CoA Response to Student Petition Regarding the Internship Imbalance

August 20, 2012

Michael Parent

Dear Mr. Parent:

As part of its responsibility for formulating accreditation policy, the Executive Committee of the APA Commission on Accreditation (APA-CoA) reviewed your open letter and petition to the American Psychological Association. The CoA wants to thank you for the comments you provided on the proposed revisions to Implementing Regulation (IR) D.4-7(b) regarding the threshold percentage for doctoral students placed in accredited internships; we also want to share with you four recent developments that are related to your concerns.

First, the CoA shares your concern about the internship imbalance and the need to ensure quality education for students/trainees in accredited programs. As a recognized accrediting body, the CoA must follow specific steps to make changes to its policies and procedures and then must adhere to those policies and procedures when making accreditation decisions. In terms of changing policies and procedures to address some aspects of the internship imbalance, following the recent public comment period, the CoA voted to approve the IR D.4-7(b) threshold for implementation in 2013 based on the results obtained from the 2011 Annual Report Online (ARO). All accredited programs are required to complete the ARO as part of the annual accreditation reaffirmation process so the CoA to assess compliance with the Guidelines and Principles for Accreditation (G&P) in between full reaccreditation reviews. A goal of the internship threshold is to remind programs of the importance of working to increase the number of students placed in internships that have been reviewed for external quality while working with others in the field to increase the number of quality internships. This threshold will not go into effect until the 2013 review of ARO data. As with all ARO thresholds, the 50% threshold will be reviewed in three years based upon ARO data and match issues at that time. It is important to note that no program will be in danger of an adverse accreditation decision based solely upon this metric on the ARO; the CoA will continue to review doctoral programs at the time of a self-study and site visit to determine how the program ensures a review of the quality of that aspect of doctoral education and training.

Second, following a period of public comment, at CoA’s July meeting changes to the Accreditation Operating Procedures (AOP) to allow for an alternative developmental sequence for applicant internship (and post-doctoral residency) programs was approved. These changes will enable an applicant program to complete a partial self-study that would be reviewed by the CoA to determine if the essential components for an “accreditable” internship program are in place, and to notify the public that a program is eligible for accreditation based on the standards contained in Domains A-D of the G&P.

Once a program has interns on site, it may apply for contingent accreditation by completing the full self-study (except for intern outcome data) and hosting a site visit. Contingent accreditation would be an accredited status that would protect the interns at a program at the time a site visit is conducted. A program on contingent accreditation status would be provided a time-certain deadline in which to submit outcome data and responses to any questions raised by the CoA for a full accreditation review. It is hoped that allowing for this sequence will enable new internship programs to become accredited and to increase the number of intern slots at APA accredited programs. This fall, both the Board of Educational Affairs and the Board of Directors will review the AOP changes for a target implementation date of January 1, 2013.

Third, in March 2012, the CoA revised the format for information that all doctoral programs must provide to the public. These data and the new format reflect the CoA’s belief that programs are obligated to share with the public, including prospective students, data in a standardized format. By September 15, 2012, all accredited doctoral programs will be required to provide data on the following key indicators using a required template: time to completion, program costs, internship placement, attrition, and licensure. Additionally, these data are to be placed within “one-click” of the program’s webpage and titled, “Student Admissions, Outcomes, and Other Data.” Although this IR has been in effect since 2006, the required format is designed to assist potential students in comparing programs on identical criteria and to allow the CoA to efficiently recognize identifiers that may signify a concern with a program’s educational quality. As you noted in your letter, debt load is certainly a significant concern for students and for the field; however, currently there are no valid and reliable ways to collect meaningful data that would enable comparisons across programs. Indeed, no centralized facility exists that links debt directly to educational costs, and reliance on self-report from students or from DCTs would be inexact and potentially result in greater confusion to the public.

Finally, at the 2012 APA Convention in Orlando, the CoA introduced its proposal for a review of the current G&P. The current G&P was initially adopted in 1995 and implemented in 1996. As we are sure you recognize, much has changed since then in higher education, education and training in professional psychology, and the health and mental health infrastructure in the United States. To guide the development of a new set of accreditation standards, the CoA has designed a “Roadmap” as a four-phase process. This systematic process will rely on input from all of the relevant publics at each phase. The CoA is asking its many communities of interests to engage in open, needed discussions about standards for accreditation. The CoA will review all phase-specific input prior to creating the next wave of questions for a subsequent phase, so that thorough input from the field will inform the drafting of the new set of standards. The Roadmap has been released for public comment and may be accessed from the Accreditation website. As with the other initiatives discussed above, the CoA can only move forward with changes following one or more periods of public comment. We therefore encourage you to review the proposal and to provide comments to the questions.

Collectively, the CoA believes these are constructive approaches to dealing with the issues you raised in your letter. Further, as these policy changes move forward and the CoA examines solutions to improve the quality of psychology education and training, it is hoped that all those served by accreditation will continue to partner with and engage in dialogue with the CoA. In order to communicate this response to the publics served by accreditation and the signatories to the petition, this letter will be posted on the Accreditation website.

Sincerely,

Elizabeth A. Klonoff, PhD, ABPP
Chair, APA Commission on Accreditation