialist degree to safely, justly, and with integrity practice as a school psychologist with children. A master's level degree is not adequate training to be labeled a "psychologist." This would be a great disservice to our schools, families, and to our children. School Psychologist in training MUST demonstrate cultural humility and anti-racist beliefs
Public Comment Intro_SoA M_Final.pdf	III. Students	B. Supportive Learning Environment	Rachel	Moss		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	B. Supportive Learning Environment	Jazmine	Rodriguez		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	B. Supportive Learning Environment	Callahan	McIlnay		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	B. Supportive Learning Environment	Sarah	McKee		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	B. Supportive Learning Environment	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	B. Supportive Learning Environment	Ritu	Verma	APAGS	This section underscores the importance of faculty accessibility in training and supervision. It would be important to specify how accessibility will be measured. For example, how will accreditation boards determine whether this is being met, particularly in larger programs with fewer faculty? This is addressed, in part, in Number 4; however, more specific language on expectations may be necessary to ensure there is not a discrepancy in perception between students and program administrators that the faculty is sufficient in size and availability.
Public Comment Intro_SoA M_Final.pdf	III. Students	B. Supportive Learning Environment	Debbieann	Santana		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	B. Supportive Learning Environment	Emily	Vulcano		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	B. Supportive Learning Environment	Nicki	Tornabene		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	B. Supportive Learning Environment	Alexis	Wageman		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	B. Supportive Learning Environment	Taylor	Carroll		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	C. Plans to Maximize Student Success	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	III. Students	C. Plans to Maximize Student Success	Ashley	Hudson		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards the well-established NASP standards, which govern the quality of school psychologists practicing in the field and sets minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, learn the best practices in program evaluation, progress monitoring, interventions and instructional support, as well as effectively collaborate and consult with school members, families and community members cannot b...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	C. Plans to Maximize Student Success	Amanda	Craven		School Psychologist should be required to have an accredited NASP approved Education Specialist degree to safely, justly, and with integrity practice as a school psychologist with children. A master's level degree is not adequate training to be labeled a "psychologist." This would be a great disservice to our schools, families, and to our children. School Psychologist in training MUST demonstrate cultural humility and anti-racist beliefs
Public Comment Intro_SoA M_Final.pdf	III. Students	C. Plans to Maximize Student Success	Jazmine	Rodriguez		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	C. Plans to Maximize Student Success	Callahan	McIlnay		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	C. Plans to Maximize Student Success	Sarah	McKee		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	C. Plans to Maximize Student Success	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	C. Plans to Maximize Student Success	Debbieann	Santana		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	C. Plans to Maximize Student Success	Emily	Vulcano		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	C. Plans to Maximize Student Success	Nicki	Tornabene		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	C. Plans to Maximize Student Success	Alexis	Wageman		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	III. Students	C. Plans to Maximize Student Success	Taylor	Carroll		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	A. Program Leadership, Administration, and Management	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	A. Program Leadership, Administration, and Management	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	A. Program Leadership, Administration, and Management	Sharon	Berry	APA Division 38, Society for Health Psychology	Division 38 Society for Health Psychology A.1: The SoA for this Domain in Doctoral, Internship, and Postdoctoral standards does not specify a percentage of time leader devotes to program related activities. We recommend removing this section: "i.e., with at least 50% of the leader’s time devoted to program-related activities." The specification of time the leader devotes to Master’s program has no apparent rationale and unless CoA intends to change the SoA for the other levels of training, percentage of time should be excluded. A.1: Likewise, as previously noted above (C.2.a.): Please eliminate this statement or provide clarification: "More than one individual can hold this leadership position." B.5.a: see earlier comments regarding diversity language: recommend change from Recruitment of Faculty who are Diverse to Recruitment of a Diverse Group of Faculty. B.5.b: consistent with previous comments regarding students from diverse backgrounds, please revise to: Retention...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	A. Program Leadership, Administration, and Management	James	Loveless	Middle Tennessee State University Clinical Psychology Faculty	Part IV, Section A, Subsection 1 The commission specifies that the program leadership must spend 50% of their time on work dedicated to program-related responsibilities, but then goes on to say that multiple individuals can hold a leadership role. Does this mean that each identified program leader must spend 50% of their time on program-related work, or does that mandated 50% allocation of programmatic work-time decrease as a function of the number of leaders involved (i.e., 25% of work time each for two leaders, 17% of work time each for three leaders, etc.)? If it is the former, then such a mandate is not feasible for existing programs in universities which have not historically allowed for program leadership to be released from other assigned duties. We would recommend that the commission add language to clarify this point. Additionally, we would encourage the commission to consider the administrative conflicts they may inadvertently be creating in existing programs by specifying...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	A. Program Leadership, Administration, and Management	Ashley	Hudson		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards the well-established NASP standards, which govern the quality of school psychologists practicing in the field and sets minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, learn the best practices in program evaluation, progress monitoring, interventions and instructional support, as well as effectively collaborate and consult with school members, families and community members cannot b...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	A. Program Leadership, Administration, and Management	Amanda	Craven		School Psychologist should be required to have an accredited NASP approved Education Specialist degree to safely, justly, and with integrity practice as a school psychologist with children. A master's level degree is not adequate training to be labeled a "psychologist." This would be a great disservice to our schools, families, and to our children. School Psychologist in training MUST demonstrate cultural humility and anti-racist beliefs
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	A. Program Leadership, Administration, and Management	Rachel	Moss		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	A. Program Leadership, Administration, and Management	Jazmine	Rodriguez		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	A. Program Leadership, Administration, and Management	Callahan	McIlnay		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	A. Program Leadership, Administration, and Management	Sarah	McKee		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	A. Program Leadership, Administration, and Management	Sarah	McKee		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	A. Program Leadership, Administration, and Management	Sarah	McKee		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	A. Program Leadership, Administration, and Management	Jill	Talley		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	A. Program Leadership, Administration, and Management	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	A. Program Leadership, Administration, and Management	Ritu	Verma	APAGS	We appreciate the clarification regarding CoA’s goal of setting SoA M for quality training in HSP vs. determining scope of practice for master’s level clinicians. Given the Commission’s ability to suggest the standards for training, we suggest a further consideration to specify (for e.g., in psychological and neuropsychological assessment) the nature or the level of competency expected, while considering theoretical and experiential learning and practice demands that are feasible to attain during a 2- year master’s degree program.
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	A. Program Leadership, Administration, and Management	Debbieann	Santana		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	A. Program Leadership, Administration, and Management	Emily	Vulcano		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	A. Program Leadership, Administration, and Management	Nicki	Tornabene		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	A. Program Leadership, Administration, and Management	Alexis	Wageman		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	A. Program Leadership, Administration, and Management	Taylor	Carroll		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	B. Faculty Qualifications and Role Modeling	CARRIE	LEWIS		More specific criteria is needed regarding faculty credentials, licensure, and faculty to student ratio. Similarly, he requirement of only one licensed faculty member is only sufficient for very small class cohorts and the wording leaves too many opportunities for loopholes.
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	B. Faculty Qualifications and Role Modeling	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	B. Faculty Qualifications and Role Modeling	Ashley	Hudson		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards the well-established NASP standards, which govern the quality of school psychologists practicing in the field and sets minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, learn the best practices in program evaluation, progress monitoring, interventions and instructional support, as well as effectively collaborate and consult with school members, families and community members cannot b...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	B. Faculty Qualifications and Role Modeling	Amanda	Craven		School Psychologist should be required to have an accredited NASP approved Education Specialist degree to safely, justly, and with integrity practice as a school psychologist with children. A master's level degree is not adequate training to be labeled a "psychologist." This would be a great disservice to our schools, families, and to our children. School Psychologist in training MUST demonstrate cultural humility and anti-racist beliefs.
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	B. Faculty Qualifications and Role Modeling	Betty	Dawson	Texas Assoc. of Psychological Associates	IV.B.1. c. and d. We support the requirement that faculty have applied experiences and recognized credentials in the subjects they are teaching.
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	B. Faculty Qualifications and Role Modeling	Betty	Dawson	Texas Assoc. of Psychological Associates	IV.B.4.c. There should be more than one member of the core faculty who is licensed in psychology. Optimally, most of the faculty should be licensed for practice in psychology. There is a vast difference in theoretical, academic learning and the application of that learning to actual clients. Having licensed faculty with practice experience will help to bridge that gap.
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	B. Faculty Qualifications and Role Modeling	Rachel	Moss		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	B. Faculty Qualifications and Role Modeling	Jazmine	Rodriguez		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	B. Faculty Qualifications and Role Modeling	Callahan	McIlnay		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	B. Faculty Qualifications and Role Modeling	Sarah	McKee		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	B. Faculty Qualifications and Role Modeling	Sarah	McKee		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	B. Faculty Qualifications and Role Modeling	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	B. Faculty Qualifications and Role Modeling	Ritu	Verma	APAGS	Part IV, Section B. Faculty Qualifications and Role Modeling: 1. Core Faculty, (c) have theoretical perspectives and academic and applied experiences appropriate to the program’s aims; We suggest editing section c. as follows: “have theoretical perspectives, and academic and applied experiences appropriate to the program’s aims, INCLUDING EXPERTISE IN DIVERSITY AND SOCIAL JUSTICE NEEDS.” Part IV, Section B. Faculty Qualifications and Role Modeling: 5. Cultural and individual differences and diversity a. We propose to eliminate ambiguity and what could be perceived as a microaggression in the following sentence by removing “when possible (i.e., when there have been faculty openings).” It is self-explanatory that recruitment is done during appropriate times (such as when faculty openings are available). The sentence should read as: The program has developed a systematic, long-term plan to attract faculty from a range of diverse backgrounds and implemented it when possible (i.e., when ...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	B. Faculty Qualifications and Role Modeling	Debbieann	Santana		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	B. Faculty Qualifications and Role Modeling	Debbieann	Santana		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	B. Faculty Qualifications and Role Modeling	Emily	Vulcano		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	B. Faculty Qualifications and Role Modeling	Nicki	Tornabene		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	B. Faculty Qualifications and Role Modeling	Alexis	Wageman		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	IV. Faculty	B. Faculty Qualifications and Role Modeling	Taylor	Carroll		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	A. Public Disclosure	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	A. Public Disclosure	Shawna	Kelly	National Association of School Psychologists	We appreciate the additions in Section V.A.2 regarding transparency in communicating faculty to student ratio and licensing options.
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	A. Public Disclosure	Shawna	Kelly	National Association of School Psychologists	We appreciate the additions made in V.A.2 regarding transparency in communicating faculty to student ratio and licensing options.
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	A. Public Disclosure	Sharon	Berry	APA Division 38, Society for Health Psychology	Division 38 Society for Health Psychology C.2.c.iii: We recommend a change from: tuition and other costs To: tuition and other costs, including availability of funding, economic decision-making, return on investment relative to future training or job placement, jurisdiction-specific limitations, and actual employment possibilities; Plus IR reporting expectations should be clarified. C.2.c.x: We recommend adding to this section: its education and training outcomes including licensure eligibility "and employment." We also want to highlight the concern that HSP Master’s graduates will find themselves in a “licensure no fly zone” and continuing to highlight potential licensure could be misleading.
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	A. Public Disclosure	Ashley	Hudson		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards the well-established NASP standards, which govern the quality of school psychologists practicing in the field and sets minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, learn the best practices in program evaluation, progress monitoring, interventions and instructional support, as well as effectively collaborate and consult with school members, families and community members cannot b...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	A. Public Disclosure	Amanda	Craven		School Psychologist should be required to have an accredited NASP approved Education Specialist degree to safely, justly, and with integrity practice as a school psychologist with children. A master's level degree is not adequate training to be labeled a "psychologist." This would be a great disservice to our schools, families, and to our children. School Psychologist in training MUST demonstrate cultural humility and anti-racist beliefs
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	A. Public Disclosure	Betty	Dawson	Texas Assoc. of Psychological Associates	V.A.1.a. We appreciate APA’s commitment to transparency and full disclosure including program information for the public, consumers and prospective consumers.
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	A. Public Disclosure	Rachel	Moss		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	A. Public Disclosure	Jazmine	Rodriguez		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	A. Public Disclosure	Callahan	McIlnay		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	A. Public Disclosure	Sarah	McKee		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	A. Public Disclosure	Jill	Talley		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	A. Public Disclosure	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	A. Public Disclosure	Debbieann	Santana		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	A. Public Disclosure	Emily	Vulcano		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	A. Public Disclosure	Emily	Klein	Delaware Association of School Psychologists	The Delaware Association of School Psychologists (DASP) wishes to thank the Commission on Accreditation (CoA) for all its thoughtful and hard work on behalf of the education and training of professional psychologists who deliver health service psychological services. We appreciate the CoA’s efforts to address the shortage of mental health professionals by considering accreditation of non-doctoral level programs. With all due respect to the high level of professionalism and the hard work evident in the CoA’s draft standards and processes for accrediting Masters’ degree programs in Health Service Psychology, DASP wishes to submit the following comments/recommendations for consideration. All of these comments/recommendations are specific to the School Psychology branch of Health Services Psychology, in keeping with our area of expertise. C.2. – Public Disclosure DASP is appreciative of the inclusion of full-time equivalent (FTE) faculty-to-student ratios as a required element in progr...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	A. Public Disclosure	Nicki	Tornabene		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	A. Public Disclosure	Alexis	Wageman		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	A. Public Disclosure	Taylor	Carroll		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Erin	Yosai		I agree and promote with this statement by a fellow colleague: It is critical that APA recognize that the specialist-level degree (e.g., EdS) represents the minimum standard for practice as a school psychologist. This degree typically requires more credits, not to mention far more supervised field experience (e.g., 1200-hour internship) than a master's degree in any area of psychology. NASP has developed comprehensive Standards for graduate preparation and credentialing that establish the minimum expectations for competency in school psychology practice, and these Standards should remain the basis for training and practice in school psychology. Accreditation of “master’s level programs” may result in programs that are not equivalent to NASP Standards and thus enable inadequately trained professionals to assume roles in school-based practice. Competently navigating the increasingly complex work of school psychologists, particularly at a time when students are experiencing tra...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Diana	Concannon	NCSPP	Please see comment submitted under 1.A for feedback representing the position of NCSPP.
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Ryan	Blackstock		Clearly, it is important that MA practitioners have a good title, AND receive parity when compared to MSWs and LPCs. In Michigan, MA LLPs are grossly discriminated against in this area in terms of having a permanent supervision requirement, and the continual lobbying to have "psychologist" removed from their title and replaced with "Associate" There has even been objections to calling them "Masters Level Psychologist", even though that is exactly what they are. There is discrimnation in advertising, in that most of the people are "Psychology Today", are not Psychologists, because MA practitioners cannot identify themselves that way.
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Ryan	Blackstock		In addition, if APA is going to get in the business of accrediting MA programs, it needs to take a stance and be an advocate for MA practitioners and work for social justice on their behalf. In the State of Michigan, individuals that graduate with an MA in clinical psychology are required by State Board to take and pass the EPPP at a score of 450. The doctoral level for passing this exam is 500. This is ludicrous and APA should step in. It makes no more sense that MAs should take and pass this exam as it does if you were working to become a Paramedic and had to to a Neurosurgery exam, and you could just miss a few more questions. The EPPP represents 4-5 years more training as well as practicum and internships, and so far APA has sat by idle while this form of bureaucratic rape occurs to the MA practitioners. Requiring this exam is a form of financial exploitation of the entry level positions in this field. If the APA is going to get into the management of standardizing what a MA prac...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Ashley	Hudson		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards the well-established NASP standards, which govern the quality of school psychologists practicing in the field and sets minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, learn the best practices in program evaluation, progress monitoring, interventions and instructional support, as well as effectively collaborate and consult with school members, families and community members cannot b...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Amanda	Craven		School Psychologist should be required to have an accredited NASP approved Education Specialist degree to safely, justly, and with integrity practice as a school psychologist with children. A master's level degree is not adequate training to be labeled a "psychologist." This would be a great disservice to our schools, families, and to our children. School Psychologist in training MUST demonstrate cultural humility and anti-racist beliefs
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Amanda	Craven		School Psychologist should be required to have an accredited NASP approved Education Specialist degree to safely, justly, and with integrity practice as a school psychologist with children. A master's level degree is not adequate training to be labeled a "psychologist." This would be a great disservice to our schools, families, and to our children. School Psychologist in training MUST demonstrate cultural humility and anti-racist beliefs
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Rachel	Moss		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Jazmine	Rodriguez		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Callahan	McIlnay		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Sarah	McKee		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Jill	Talley		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Lauren	White		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Caroline	DeWitt		As a school psychologist intern, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members cannot be ...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Debbieann	Santana		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Debbieann	Santana		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Emily	Vulcano		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Nicki	Tornabene		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Alexis	Wageman		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment
Public Comment Intro_SoA M_Final.pdf	V. Communication Practices	B. Communication and Relationship With the Accrediting Body	Taylor	Carroll		As a school psychologist-in-training, I am profoundly concerned about APA’s push to accredit the master’s degree in Health Service Psychology due to the inappropriate and inadequate training of these professionals for the field of education. This decision disregards NASP’s well-established standards, which not only govern the quality of school psychologists practicing in the field, but also set minimum standards of practice. While I appreciate APA’s recognition of the shortage of school psychologists, lowering the level of entry is not the solution for equitable practices. If this is passed, it can lead to poorly prepared psychologists entering the school system, leaving our most vulnerable populations unsupported. The training required to adequately conduct and evaluate assessments, employ best practices in program evaluation, progress monitoring, interventions and instructional support, and effectively collaborate and consult with school members, families, and community members canno...	See Full Comment