Accreditation Public Comment System





This project is now closed for new comments.
DocumentSectionItemFirst NameLast NameGroup NameComment 
Implementing Regulations (IRs) C-8 D, C-9(d) P, C-9(f) P, and C-9(j) P.pdf C-8 D. Profession-Wide CompetenciesJackSchaffer I write in support of the changes made to IR C-8D. The focus on the level of training, the elimination of duplication, and some additional clarifying language should make the IR less confusing to programs. Well done!
Implementing Regulations (IRs) C-8 D, C-9(d) P, C-9(f) P, and C-9(j) P.pdf C-8 D. Profession-Wide CompetenciesSeanScanlan The phrasing in the Research competency seems to imply that students must publish AND present their work in order to meet this competency. I suggest changing "and" to "and/or" (see below). Or considering that the previous phrasing states "at a minimum", I am wondering if simply replacing "and" with "or" would better reflect that. "...critically evaluate and disseminate research or other scholarly activity via professional publication and presentation at the local (including the host institution), regional, or national level." "...critically evaluate and disseminate research or other scholarly activity via professional publication and/or presentation at the local (including the host institution), regional, or national level."
Implementing Regulations (IRs) C-8 D, C-9(d) P, C-9(f) P, and C-9(j) P.pdf C-8 D. Profession-Wide CompetenciesSartaj AhmadAllaie Develop and implement evidence-based intervention plans specific to the service delivery goals informed by the current scientific literature, assessment findings, diversity considerations, and contextual variables. This includes the ability to modify and adapt evidence-based approaches effectively when a clear evidence-base is lacking,
Implementing Regulations (IRs) C-8 D, C-9(d) P, C-9(f) P, and C-9(j) P.pdf C-8 D. Profession-Wide CompetenciesJasonWashburnCouncil of University Directors of Clinical PsychologyThe CUDCP Board appreciates the opportunity to comment on the proposed changes to doctoral, internship, and postdoctoral competencies in IRs C-8 D, C-8 I, and C-9 P. Given the focus of the CUDCP Board on doctoral level training, our comments will be focused exclusively on C-8 D. The lack of a red-line version of the modified IRs made review of the changes difficult. The CUDCP Board once again requests that future proposed changes be provided to the public for comment with an additional red-line version to avoid the need to compare documents line-by-line. The CUDCP Board greatly appreciates CoA considering the feedback of our Board and others provided in October 2020 in revising C-8 D. We are especially pleased to see the identification of minimum expectations under each of the PWCs. Although we encourage CoA to continue to provide substantial flexibility and opportunities for innovations for programs meet these minimum competencies, we believe it is important that all programs ... See Full Comment
Implementing Regulations (IRs) C-8 D, C-9(d) P, C-9(f) P, and C-9(j) P.pdf C-8 D. Profession-Wide CompetenciesAngelaCusimano From the perspective of early intervention and a movement towards integrated healthcare, it is recommended that competencies in clinical psychopharmacology be added to section IX, as many psychologists are providing at least psychoeducation about medication as part of the evidence base for treatment of depression and anxiety. Psychologists (and masters level counselors) working in primary care settings are conducting themselves in ways that are closely aligned with the responsibilities of prescribers due to the lack of psychiatrists, prevalence of mid-level providers without speciality training in psychiatry, and because the majority of psychotropics are prescribed by primary care providers. Advanced training in psychopharmacology should be considered a requirement for doctoral studies and to better meet the needs of patients across the country, offering an option to complete the masters in clinical psychopharmacology (MSCP) en route to the PhD or PsyD in Psychology is recommended as m... See Full Comment
Implementing Regulations (IRs) C-8 D, C-9(d) P, C-9(f) P, and C-9(j) P.pdf C-8 D. Profession-Wide CompetenciesRobertAx Knowledge of clinical psychopharmacology (as reflected in the old Level 1 curriculum) is crucial to effective practice, notably as regards assessment, intervention and consultation. Future iterations of the Accreditation Standards and Implementing Regulations should reflect this. I believe a 3-credit course would be appropriate for teaching the subject matter at the level necessary to provide graduate students with foundational knowledge.
Implementing Regulations (IRs) C-8 D, C-9(d) P, C-9(f) P, and C-9(j) P.pdf C-8 D. Profession-Wide CompetenciesDerekPhillipsDivision 55: Society for Prescribing PsychologyOn behalf of, and as President of, the Society for Prescribing Psychology (APA Division 55), I would like to advocate for psychopharmacology to be a required, profession-wide competency. This could be incorporated into sections VI, VII, and IX. At present, a biological bases of behavior course is required of all APA-accredited programs; however, this is necessary but not sufficient for psychologists-in-training. As both students and licensed professionals, we must have at least a basic understanding of psychopharmacology, as reflected by Level 1 training in the "Practice Guidelines Regarding Psychologists' Involvement in Pharmacological Issues" (APA, 2011). This level of training is vital to effective practice and generally includes providing information to pharmacotherapy decision-makers, and could be achieved through a 3-credit hour course in psychopharmacology. Many doctoral HSP programs (and even in non-HSP programs such as social work and marriage family therapy) already require p... See Full Comment
Implementing Regulations (IRs) C-8 D, C-9(d) P, C-9(f) P, and C-9(j) P.pdf C-8 D. Profession-Wide CompetenciesFernandoRegalado It has become increasingly relevant that knowledge of clinical psychopharmacology (as reflected in the old Level 1 curriculum) is crucial to effective practice, especially in an interdisciplinary environment. The ability to understand the impact of certain medications and treatments on an individuals functioning, notably as regards assessment, intervention and treatment planning is crucial to independent professional practice at the highest level and future iterations of the Accreditation Standards and Implementing Regulations should reflect this in order to prepare clinicians to function at that highest level.
Implementing Regulations (IRs) C-8 D, C-9(d) P, C-9(f) P, and C-9(j) P.pdf C-8 D. Profession-Wide CompetenciesPeterSmith As President-elect of, the Society for Prescribing Psychology (APA Division 55), I would like to advocate for psychopharmacology to be a required, profession-wide competency. This could be incorporated into sections VI, VII, and IX. At present, a biological bases of behavior course is required of all APA-accredited programs; however, this is necessary but not sufficient for psychologists-in-training. As both students and licensed professionals, we must have at least a basic understanding of psychopharmacology, as reflected by Level 1 training in the "Practice Guidelines Regarding Psychologists' Involvement in Pharmacological Issues" (APA, 2011). This level of training is vital to effective practice and generally includes providing information to pharmacotherapy decision-makers, and could be achieved through a 3-credit hour course in psychopharmacology. Many doctoral HSP programs (and even in non-HSP programs such as social work and marriage family therapy) already require psychopharmac... See Full Comment
Implementing Regulations (IRs) C-8 D, C-9(d) P, C-9(f) P, and C-9(j) P.pdf C-8 D. Profession-Wide CompetenciesDavidShearer The knowledge of clinical psychopharmacology is absolutely essential to effective practice, notably as regards assessment, intervention and consultation, and future iterations of the Accreditation Standards and Implementing Regulations should reflect this. I say this as a prescribing psychologist of 12 years who teaches psychology interns in an APA accredited program. A psychologist's ability to navigate and effectively communicate as a member of any multidisciplinary team requires at least this basic knowledge of clinical psychopharmacology
Implementing Regulations (IRs) C-8 D, C-9(d) P, C-9(f) P, and C-9(j) P.pdf C-8 D. Profession-Wide CompetenciesCharlesEckhartPsiAN Education CommitteeImplementing Regulations (IRs) C-8 D, C-9(d) P, C-9(f) P, C-9(j) P, and C-9 (k) P This comment is offered in response to posted IRs c-8 D, C-9(d) P, C-9 (f) P, C-9 (j) P and C-9 (k) P. We appreciate the opportunity to provide an additional voice as changes to these IRs are considered (though we agree that their clearer designation here would have been helpful). Regarding changes to these documents, we are most concerned to see which ones have not been adopted, including, among the PWCs, competencies in creating dynamic formulations, in developing sensitivities to the meaning-worlds of clients, in appreciating the unconscious determinants of human experience, in helping patients cultivate affect tolerance, in comprehending internal family systems, intergenerational traumas, patterns of emotional response and relational-developmental histories, and in metabolizing transference and countertransference towards facilitating patients’ growth. As before, requirements for cultural sen... See Full Comment
Implementing Regulations (IRs) C-8 D, C-9(d) P, C-9(f) P, and C-9(j) P.pdf C-8 D. Profession-Wide CompetenciesKathleenMcNamara As healthcare delivery systems increasingly emphasize integrated care, relying on inter-professional collaboration, the need for psychologists to develop competency in clinical psychopharmacology is more evident. This comment is added to encourage the inclusion of such competence as part of the preparation for practice in health service psychology. Primary care providers more often assume the added responsibility of accurately recognizing, assessing, and treating behavioral and mental health issues. Psychologists with a basic level of competence in clinical psychopharmacology added to their already existing broad clinical knowledge can augment the quality of patient care in primary care settings and as primary care providers, themselves. Further, with the emphasis in doctoral training on “conducting all professional activities with sensitivity to human diversity,” and the commitment to science and practice, psychologists will bring a new dimension to the collaborative process of consid... See Full Comment
Implementing Regulations (IRs) C-8 D, C-9(d) P, C-9(f) P, and C-9(j) P.pdf C-9(d) P. Postdoctoral Residency Level 3 – Specialty Competencies Clinical NeuropsychologyBradRoper As a former co-chair of a Postdoc Competencies Workgroup for the Clinical Neuropsychology Specialty Council, I was involved in the development of consensus postdoc competencies and in providing public comment to the CoA on successive revisions of the Level 3 competencies IR. I thank the CoA for accepting the suggested revisions of our workgroup, as approved by CNSC-member organizations. Clearly, the development of specialty competencies has been a "heavy lift" for all organizations in light of its many and inherent complexities. I appreciate that the CoA has endeavored to create a structure within the IRs that provides specialty postdoc programs with clear guidance AND allows a mechanism for future changes to be submitted from within the specialties. By doing so, the CoA's actions have helped to realize the advances that the SoA has made over the old G&P regarding postdoctoral specialty practice, taking specialty practice much more seriously than was previously possible. What is being ... See Full Comment
Implementing Regulations (IRs) C-8 D, C-9(d) P, C-9(f) P, and C-9(j) P.pdf C-9(d) P. Postdoctoral Residency Level 3 – Specialty Competencies Clinical NeuropsychologyAmySilberbogenAPPICThe Association of Psychology Postdoctoral and Internship Programs (APPIC) Postdoctoral Committee represents 248 APPIC Member postdoctoral programs and works to provide an overarching structure for postdoctoral recruitment and training, including hosting over 1400 program listings in the Universal Psychology Postdoctoral Directory (UPPD). The APPIC Board and the APPIC Postdoctoral Committee welcome the opportunity to comment on the proposed Implementing Regulation on the Postdoctoral Residency Level 3 – Specialty Competencies, C-9(d) P (Clinical Neuropsychology) and C-9(f) P (Geropsychology). Overall, we appreciate CoA’s efforts to provide well-needed clear and specific guidance on training expectations within psychology postdoctoral training (Level 1 & 2 Competencies) and specifically within specialty training (Level 3 Competencies). We applaud the collaboration among CoA and the individual specialties needed to accomplish this task. Overall, the APPIC Postdoctoral Committee a... See Full Comment