Accreditation Public Comment System

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Document	Section	Item	First Name	Last Name	Group Name	Comment
Accreditation Operating Procedures Fall 2014	Section 1-5	Section 1 Reaffirmation for Continued Accreditation	Philip	Lanzisera		reasonable
Accreditation Operating Procedures Fall 2014	Section 1-5	Section 1 Reaffirmation for Continued Accreditation	Cindy	Juntunen		This all seems appropriate.
Accreditation Operating Procedures Fall 2014	Section 1-5	Section 1 Reaffirmation for Continued Accreditation	Annette	Mahoney		Reasonable.
Accreditation Operating Procedures Fall 2014	Section 1-5	Section 1 Reaffirmation for Continued Accreditation	Matt	Zimmerman	Association of Counseling Center Training Agencies	1.1 Annual Review (Reaffirmation) ACCTA believes that the proposed CoA procedure of specifying a rationale for a special site visit request is reasonable and useful.
Accreditation Operating Procedures Fall 2014	Section 1-5	Section 1 Reaffirmation for Continued Accreditation	Jan-Sheri	Morris	Board of Educational Affairs	1.1 Annual Review (Reaffirmation)BEA: BEA agrees with the plan to identify specific and unique issues requiring a special site visit, but allow for a broad filter through which to review the program in person.
Accreditation Operating Procedures Fall 2014	Section 1-5	Section 1 Reaffirmation for Continued Accreditation	Merilee	McCurdy	CDSPP	1.1 A special site visit should be a last resort and requests to provide any missing information, or explain any discrepancies should answer most of the CoA’s questions Perhaps a statement such as the following could be added. In most cases issues can be resolved without a special site visit. These are only required when a program cannot/will not provide the needed information to the CoA within six months after the initial request. 1.3 How do they make the determination to withdraw a program? When there are no more registered students? Could a program take a leave of absence, rather than withdraw completely if there is the possibility that the program may be redeveloped?
Accreditation Operating Procedures Fall 2014	Section 1-5	Section 1 Reaffirmation for Continued Accreditation	Stephanie	Wood	National Council of Schools and Programs of Professional Psychology (NCSPP)	Section 1.1 Annual Review (Reaffirmation) NCSPP appreciates CoA’s commitment to transparency and its rendering the specific reasons as to why a site visit might be warranted based upon the annual review explicit; we support this change.
Accreditation Operating Procedures Fall 2014	Section 1-5	Section 1 Reaffirmation for Continued Accreditation	Gilbert	Newman		I support the NCSPP responses for all sections of the revised AOP.
Accreditation Operating Procedures Fall 2014	Section 1-5	Section 1 Reaffirmation for Continued Accreditation	Hideko	Sera		I fully support NCSPP's stance/feedback on Sections 1 through 5.
Accreditation Operating Procedures Fall 2014	Section 1-5	Section 1 Reaffirmation for Continued Accreditation	Stephen	Lally		I support NCSPP's comments across all of the sections.
Accreditation Operating Procedures Fall 2014	Section 1-5	Section 2 Appeal of a Decision	Philip	Lanzisera		reasonable
Accreditation Operating Procedures Fall 2014	Section 1-5	Section 2 Appeal of a Decision	Merilee	McCurdy	CDSPP	Notice of an appeal should be sent by certified mail to ensure receipt.
Accreditation Operating Procedures Fall 2014	Section 1-5	Section 3 Complaints	Matt	Zimmerman	Association of Counseling Center Training Agencies	3.2.1 Filing a Complaint ACCTA is appreciative of the CoA’s efforts to allow flexibility for time above and beyond the 14 day threshold required for most complaints to inform CoA of site visitor’s potential problematic behavior. As written, there are a few aspects of this procedure that are unclear. a)First, the definition of “exceptional and unusual complaints” is absent, and clarity about that term within this section would be useful for programs. b)Second, 3.2.1 references 14 days after completion of the site visit to file a complaint, and the new section specifies that the program has 30 days to inform CoA “after becoming aware of an issue.” The varying time frames may be due to whether the complaint is considered “exceptional and unusual,” yet without the defining characteristics of that term, the difference in time frames is confusing.
Accreditation Operating Procedures Fall 2014	Section 1-5	Section 3 Complaints	Merilee	McCurdy	CDSPP	3.1.2 Perhaps complaints filed by students should be given a 3 year timeline since it could require 3 years in some states before they hear from the licensing board that their program was remiss in preparing the student for licensure (if the student graduates, completes a post-doc and then applies for licensure). 3.1.3 Legal issues may dictate against this. What is the rationale for withholding information provided by the program from the complainant? 3.2.1 Some additional guidance would be helpful regarding potential “exceptional or unusual circumstances.” Site visitors are currently evaluated by the program director and the chair/team members subsequent to the visit. Perhaps, APA could review its files and provide some examples, with all identifying information and specific details removed.
Accreditation Operating Procedures Fall 2014	Section 1-5	Section 3 Complaints	Stephanie	Wood	National Council of Schools and Programs of Professional Psychology (NCSPP)	Section 3.2.1 Filing a Compliant NCSPP supports formalization of the process for review of complaints against site visitors, when extant.
Accreditation Operating Procedures Fall 2014	Section 1-5	Section 3 Complaints	Mary	Hardiman	Board of Professional Affairs	Seems reasonable as issues may not come to light right away.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 6.D Doctoral Application for Initial Accreditation	Christiane	Brems		Thank you for developing the "intent to apply" and "accredited, on contingency" categories for new doctoral programs. This takes the burden off students to demonstrate internship and licensure eligibility and places it, appropriately, on the new program. This move also makes psychology accreditation more comparable to accreditation for other health professions, most of which offer accreditation for new programs that meet minimum standards of curriculum planning, without the requirement to have demonstrable outcomes, that is, graduates. The current APA model of not allowing programs to apply for accreditation until students are matriculated at all levels of a new program typically places a hardship on early cohorts in new programs. These student have limitations on internship applications and larger paperwork burdens for licensure. They are also ineligible for a number of internship sites and for several types of employers post-graduation. It also typically means that at least a ...	See Full Comment
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 6.D Doctoral Application for Initial Accreditation	Barry	Dauphin		Although in principle, I support the process of accredit on contingency, I find the timing problematic when the internship match rate remains such a significant problem. Frankly, I would prefer that the CoA have a moratorium on accrediting new programs until it accredits more internships. Accredit on contingency will put more pre-internship trainees into an already unbalanced "market" for accredited internships. The problem of lack of balance is exacerbated by the model licensing act, which seeks to make graduating from an accredited program and completion of an accredited internship requirements for licensure. Taken as a whole (rather than each part looked at separately), adding more trainees from accredited programs into the pool would use failure to match as a weeding out process for eligibility to practice. This is problematic for students who would have spent several years in training in an accredited program.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 6.D Doctoral Application for Initial Accreditation	Cindy	Juntunen		I believe this is a positive change and clarification for new programs. It will also help potential students have a more accurate picture of program plans, and provide additional accountability for programs to move toward accreditation.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 6.D Doctoral Application for Initial Accreditation	Matt	Zimmerman	Association of Counseling Center Training Agencies	6.1D Doctoral Application ACCTA supports the “intent to apply” and “accredited, on contingency statuses for both doctoral and internship programs. Clarifying definitions for programs to use and communicate to the public will also be helpful. It appears that the “accredited, on contingency” status is more clearly defined that the “intent to apply” description in the proposed AOP.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 6.D Doctoral Application for Initial Accreditation	Jan-Sheri	Morris	Board of Educational Affairs	6.1D Doctoral Application BEA: BEA agrees with the plan to move forward to offer doctoral programs the option to seek program review and approval as “intent to apply” as well as status as “accredited, on contingency.” Please clarify how long a program can be listed as “intent to apply” as this is important information (and clarified under 8.2 where you indicate: “…programs can be listed publicly once for up to 3 years”). We also appreciate the clarity with expecting full accreditation for a doctoral program with a self-study submitted within 5 years of being granted “contingent accreditation.”
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 6.D Doctoral Application for Initial Accreditation	Merilee	McCurdy	CDSPP	6.1.D CDSPP supports, in principle, the process of initial accreditation “on contingency.” However, a number of issues should be considered. The field is currently in the midst of significant shortages of internships and issues with internship match rates. The status of Accredited on Contingency may have the effect of placing more pre-internship trainees into an already unbalanced "market" for accredited internships. As others have indicated, the problem is further complicated by the model licensing act, which seeks to make graduating from an accredited program and completion of an accredited internship requirements a requirement for licensure. If the impact of the “contingency” status would add more trainees from provisionally accredited programs into the pool of intern applicants, we may experience a higher rate of “failure to match.” This is problematic for students who have spent several years in training in an accredited program “on contingency.” Some have suggested in other com...	See Full Comment
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 6.D Doctoral Application for Initial Accreditation	Stephanie	Wood	National Council of Schools and Programs of Professional Psychology (NCSPP)	Section 6.1D Doctoral Application NCSPP applauds CoA’s decision to allow programs the option of pursuing accreditation in multiple ways, including via a formal “intent to apply” and pursuit of “accredited, on contingency” status, as doing so will support existing programs who have not sought accredited status heretofore, as well as support the development of new programs in response to the needs of the profession. However, NCSPP suggests that the proposed process language for “accredited, on contingency” status does not clearly delineate the differing expectations for this designation and for pursuing accreditation. NCSPP recommends that CoA mirror the language adopted for the “accredited, on contingency” status for internship programs, and explicitly state which areas a program is not expected to submit for consideration – such as distal outcome measures -- in addition to listing those areas in which programs are required to demonstrate accreditation-readiness as currently outlined...	See Full Comment
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 6.D Doctoral Application for Initial Accreditation	Hideko	Sera		I fully support NCSPP's stance/feedback on Sections 6 through 8.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 6.D Doctoral Application for Initial Accreditation	Mary	Hardiman	Board of Professional Affairs	developed, they should have a way to applying for accreditation so that students know of intent to apply and when program components are in place for accreditation. This also allows students to apply for internship from an accredited program. This change is consistent with what is done in other health service accreditation systems.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 6.D Doctoral Application for Initial Accreditation	Brad	Roper	Society for Clinical Neuropsychology (APA Div. 40)	Regarding “Intent to Apply” status, the purpose of this status is unclear, and it is also unclear what is involved in the paper-only review for this status. Additionally, we are concerned that listing programs as intending to apply for accreditation could send an inappropriate message to prospective students regarding the program’s prospects for successfully achieving accreditation. The AOP states that doctoral programs can be listed publicly once for 3 years, but it is unclear whether a record is publicly kept regarding “intent to apply” status that does not result in accreditation. It is also unclear if programs can reapply for “intent to apply” status at a later date if they do not achieve accreditation. In general, we believe this status needs to be better defined and its purpose more clearly stated.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Jennifer	Ripley		I just have a concern for programs with specific focus ensuring that they are able to get at least one site visitor with some level of understanding of the type of program. For example a PsyD/PhD program, a Counseling/Clinical program, a psychodynamic program, a religious affiliated program or a program focused on healthcare integration might want at least one site visitor who understands the style of training and specific needs of that type of program to avoid misunderstandings on the team. When given a slate of site visitors, the program can attempt to select at least one person who knows that type of training program. I also think it's important for programs to refuse/exclude someone as a site visitor without stating the reason why for a variety of reasons. If these concerns can be addressed, then it seems easiest for the office to manage the issue of selecting site visitors that are available on certain dates and that sort of thing.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Barry	Dauphin		I prefer the current practice of providing lists to programs. Although it takes time, it enables programs to have sufficient input into the process.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Cindy	Juntunen		I support these changes.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Deborah	Beidel	Council of University Directors of Clinical Psychology Programs (CUDCP)	CUDCP strongly supports this change to the AOP as it will make APA Accreditation Procedures consistent with other health related-professions and the broader educational community. The bedrock of accreditation is the establishment of clear quality standards and the lack of conflicts of interest (or perceived conflicts of interest) in the application of those standards to any individual program seeking accreditation. The selection of site visitors by CoA is consistent with that aspiration. In very rare cases when conflicts or concerns may occur, the procedures allow for input by the program into the selection process. We wish to further note that this revision will only be satisfactory if CoA has the IT and infrastructure resources to do this accurately and well. Without the IT infrastructure and personnel support, this change will not be implemented correctly, leading to undue burdens on the part of CoA staff and the affected programs.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Jeffrey	Goodie		I agree with the CUDCP comment
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Daniel	Segal		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Barbara	Yutrzenka		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Bethany	Teachman		I agree with the CUDCP comment
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Stewart	Shankman		I strongly agree with the CUDCP comment
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Gibb	Brandon		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Julie	Suhr		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Michelle	Salyers		I agree with the CUDCP comment
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Patrick	Steffen		I agree with the CUDCP comment
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Sarah	Francis		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Lee	Cooper		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Julie	Exline		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Rebecca	Ready		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Simms	Leonard		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Jason	Schiffman		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Ellen	Koch		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Wildman	Beth		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Jan-Sheri	Morris	Board of Educational Affairs	7.1 D Site Visit Team BEA: BEA supports the plan for the CoA to assign site visitors as this will reduce any perception of bias or favoritism that is possible when the program selects their own from a list of randomly selected possible site visitors. This model is consistent with other health professions and eliminates any perceived conflict of interest.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Merilee	McCurdy	CDSPP	7.1.D While the intended change may discourage a program from “cherry-picking” a list, this may be problematic for several reasons. Programs know best when potential conflicts of interest arise, and whether they arise from existing or previous professional or personal relationships. It would be difficult and potentially more time consuming for a central office to know when or if these circumstances arise from the program's perspective without allowing the program some opportunity to review lists of potential chairs or members. Programs with a specific specialty focus (many do) should have availability of at least one site visitor with some level of understanding of the general type or model of the program. It is not entirely clear how a program's ability to refuse/exclude someone as a site visitor would be operationalized without additional guidance. If these concerns can be addressed, then it seems easiest for the office to manage the issue of selecting site visitors that are availa...	See Full Comment
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Stephanie	Wood	National Council of Schools and Programs of Professional Psychology (NCSPP)	Section 7.1 D Site Visit Team NCSPP recognizes CoA desire to clarify its role in assigning site visitors, and appreciates the effort to preserve a programs’ ability to communicate any objections. We suggest strengthening this language to reflect something akin to “CoA will extend particular consideration to any program concerns that a prospective site visitor may have a conflict of interest that renders him/her an inappropriate member of the site visit team.”
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Mary	Hardiman	Board of Professional Affairs	Seems a reasonable addition for programs to know what the major concerns are that prompt a special site visit. Endorse this change.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Mary	Hardiman	Board of Professional Affairs	This change would streamline the site visitor selection process while still allowing programs to provide feedback on site visitor selections. CoA would take on the work of insuring site visit team availability and appropriate expertise which can delay scheduling the site visit. Endorse this change.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 7.D Doctoral Site Visit	Brad	Roper	Society for Clinical Neuropsychology (APA Div. 40)	Regarding the selection of site visitors, we are hopeful that clear explication of the CoA’s responsibility in selecting site visitors will lead to a more streamlined and timely process of scheduling site visits. However, we believe that the OPCA and CoA will need to develop more robust databases regarding site visitor qualifications, expertise, and conflicts of interest. In order to preserve and promote a system of true peer-review, site visitors should have familiarity with a program’s institutional setting and expertise in the program’s traditional or specialty practice area. Additionally, we agree that special site visits should allow for a broader review than merely issues identified as the reason for the special site visit.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Cindy	Juntunen		I appreciate the extension of the accreditation cycle from 7 to 10 years for programs demonstrating sustained ability to maintain requirements.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Deborah	Beidel	Council of University Directors of Clinical Psychology Programs (CUDCP)	CUDCP supports the extension of the period of between site visits to 10 years.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Daniel	Segal		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Barbara	Yutrzenka		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Bethany	Teachman		I agree with the CUDCP comment
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Stewart	Shankman		I strongly agree with the CUDCP comment
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Gibb	Brandon		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Julie	Suhr		I agree with the CUDCP comment re: these changes.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Michelle	Salyers		I agree with the CUDCP comment
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Sarah	Francis		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Lee	Cooper		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Julie	Exline		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Rebecca	Ready		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Jason	Schiffman		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Ellen	Koch		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Beth	Wildman		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Jan-Sheri	Morris	Board of Educational Affairs	8.1 D Guiding Principles of the Periodic Review BEA: BEA supports the plan for the CoA to assign site visitors as this will reduce any perception of bias or favoritism that is possible when the program selects their own from a list of randomly selected possible site visitors. This model is consistent with other health professions and eliminates any perceived conflict of interest.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Jan-Sheri	Morris	Board of Educational Affairs	8.4 D Site Visit Interval BEA: There was respectful disagreement among BEA members regarding extending the maximum allowable accreditation from the current 7 years to 10 years; however, the majority of BEA members favored this extension in light of the reality that all programs are accredited “annually” and must complete an online update along with communicating with CoA with any substantive changes to the program. We also understand that the maximum of 10 years is not a reference to the length of accreditation, as the AOP wording indicates that the time between periodic reviews is a range of 0 to 10 years (with shorter times until the next review given to those on contingent accreditation or with documented concerns by CoA).
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Merilee	McCurdy	CDSPP	8.2D It is not clear why programs can be listed for three years only, when the program can be accredited on contingency for 5 years? 8.4 D The option of a 10 year approval period should be reviewed carefully to address general implications, possible intermediate review circumstances, etc. APA/CoA should remind programs of their need to renew by an email or letter each summer and provide appropriate forms or checklists to make it easier to reapply each year. In an “accredited on contingency” status, who will review data after 3 years and be responsible for making a determination of the adequacy of formative outcomes? Committee within CoA or members of original site visit team?
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Tony	Cellucci	APTC	APTC strongly supports CoA having more control over site visitor selection and improving training for same with greater emphasis on how site visitors should collect unique information rather than repeat what is already found in documents We only cautiously support extending cycle to 10 years with caveat of careful attention to major changes in number or clinical courses/extent of clinical training provided, as well as turnover in core faculty and Director position. Ten years is a long time in the course of a program Again, we appreciate the CoA efforts and like the addition of contingent status. Good job
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Stephanie	Wood	National Council of Schools and Programs of Professional Psychology (NCSPP)	Section 8.2 D Accreditation Statuses and Decision Options NCSPP concurs with the timeframes proposed for each of the categories, i.e., 3 years for “intent to apply;” 5 years for “accredited, on contingency” and up to 10 years for review of accredited programs.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Mary	Hardiman	Board of Professional Affairs	Strongly support this change. This would reduce the administrative burden on programs that are providing quality training, would reduce the workload of the CoA in reviewing programs that are consistently in compliance with standards, and change is consistent with procedures in other health service accrediting bodies.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	Section 8.D Periodic Review by the CoA (Doctoral Level)	Brad	Roper	Society for Clinical Neuropsychology (APA Div. 40)	Regarding the change to a maximum of 10 years for period review, we view this as a positive development that will reduce the burden to programs that consistently demonstrate high quality. We are strongly in favor of the change. We look forward to the OPCA and CoA taking a larger role in keeping programs abreast of changes in accreditation requirements between periodic reviews.
Accreditation Operating Procedures Fall 2014	Internship Programs	Section 6.I & 7.I Internship Application for Initial Accreditation & Internship Site Visit	Jeff	Baker		I fully support the CoA moving to this method of assigning site visitors rather than programs choosing from a list (as sometimes 4 or 5 lists are needed). This would relieve the programs from the responsibility of calling down the list until someone is available (and interested) in doing the site visit. This takes up an inordinate amount of time for the Training Director and can be confusing/frustrating to make so many calls until someone says yes. Programs still have the option of identifying a conflict of interest for anyone assigned to their site visit.
Accreditation Operating Procedures Fall 2014	Internship Programs	Section 6.I & 7.I Internship Application for Initial Accreditation & Internship Site Visit	Philip	Lanzisera		Very reasonable
Accreditation Operating Procedures Fall 2014	Internship Programs	Section 6.I & 7.I Internship Application for Initial Accreditation & Internship Site Visit	Stephen	Holliday		Love the idea of CoA choosing the Site Visitors! It will be less of a burdon on the programs and more fully utilize the corps of trained SVs (especially the newer ones).
Accreditation Operating Procedures Fall 2014	Internship Programs	Section 6.I & 7.I Internship Application for Initial Accreditation & Internship Site Visit	Karin	McCoy		The programs that are accredited differ widely depending on setting, patient population, and services provided. The institutions or practices within which a training program is housed have guidelines, rules, and best practices unique to their setting. It would behoove the program and CoA to have site visitors familiar with the type of program being visited; for example someone familiar with a forensic hospital may not be the best site visitor for a university counseling center and someone familiar with a university counseling center may not be the best site visitor for a VA hospital. I am very concerned about the vagueness of the statement that "CoA is responsible for assigning site visitors, but will give notice to the program and provide an opportunity for the program to communicate its views and any objections regarding site visitor selection." I believe that the operating procedures should clearly state that at least half of the site visitors must have experience with the type...	See Full Comment
Accreditation Operating Procedures Fall 2014	Internship Programs	Section 6.I & 7.I Internship Application for Initial Accreditation & Internship Site Visit	Matt	Zimmerman	Association of Counseling Center Training Agencies	7.1. I Site Visit Team In ACCTA’s view, the CoA pre-assigning site visitors could facilitate the site visit scheduling process. It is appreciated that programs will have the opportunity to register views or objections regarding those site visitors. The proposed AOP is unclear re: how programs will have this opportunity to register such objections, and what process CoA will follow in evaluating such objections. In regard to assignment of site visitors by CoA, the most significant barrier for internship programs in choosing site visitors in the recent past has been scheduling difficulties. It will be helpful for CoA to ascertain prospective site visitors’ schedules as well as that of the program to be visited, and obtain a wide range of dates prior to assignment in order to identify possible non-workable pairings.
Accreditation Operating Procedures Fall 2014	Internship Programs	Section 6.I & 7.I Internship Application for Initial Accreditation & Internship Site Visit	Merilee	McCurdy	CDSPP	6.1 I If this is a 4 year period, why 4 year contingency period for internship and 5 for university programs?
Accreditation Operating Procedures Fall 2014	Internship Programs	Section 6.I & 7.I Internship Application for Initial Accreditation & Internship Site Visit	Stephanie	Wood	National Council of Schools and Programs of Professional Psychology (NCSPP)	Section 7.1 I Site Visit Team As reflected under comments to Section 7.1 D, NCSPP endorses CoA’s decision to assign site visitors, while preserving programs’ ability to communicate any objections, particularly as related to a potential or perceived conflict of interest.
Accreditation Operating Procedures Fall 2014	Internship Programs	Section 6.I & 7.I Internship Application for Initial Accreditation & Internship Site Visit	Mary	Hardiman	Board of Professional Affairs	Seems a reasonable addition for programs to know what the major concerns are that prompt a special site visit. Endorse this change.
Accreditation Operating Procedures Fall 2014	Internship Programs	Section 6.I & 7.I Internship Application for Initial Accreditation & Internship Site Visit	Mary	Hardiman	Board of Professional Affairs	This change would streamline the site visitor selection process while still allowing programs to provide feedback on site visitor selections. CoA would take on the work of insuring site visit team availability and appropriate expertise which can delay scheduling the site visit. Endorse this change.
Accreditation Operating Procedures Fall 2014	Internship Programs	Section 6.I & 7.I Internship Application for Initial Accreditation & Internship Site Visit	Brad	Roper	Society for Clinical Neuropsychology (APA Div. 40)	Regarding the selection of site visitors, we are hopeful that clear explication of the CoA’s responsibility in selecting site visitors will lead to a more streamlined and timely process of scheduling site visits. However, we believe that the OPCA and CoA will need to develop more robust databases regarding site visitor qualifications, expertise, and conflicts of interest. In order to preserve and promote a system of true peer-review, site visitors should have familiarity with a program’s institutional setting and expertise in the program’s traditional or specialty practice area. Additionally, we agree that special site visits should allow for a broader review than merely issues identified as the reason for the special site visit.
Accreditation Operating Procedures Fall 2014	Internship Programs	Section 8.I Periodic Review by the CoA (Internship)	Jeff	Baker		I support the idea of moving to a 10 year interval for site visits but also understand that programs might have more reporting requirements to insure the CoA is fully apprised of any changes that might interfere with the program's mission of training competent psychologists. 10 years is a long time and there are some strong stable internship training programs that have full support from administration, clinical supervisors and have a consistent outcome data with evidence they continue to produce quality graduates that are competent. If programs have that kind of stability and outcomes the 10 years works. I do think the CoA will have to address the necessity of what reporting requirements would be needed and how often the program would need to provide the information. Maybe similar to the ARO but adding some additional information/questions would be a possibility.
Accreditation Operating Procedures Fall 2014	Internship Programs	Section 8.I Periodic Review by the CoA (Internship)	William	ScarpettiI		My only comment is regarding the change from 7 to 10 years in the interval between site visits. Most internship programs and often their institutions are in very fluid economic and programmatic circumstances. Without some evidence that 10 year intervals would be sufficient, I think its better not to change the interval at this time.
Accreditation Operating Procedures Fall 2014	Internship Programs	Section 8.I Periodic Review by the CoA (Internship)	Matt	Zimmerman	Association of Counseling Center Training Agencies	8.2 Accreditation Statuses and Decision Options These appear clearly defined. ACCTA is appreciative of the extension of the potential accreditation periodic review time frame to 10 years.
Accreditation Operating Procedures Fall 2014	Internship Programs	Section 8.I Periodic Review by the CoA (Internship)	Matt	Zimmerman	Association of Counseling Center Training Agencies	8.4 I Site Visit Interval ACCTA is in support of the 10 year time frame between site visits.
Accreditation Operating Procedures Fall 2014	Internship Programs	Section 8.I Periodic Review by the CoA (Internship)	Matt	Zimmerman	Association of Counseling Center Training Agencies	8.2.I ACCTA would like clarification regarding the schedule for periodic review of internship programs. 8.2 I states that “The following decisions are available to the CoA with respect to the accredited status of a doctoral program,” without mention of internship programs. There does not appear to be another location in the document that discusses statuses and decision options for internships. Furthermore, 8.2.I c, if referring to internships as well as doctoral programs, notes that the decision making process leads to scheduled periodic review after 5 or 10 years, and it is unclear as to the basis for that differentiation. ACCTA recommends clarification on the basis for the time period designation between site visits for internship programs, as well as whether this is a continuous designation “up to 10 years,” a designation anywhere between 5 to 10 years, or categorically either 5 or 10 years.
Accreditation Operating Procedures Fall 2014	Internship Programs	Section 8.I Periodic Review by the CoA (Internship)	Mary	Hardiman	Board of Professional Affairs	Strongly support this change. This would reduce the administrative burden on programs that are providing quality training, would reduce the workload of the CoA in reviewing programs that are consistently in compliance with standards, and change is consistent with procedures in other health service accrediting bodies.
Accreditation Operating Procedures Fall 2014	Internship Programs	Section 8.I Periodic Review by the CoA (Internship)	Brad	Roper	Society for Clinical Neuropsychology (APA Div. 40)	Regarding the change to a maximum of 10 years for period review, we view this as a positive development that will reduce the burden to programs that consistently demonstrate high quality. We are strongly in favor of the change. We look forward to the OPCA and CoA taking a larger role in keeping programs abreast of changes in accreditation requirements between periodic reviews.
Accreditation Operating Procedures Fall 2014	Postdoctoral Residency Programs	Section 6.P & 7.P Postdoctoral Residency Application for Initial Accreditation & Postdoctoral Residency Site Visit	Jeff	Baker		I support the CoA assigning site visitors for the same reasons I submitted for the internship.
Accreditation Operating Procedures Fall 2014	Postdoctoral Residency Programs	Section 6.P & 7.P Postdoctoral Residency Application for Initial Accreditation & Postdoctoral Residency Site Visit	Stephen	Holliday		Agree that CoA should select the Site Visitors.
Accreditation Operating Procedures Fall 2014	Postdoctoral Residency Programs	Section 6.P & 7.P Postdoctoral Residency Application for Initial Accreditation & Postdoctoral Residency Site Visit	Karin	McCoy		The programs that are accredited differ widely depending on setting, patient population, and services provided. The institutions or practices within which a training program is housed have guidelines, rules, and best practices unique to their setting. It would behoove the programs and CoA to have site visitors familiar with the type of program being visited; for example someone familiar with a forensic hospital may not be the best site visitor for a university counseling center and someone familiar with a university counseling center may not be the best site visitor for a VA hospital. I am very concerned about the vagueness of the statement that "CoA is responsible for assigning site visitors, but will give notice to the program and provide an opportunity for the program to communicate its views and any objections regarding site visitor selection." I believe that the operating procedures should clearly state that at least half of the site visitors must have experience with the typ...	See Full Comment
Accreditation Operating Procedures Fall 2014	Postdoctoral Residency Programs	Section 6.P & 7.P Postdoctoral Residency Application for Initial Accreditation & Postdoctoral Residency Site Visit	Mary	Hardiman	Board of Professional Affairs	Seems a reasonable addition for programs to know what the major concerns are that prompt a special site visit. Endorse this change
Accreditation Operating Procedures Fall 2014	Postdoctoral Residency Programs	Section 6.P & 7.P Postdoctoral Residency Application for Initial Accreditation & Postdoctoral Residency Site Visit	Mary	Hardiman	Board of Professional Affairs	This change would streamline the site visitor selection process while still allowing programs to provide feedback on site visitor selections. CoA would take on the work of insuring site visit team availability and appropriate expertise which can delay scheduling the site visit. Endorse this change.
Accreditation Operating Procedures Fall 2014	Postdoctoral Residency Programs	Section 6.P & 7.P Postdoctoral Residency Application for Initial Accreditation & Postdoctoral Residency Site Visit	Brad	Roper	Society for Clinical Neuropsychology (APA Div. 40)	Regarding the selection of site visitors, we are hopeful that clear explication of the CoA’s responsibility in selecting site visitors will lead to a more streamlined and timely process of scheduling site visits. However, we believe that the OPCA and CoA will need to develop more robust databases regarding site visitor qualifications, expertise, and conflicts of interest. In order to preserve and promote a system of true peer-review, site visitors should have familiarity with a program’s institutional setting and expertise in the program’s traditional or specialty practice area. Additionally, we agree that special site visits should allow for a broader review than merely issues identified as the reason for the special site visit.
Accreditation Operating Procedures Fall 2014	Postdoctoral Residency Programs	Section 8.P Periodic Review by the CoA (Postdoctoral Residency)	Jeff	Baker		I believe that 10 years is an appropriate amount of time for postdoc accreditation but have similar concerns about reporting requirements and making that easy and efficient for programs to submit. Possibly through the ARO. A decade is a long time and I expect there would be many changes during that time and a program would need to be sure to keep CoA apprised of any of those changes that could be perceived to impact the quality of training.
Accreditation Operating Procedures Fall 2014	Postdoctoral Residency Programs	Section 8.P Periodic Review by the CoA (Postdoctoral Residency)	Kevin	Arnold	Council of Specialties in Professional Psychology	The Council of Specialties in Professional Psychology (CoS) thanks the Commission on Accreditation (CoA) for it unwavering dedication to promoting high-quality education and training programs in professional health service psychology. CoS also thanks CoA for the opportunity to comment on the proposed changes to CoA’s Accreditation Operating Procedures (AOPs). CoS makes the following comments: In general, CoS would encourage CoA to reconsider the placement of “specialty” education and training only under the AOPs related to post-doctoral residency programs (i.e., 8.1 P). It is a known reality that doctoral and internship programs use terms to reflect education and training in specialty areas within their public statements. For example, the University of Colorado, Denver, states it offers a doctorate in Clinical Health Psychology, and notes it is an APA-accredited program (http://www.ucdenver.edu/academics/colleges/CLAS/Departments/psychology/Programs/PhD/Pages/Overview--FAQs.as...	See Full Comment
Accreditation Operating Procedures Fall 2014	Postdoctoral Residency Programs	Section 8.P Periodic Review by the CoA (Postdoctoral Residency)	Antoinette	Minniti	Commission for the Recognition of Specialties and Proficiences in Professional Psychology (CRSPPP)	The Commission for the Recognition of Specialties and Proficiencies in Professional Psychology (CRSPPP) thanks the Commission on Accreditation (CoA) for its unwavering dedication to promoting high-quality education and training programs in professional health service psychology. CRSPPP also thanks CoA for the opportunity to comment on the proposed changes to CoA’s Accreditation Operating Procedures (AOPs). CRSPPP makes the following comments: In general, CRSPPP would encourage CoA to reconsider the placement of “specialty” education and training only under the AOPs related to post-doctoral residency programs (i.e., 8.1 P). Doctoral and internship programs use terms to reflect education and training in specialty areas within their public statements, a reality that led CRSPPP to develop the Education and Training Guidelines: A Taxonomy for Education and Training in Professional Psychology Health Service Specialties (Taxonomy). Given that programs make these claims, we would ask C...	See Full Comment
Accreditation Operating Procedures Fall 2014	Postdoctoral Residency Programs	Section 8.P Periodic Review by the CoA (Postdoctoral Residency)	Mary	Hardiman	Board of Professional Affairs	Strongly support this change. This would reduce the administrative burden on programs that are providing quality training, would reduce the workload of the CoA in reviewing programs that are consistently in compliance with standards, and change is consistent with procedures in other health service accrediting bodies.
Accreditation Operating Procedures Fall 2014	Postdoctoral Residency Programs	Section 8.P Periodic Review by the CoA (Postdoctoral Residency)	Brad	Roper	Society for Clinical Neuropsychology (APA Div. 40)	Regarding the change to a maximum of 10 years for period review, we view this as a positive development that will reduce the burden to programs that consistently demonstrate high quality. We are strongly in favor of the change. We look forward to the OPCA and CoA taking a larger role in keeping programs abreast of changes in accreditation requirements between periodic reviews.
Accreditation Operating Procedures Fall 2014	Section 1-5	General Comment on Sections 1-5	Norman	Stehenson		The data on successful placement of program completers in APA/APPIC approved/accepted internships should not only be prominately displayed to prospective program applicants, it and the percentage of program graduates who successfully complete the EPPP the first time they take it should be a prominent part of the standards for continued APA accreditation' Program students should have completed all requiremnts for graduation including the dissertation and passing the EPPP before applying for internship. Many state laws/regulations would have to be changed to allow studenrs toi take the EPPP before internship.
Accreditation Operating Procedures Fall 2014	Section 1-5	General Comment on Sections 1-5	Keith	Renshaw		I agree with the CUDCP comments.
Accreditation Operating Procedures Fall 2014	Section 1-5	General Comment on Sections 1-5	Myron	Hays		I am not clear on what a "Health Service Psychologist" is any longer with these changes. I would suggest that the CoA consider moving the definition to an IR so that it could update the definition in response to changes in the field, and to feedback from the public.
Accreditation Operating Procedures Fall 2014	Section 1-5	General Comment on Sections 1-5	Alicia	Del Prado		I support the NCSPP response for all sections.
Accreditation Operating Procedures Fall 2014	Section 1-5	General Comment on Sections 1-5	Jen	McCrindle	APPIC	On Behalf of APPIC: We want to thank the CoA for its excellent work, and indicate our overall support for both of these documents.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	General Comment on Doctoral AOP	Keith	Renshaw		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	General Comment on Doctoral AOP	Kathleen	Sikkema		I agree with the CUDCP comment.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	General Comment on Doctoral AOP	Julie	Koch	CCPTP (Council of Counseling Psychology Training Programs) Board	In most places it is noted that a periodic review will occur after 10 years for accredited programs except on pg. 29 under bullet c - where it says 5 or 10 years – this needs clarification. We really like that there can be up to 10 years between site visits/self-studies! We think having CoA assign site-visitors will substantially streamline the process, which currently can take weeks and weeks. We believe it is critical that programs are able to have feedback though and that it should be taken seriously; not sure how that will be assured. There are many ways in which conflicts of interest can arise that would not be known from something like a vita review (it is actually quite unclear to us how these assignments will be determined). We like the step-wise intent-to-apply/accredited on contingency/full accreditation process – it allows for growth. However, we have several questions about the process: We wonder if all levels will be allowed to send students into the APPIC mat...	See Full Comment
Accreditation Operating Procedures Fall 2014	Doctoral Programs	General Comment on Doctoral AOP	Nabil	El-Ghoroury	APAGS	APAGS appreciates the opportunity to provide feedback to the Commission on Accreditation regarding changes to the Accreditation Operating Procedures (AOP). We appreciate that CoA considers APAGS’ comments carefully and are happy to provide additional feedback on new changes. In general, APAGS is supportive of the recommended changes to the AOP. APAGS supports the addition of the “intent to apply” and “accredited, on contingency” statuses for doctoral programs. This is consistent with the same statuses for internship and postdoctoral programs, which APAGS supported as well. One question that APAGS had was that it was unclear from the AOP as currently written that the “accredited, on contingency” status was considered an APA-accredited internship. A student reading this AOP may not have that understanding. It would be helpful to make this as clear as possible that the “accredited, on contingency” status is considered an APA-accredited internship. In general APAGS supports a 10 year...	See Full Comment
Accreditation Operating Procedures Fall 2014	Doctoral Programs	General Comment on Doctoral AOP	Myron	Hays		I strongly support the CoS statement and encourage its adoption in its entirety.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	General Comment on Doctoral AOP	Morgan	Sammons	National Register of Health Service Psychologists	The National Register of Health Service Psychologists is a nonprofit organization established in 1974. The National Register credentials psychologists, promotes credentialed psychologists to consumers, guides psychology students towards credentialing, enhances psychologists’ contributions to integrated healthcare, and facilitates identification of qualified psychologists. With more than 10,000 credentialed psychologists, the National Register represents one of the largest practice communities in the field. The National Register has reviewed the August 2014 “Changes to Accreditation Operating Procedures” and wishes to take advantage of the opportunity to comment on these changes. In general, the National Register believes the proposed changes represent a significant advance over current standards, and wishes to compliment the members of the CoA and its staff for undertaking this challenging process. That said, the National Register does not agree with provisions in the proposed...	See Full Comment
Accreditation Operating Procedures Fall 2014	Doctoral Programs	General Comment on Doctoral AOP	Alicia	Del Prado		I support the NCSPP response for all sections.
Accreditation Operating Procedures Fall 2014	Doctoral Programs	General Comment on Doctoral AOP	David	Renjilian		I support the NCSPP response for all sections
Accreditation Operating Procedures Fall 2014	Doctoral Programs	General Comment on Doctoral AOP	Milton	Fuentes		I support the NCSPP response for all sections.
Accreditation Operating Procedures Fall 2014	Internship Programs	General Comment on Internship AOP	Joel	Schmidt	VA Psychology Training Council	Site visitor selection has been a significant challenge for some programs, so transferring the responsibility to CoA provides a significant benefit to our programs. However, it is recommended that the AoP specify that site visitor selection will continue to take the institutional setting into consideration and attempts will be made to select site visitors with experience in similar settings. The VA Psychology Training Council is in favor of moving from a 7 to 10 year maximal accreditation cycle, provided there is some level of oversight to help correct changes that may occur in less stable programs. Perhaps the Annual Review Online (ARO) provides this oversight. The new categories, “intent to apply” and “accredited, on contingency” may be valuable for new programs as mechanisms to demonstrate progress toward accreditation. For example, continued VA funding for training programs requires obtaining accreditation and these new categories may help demonstrate progress in this regard.
Accreditation Operating Procedures Fall 2014	Internship Programs	General Comment on Internship AOP	Myron	Hays		I strongly support the CoS statement and encourage its adoption in its entirety.
Accreditation Operating Procedures Fall 2014	Postdoctoral Residency Programs	General Comment on Postdoctoral Residency AOP	Joel	Schmidt	VA Psychology Training Council	Site visitor selection has been a significant challenge for some programs, so transferring the responsibility to CoA provides a significant benefit to our programs. However, it is recommended that the AoP specify that site visitor selection will continue to take the institutional setting into consideration and attempts will be made to select site visitors with experience in similar settings. The VA Psychology Training Council is in favor of moving from a 7 to 10 year maximal accreditation cycle, provided there is some level of oversight to help correct changes that may occur in less stable programs. Perhaps the Annual Review Online (ARO) provides this oversight. The new categories, “intent to apply” and “accredited, on contingency” may be valuable for new programs as mechanisms to demonstrate progress toward accreditation. For example, continued VA funding for training programs requires obtaining accreditation and these new categories may help demonstrate progress in this regard.
Accreditation Operating Procedures Fall 2014	Postdoctoral Residency Programs	General Comment on Postdoctoral Residency AOP	Myron	Hays		I strongly support the CoS statement and encourage its adoption in its entirety.
Accreditation Operating Procedures Fall 2014	Postdoctoral Residency Programs	General Comment on Postdoctoral Residency AOP	Antoinette	Minniti	Commission for the Recognition of Specialties and Proficiencies in Professional Psychology (CRSPPP)	The Commission for the Recognition of Specialties and Proficiencies in Professional Psychology (CRSPPP) thanks the Commission on Accreditation (CoA) for its unwavering dedication to promoting high-quality education and training programs in professional health service psychology. CRSPPP also thanks CoA for the opportunity to comment on the proposed changes to CoA’s Accreditation Operating Procedures (AOPs). CRSPPP makes the following comments: In general, CRSPPP would encourage CoA to reconsider the placement of “specialty” education and training only under the AOPs related to post-doctoral residency programs (i.e., 8.1 P). Doctoral and internship programs use terms to reflect education and training in specialty areas within their public statements, a reality that led CRSPPP to develop the Education and Training Guidelines: A Taxonomy for Education and Training in Professional Psychology Health Service Specialties (Taxonomy). Given that programs make these claims, we would ask C...	See Full Comment