Accreditation Public Comment System
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Document
Section
Item
First Name
Last Name
Group Name
Comment
Implementing Regulation (IR) C-9 P and Substantive Change IRs
Implementing Regulation (IR) C-9 P. Profession-Wide Competencies
Kevin
Larkin
Specialty Competencies Task Force of the Clinical Health Psychology Specialty Council
As members of the Task Force charged by the Clinical Health Psychology Specialty Council to review and submit competencies required for clinical health psychology postdoctoral programs to CoA, we have reviewed the revised competencies for postdoctoral residencies in clinical health psychology (IR C-9 P) and believe they capture all of the competencies of our specialty area. We appreciate CoA’s attention to our feedback and find the description of competencies for postdoctoral residencies in clinical health psychology acceptable. Respectfully submitted, Lloyd Berg, Ph.D., ABPP (Clinical Health Psychology) Jeffrey Goodie, Ph.D., ABPP (Clinical Health Psychology) Kevin T. Larkin, Ph.D., ABPP (Clinical Health Psychology) Marquisha R. G. Lee, Ph.D., ABPP (Clinical Health Psychology) Richard J. Seime, Ph.D., ABPP (Clinical Health Psychology) Mark Vogel, Ph.D., ABPP (Clinical Health Psychology)
Implementing Regulation (IR) C-9 P and Substantive Change IRs
Implementing Regulation (IR) C-9 P. Profession-Wide Competencies
Kelly
Trevino
APA Committee on Aging
C-9.f P. Geropsychology Level 3 – Specialty Competencies The APA Committee on Aging (CONA) is concerned about the lack of specificity within the Geropsychology Specialty Competencies. Much of the language describing the geropsychology competencies is repeated in the description of other competencies, reducing the distinction between specialties. CONA is concerned that this lack of specificity will result in the accreditation of geropsychology programs when, in fact the trainees are receiving largely generalist training. The absence of rigorous specialty training has the potential to dilute the subspecialty and negatively impact the care of older adults. Further, psychologists who advertise as geropsychologists based on the accreditation of their training program but do not have specialized knowledge and skills could be a negative reflection on the geropsychology subspecialty and the field of psychology, albeit inadvertently. Our colleagues in the Society of Clinical Geropsycholo...
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Implementing Regulation (IR) C-9 P and Substantive Change IRs
Implementing Regulation (IR) C-9 P. Profession-Wide Competencies
Nancy
Burke
Psychotherapy Action Network
This comment regarding IR C-9 is submitted on behalf of the Psychotherapy Action Network and the undersigned clinicians, APA members and mental health stakeholders. Our concerns are both general and program-specific, and call attention to the entwined problematic ethical and diversity implications of the policies outlined in this document. Our request for modification of IR C-9 goes hand-in-hand with our parallel requests that APA demonstrate good faith towards clinicians and clients by re-visioning its guidelines program, speaking out about inequities in research funding areas and preferred methodologies, and submitting an Amicus brief, as have the American Psychiatric Association, the American Medical Association and other national professional organizations, in support of the Wit v UBH decision of 2019, whose reprocessing order issued by the court is now under judicial review, and the appeal of which to the Ninth Circuit of all adverse rulings is forthcoming. We would hope th...
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Implementing Regulation (IR) C-9 P and Substantive Change IRs
Implementing Regulation (IR) C-9 P. Profession-Wide Competencies
Ann
Steffen
Society of Clinical Geropsychology (APA Division 12 Section II)
The Society of Clinical Geropsychology (APA Div. 12 Section II) appreciates the importance of this effort. In addition to the below, we support all comments made by the APA Committee on Aging (CONA). C-9.f P. Geropsychology Level 3 – Specialty Competencies – General Comments The Society of Clinical Geropsychology (SCG; APA Division 12 Section II) is concerned about the lack of specificity within the Geropsychology Specialty Competencies. Much of the language describing the geropsychology competencies is repeated in the description of other competencies, reducing the distinction between specialties. SCG is concerned that this lack of specificity will result in the accreditation of geropsychology programs when, in fact the trainees are receiving largely generalist training although perhaps serving older adults. The absence of rigorous specialty training has the potential to dilute the subspeciality and negatively impact the care of older adults. Further, psychologists who adve...
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Implementing Regulation (IR) C-9 P and Substantive Change IRs
Implementing Regulation (IR) C-9 P. Profession-Wide Competencies
Robin
Hilsabeck
Clinical Neuropsychology Specialty Council
Dear Members of the COA: I am writing you as Chair of the Clinical Neuropsychology Specialty Council, which represents the specialty of clinical neuropsychology on the Council of Specialties in Professional Psychology (CoS). The following comments are in response to the proposed revision to draft Implementing Regulation C-9 P. The CNS consists of representatives from the following organizations: Society for Clinical Neuropsychology (APA Division 40), National Academy of Neuropsychology, American Academy of Clinical Neuropsychology, Hispanic Neuropsychological Society, Society for Black Neuropsychology, Asian Neuropsychological Association, American Board of Professional Neuropsychology, American Board of Clinical Neuropsychology, Association of Post-Doctoral Programs in Clinical Neuropsychology, and Association for Internship Training in Clinical Neuropsychology. This response was primarily authored by the CNS Postdoctoral Competencies Workgroup, consisting of Amy Heffelfinger, Ph....
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Implementing Regulation (IR) C-9 P and Substantive Change IRs
Implementing Regulation (IR) C-9 P. Profession-Wide Competencies
Richard
Seime
Council of Specialties in Professional Psychology (CoS)
CoS Public Comment on IR C-9 P We acknowledge that for some specialties, the latest IR C-9 P draft of specialty specific postdoctoral competency domains and their essential elements has incorporated specialty recommendations. And for those specialties, their public comments reflect satisfaction with the IR C-9 P. However, for a few specialties whose competency domains and associated essential elements have not incorporated that respective specialty’s feedback, there is dissatisfaction with the current draft. These specialties believe that more specific specialty-related criteria could be incorporated into their competencies. The Council of Specialties in Professional Psychology supports the primacy of a CoA recognized postdoctoral specialty in determining their competency domains and essential elements. We encourage the CoA to incorporate into IR C-9 P the elements for competency that a specialty requests. We thank the CoA for incorporating previous recommendations in the curre...
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Implementing Regulation (IR) C-9 P and Substantive Change IRs
Implementing Regulation (IR) C-20 P. Notification of Changes to Accredited Programs
Mary
Jansen
Specialty Council for Serious Mental Illness (SMI) Psychology
We appreciate the work of the Commission on Accreditation and look forward to post-doctoral programs being able to apply for accreditation in Serious Mental Illness Psychology. Mary Jansen, Ph.D. Executive Officer Specialty Council for Serious Mental Illness (SMI) Psychology