Accreditation Public Comment System

This project is now closed for new comments.

Document	Item	First Name	Last Name	Group Name	Comment
Master's Accreditation IRs (Section C) [Part II] and IR D.4-7 (b)	Implementing Regulation (IR) C-1 M. Conduct of Master's Reviews	Eric	Rossen	National Association of School Psychologists	NASP Standards recognize a specialist level degree (which is more rigorous in depth, scope, and required credit hours to complete than a master’s degree) as the entry-level degree to be a school psychologist. The vast majority of states have adopted credentialing requirements for school psychologists aligned with these standards. Paragraph 4 of this IR implies that the CoA places heavy emphasis on the proportion of students completing the master’s program who attain licensure or credentials when reviewing accreditation status of master’s HSP programs. NASP agrees that accredited programs should prepare students to obtain licensure/certification. However, it is highly problematic accredit master’s level school psychology programs. Graduates from these programs would not meet requirements to obtain a credential or practice as a school psychologist.
Master's Accreditation IRs (Section C) [Part II] and IR D.4-7 (b)	Implementing Regulation (IR) C-1 M. Conduct of Master's Reviews	Leihua	Edstrom	National Council of Schools and Programs of Professional Psychology	The National Council of Schools and Programs of Professional Psychology (NCSPP) continues to have concerns that the MA IRs are basically "grafts" from the doctoral level without answering several key questions: 1. Can the terminal master's be included in current doctoral programs and, if so, will the CoA modify/clarify doctoral IRs around issues such as distance education to accommodate? 2. Will CoA work in tandem with ASPPB to influence licensing boards to determine scope of practice for master's level practitioners to preserve the integrity of the master's and doctoral identities? In relation to the latter, we feel that it is naive and actually irresponsible to believe that "the states will decide" the scope of practice for master's level practitioners. While the IRs speak to "entry level health psychology practitioners", they fail to define this in any meaningful way. We need to do so.
Master's Accreditation IRs (Section C) [Part II] and IR D.4-7 (b)	Implementing Regulation (IR) C-2 M. Definition of "Developed Practice Areas" for Master's Programs and the Process by which Areas May be Identified as Such	Eric	Rossen	National Association of School Psychologists	The National Association of School Psychologists (NASP) shares and acknowledges the value and importance of clearly articulated standards to advance a common understanding of Health Service Psychology, Health Service Psychologists, and to protect the public by ensuring Master’s degree accredited graduate education programs are properly preparing students to provide high quality, evidence-based, psychological services. As such it will be imperative that the final IRs, and corresponding credentialing and scope of practice recommendations, are specific to Health Service Psychologists and do not contradict or invalidate currently accepted and recognized preparation, practice, and credentialing standards for other similar, yet distinct, professions. As stated in the SoA-M, “health service psychology includes several practice areas in which an accredited program may focus, including but not limited to the areas of clinical psychology, counseling psychology, school psychology, combination...	See Full Comment
Master's Accreditation IRs (Section C) [Part II] and IR D.4-7 (b)	Implementing Regulation (IR) C-2 M. Definition of "Developed Practice Areas" for Master's Programs and the Process by which Areas May be Identified as Such	Ana	Belmonte	The Chicago School of Professional Psychology, Chicago Campus, Forensic Psychology Department	We applaud the CoA for allowing consideration of accreditation for programs with a specialized practice area. We recommend clarification of this IR to include answers to the following questions: 1. Does the process for applying to be identified as a practice area for the purposes of masters-level accreditation include specialties already recognized by the CRSSPP? 2. At this time, there are very few if any training councils dedicated to masters-level training. Can other bodies (such as divisions of APA, educational programs/institutions, etc.) initiate an application to be considered as a practice area? We would support an amendment to this IR to include a streamlined process for approval of programs applying as an already recognized specialty area (per CRSSPP) and the provision for other entities to put forth an application to be considered as a practice area.
Master's Accreditation IRs (Section C) [Part II] and IR D.4-7 (b)	Implementing Regulation (IR) C-10 M. Positive Identification of Students Consistent with Higher Education Opportunity Act	Erika	Liljedahl		As the requirement indicates, there should be “regular and substantive interactions with the instructor or supervisor.” This includes but is not limited to the following: 1) instructor responding to students at least twice within the weekly discussion forums; 2) holding weekly/ biweekly synchronous Zoom meetings; 3) holding weekly office hours by the instructor; 4) conducting one-on-one meetings with students who require more guidance on assignment requirements and other course-related issues.
Master's Accreditation IRs (Section C) [Part II] and IR D.4-7 (b)	Implementing Regulation (IR) C-13 M. Telesupervision	Teresa	Goscicki		Recommend that 100% telesupervision be allowed if there is rationale for doing so. Limiting to 50% may not always be appropriate, and doing so may limit opportunities for clinical experience of masters trainees.
Master's Accreditation IRs (Section C) [Part II] and IR D.4-7 (b)	Implementing Regulation (IR) C-13 M. Telesupervision	Reed	Michael		In the 21st century we should embrace technology. I personally don't agree with the assertation that professional socialization and assessing student competence can only occur in-person. I have supervised trainees and staff during the pandemic remotely and I do not see a difference. In fact, I think it is easier to log in and observe a session between a trainee and a client in-vivo without it being intrusive. There are many rural or remote locations without a qualified supervisor or psychologist. I would recommend allowing 100% tele-supervision if deemed appropriate by the core faculty.
Master's Accreditation IRs (Section C) [Part II] and IR D.4-7 (b)	Implementing Regulation (IR) C-13 M. Telesupervision	Ana	Belmonte	The Chicago School of Professional Psychology, Chicago Campus, Forensic Psychology Department	We support the IR as written.
Master's Accreditation IRs (Section C) [Part II] and IR D.4-7 (b)	Implementing Regulation (IR) C-13 M. Telesupervision	Leihua	Edstrom	National Council of Schools and Programs of Professional Psychology	The criterion "Telesupervision may not account for more than 50% of the total supervision at a given practicum clinical experience site" is likely to limit the availability of practicum training sites, some of which in this post-COVID era have moved towards over 50% telesupervision. This may also present an equity concern, as training sites with limited resources may rely more on telesupervision.
Master's Accreditation IRs (Section C) [Part II] and IR D.4-7 (b)	Implementing Regulation (IR) C-13 M. Telesupervision	Erika	Liljedahl		1) Agree that 100% Telesupervision should be an option for continuity of supervision when students are counseling community members in unavoidable situations such as supervisor or student illness, or other unavoidable situations, as long as the state regulations and the Practicum/Internship site permits 100% Telesupervision. The formal policy would include “explicit rationale for using Telesupervision”. 2) Suggestion: Mandate a class on Telehealth to educate students on navigating telehealth (navigating suicidal clients, HIPAA compliant documentation). 3) Suggestion: To provide a training for site supervisors on best practices for Telesupervision.
Master's Accreditation IRs (Section C) [Part II] and IR D.4-7 (b)	Implementing Regulation (IR) C-19 M. Licensure Rate for Master's Programs	Eric	Rossen	National Association of School Psychologists	NASP supports inclusion of data about graduates’ ability to obtain appropriate licensure/certification when reviewing a master’s programs accreditation status. As noted in this IR, “all master’s programs… are expected to… prepare[sic] students for entry-level practice. One tangible index of preparation for entry level practice is a program's success in preparing its graduates to be licensed (or appropriately credentialed to practice at the master’s level).” NASP appreciates that the SoA-M specifically acknowledges that a specialist degree is the entry level requirement for school psychologists. However, these IRs still imply that APA may accredit school psychology master’s programs. This creates an apparent contradiction and potential confusion given that a master's degree is broadly seen (with few exceptions) as insufficient to qualify for a school psychologist credential.
Master's Accreditation IRs (Section C) [Part II] and IR D.4-7 (b)	Implementing Regulation (IR) C-19 M. Licensure Rate for Master's Programs	Leihua	Edstrom	National Council of Schools and Programs of Professional Psychology	For an otherwise data-driven organization, this statement in the proposed regulation is quite vague: "The CoA uses its professional judgment to determine if the program's licensure or credentialing rate, in combination with other factors such as the attrition of students from the program and their time to degree, demonstrates students' successful preparation for entry-level practice in professional psychology."
Master's Accreditation IRs (Section C) [Part II] and IR D.4-7 (b)	Implementing Regulation (IR) C-23 M. Faculty Qualifications	Leihua	Edstrom	National Council of Schools and Programs of Professional Psychology	While perhaps asking too much specificity from the CoA, it would be helpful here to know if Master's level graduates could be considered qualified to teach in a Master's program. Might the statement here of "formal or other post-doctoral training" be modified to "formal or other post-Master's training?"
Master's Accreditation IRs (Section C) [Part II] and IR D.4-7 (b)	Implementing Regulation (IR) C-24 M. Program Names, Labels, and Other Public Descriptors	Eric	Rossen	National Association of School Psychologists	NASP has significant concerns about the examples of accurate accreditation status provided in this IR. The examples have the potential to create significant confusion to both the public and prospective students, including implications for eventual licensure and/or certification. Some examples are potentially misleading regarding both the level of preparation and eligibility for certain credentials upon program completion. For example, it remains very unclear how an accredited Master’s program in applied behavior analysis prepares them to meet eligibility requirements for a school psychologist credential. Additionally, this language is in direct conflict with standards to obtain NASP accreditation as a program in school psychology, and has significant potential to create confusion both within the profession and among the public. Therefore, we recommend adding language such as: “Moreover, regardless of the self-descriptor used, programs seeking accreditation in an established progra...	See Full Comment
Master's Accreditation IRs (Section C) [Part II] and IR D.4-7 (b)	Implementing Regulation (IR) C-24 M. Program Names, Labels, and Other Public Descriptors	Ana	Belmonte	The Chicago School of Professional Psychology, Chicago Campus, Forensic Psychology Department	We recommend specifically stating programs that are accredited in other practice areas may use the practice area in their program name, label, or other public descriptor (e.g.- Master’s program in Forensic Psychology).
Master's Accreditation IRs (Section C) [Part II] and IR D.4-7 (b)	Implementing Regulation (IR) D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs	Allison	Gillens	Committee on Early Career Psychologists	The Committee on Early Career Psychologists (CECP) appreciates the opportunity to review the proposed revisions to the Master's Accreditation Implementing Regulations (Section C) [Part II] and Implementing Regulation (IR) D.4-7 (b). CECP Comments: From a trainer perspective, APA internships are costly to both create and maintain. Given the changing environment to require all students to have an APA internship, continuing support from APA will be needed to ensure that there are enough APA internships sites that students can be placed at. As long as APA's support continues, this is a reasonable change to the accreditation requirements. From a student/ECP perspective, this is great and cannot be more highly recommended. This should increase the likelihood that students receive high quality training as well as a reasonable return on the time and financial resources they spend on their training.
Master's Accreditation IRs (Section C) [Part II] and IR D.4-7 (b)	Implementing Regulation (IR) D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs	David	Sitzer		Thank you for the opportunity to provide comment on the proposed changes to IR D.4-7(b). My colleagues and I believe that internship training at APA-accredited internship sites provide students with the most robust training opportunities with fantastic oversight of the individual internship sites. However, we have some concerns regarding the proposed increase in proportion of students required to match with APA-accredited internship sites. 1) Some students, especially returning and non-traditional students, have geographic restrictions that limit their access to APA-accredited internship sites. Students with limited finances may struggle to travel to interview at APA-accredited sites or move to other locations (as would those with family obligations), limiting their access to these sites. For those in the Los Angeles or Chicago areas, there are comparatively fewer APA-accredited internship sites relative to the number of programs/students in those areas versus other geographic loca...	See Full Comment
Master's Accreditation IRs (Section C) [Part II] and IR D.4-7 (b)	Implementing Regulation (IR) D.4-7(b). Thresholds for Student Achievement Outcomes in Doctoral Programs	Leihua	Edstrom	National Council of Schools and Programs of Professional Psychology	We are grateful for the opportunity to comment on these proposed changes, and sincerely appreciate the Commission’s diligence on continuing to refine the accreditation standards. The following comments are offered on behalf of the National Council of Schools and Programs of Professional Psychology (NCSPP) about this current set of proposed changes. NCSPP recognizes that it is generally important to anchor the D.4-7 thresholds in objective data points; however, we have some concerns about the current proposal to move the threshold for APA-accredited internships from 50% to 75%. This is a very large jump. Even though the number of APA-accredited internships has increased in recent years and the overall internship imbalance has improved, the number of applicants exceeds accredited positions by 446 during this last year. Further, we are aware that for historically disadvantaged students as well as mature students, they have more limited opportunities to apply to geographically diverse a...	See Full Comment