Section 1: Background, Process, and Statement of the Commission
In February 2000, the APA
Council of Representatives (Council) approved the establishment of a 30
member, presidentially-appointed, cross-constituency Commission on Education
and Training Leading to Licensure in Psychology.
Commission was charged to report back to the Board of Directors within one
year with recommendations for modifications in education, training,
and supervision requirements leading to licensure
in psychology, particularly as they relate to the current and future
marketplace for psychological services. The
Commission’s review of the education, training, and licensure process was to
include an examination of the content of training in relation to the twin
goals of quality of education and training and relevance to the changing
marketplace and emerging specialties. Council
requested that the Commission's report include specific mechanisms for
achieving its recommendations.
APA President Dr. Patrick DeLeon appointed APA President-Elect, Dr. Norine Johnson, to chair the Commission. The Commission was co-chaired by two members of the APA Board of Directors, Dr. Ronald F. Levant and Dr. Ruth Ullmann Paige. Nominations for commissioners were solicited from the organizations and governance constituencies specified by the Council of Representatives. Each commissioner was granted one vote in decisions of the Commission. Commissioners represented the organizations that nominated them, and were expected to consider issues in light of the concerns of the constituencies they represented. Commissioners were not required to seek authorization of their nominating organizations, as the Commission itself was an independent group. Based upon their expertise in the field, commissioners were asked to vote their minds on the issues discussed by the Commission. As such, the recommendations of the Commission carry the weight of a group of respected leaders representing many constituencies in the field. Decisions of the Commission are not binding on the nominating organizations.
Meetings of the Commission were held May 19-21 and September 8-10, 2000. A list of organizations and constituencies represented on the Commission and the names of their commissioner(s) and liaison(s) is attached as Appendix 1.
The Commission was charged with
reviewing the current state of education and training in professional
psychology for the purpose of determining at what point basic readiness for
independent practice is achieved. Given
that licensure is intended to be a proxy for this basic readiness to practice,
the Commission used
as a starting point for discussion the
Model Act for State Licensure of Psychologists (Model Act), the current
APA policy that provides recommendations regarding education and training
leading to licensure. The
Commission was aware that its recommendations were intended to inform
policymakers and that only the APA Council of Representatives can make changes
to APA policy.
The Commission asserted that professional training,
whether at the practicum, internship, or postdoctoral level, needs to be
organized, sequential, and well supervised with ongoing evaluation of
competence in a breadth of professional areas.
The Commission’s review of the current state of education and
training in professional psychology highlighted the changes in predoctoral
supervised professional training that have occurred over the last fifty years,
and especially within the past decade.
The Commission specifically and explicitly stated that two years of organized, sequential, supervised, professional training experience (in addition to completion of the doctorate) is necessary and sufficient for entry-level professional practice. The Commission affirmed a one-year, formal, predoctoral internship as a necessary component in the sequence of education and training, and recommended that this be added as an explicit aspect of APA policies regarding licensure. Students currently receive a substantially increased amount of supervised professional training in practica prior to internship. Provided that this pre-internship practicum experience is organized, sequential, and well supervised, the Commission believed that this experience met the need for a second year of training in addition to the internship. However, the additional year could also be obtained after the predoctoral internship and the granting of the degree, through postdoctoral experience. Thus, the Commission did not recommend decreasing supervised experience for licensure, but rather recommended increased flexibility in the timing of these experiences. The Commission believed that this flexibility would strengthen the profession by better matching current training models and also by encouraging accountability among training programs for providing organized and sequential training, regardless of whether it is predoctoral or postdoctoral.
The Commission was committed to
the importance of APA accreditation of both doctoral and internship programs,
yet wanted to ensure that opportunities remain available for new and
innovative programs to develop as well as for postdoctoral respecialization.
The Commission concluded that
current training of many doctoral psychologists provides them with sufficient
experience to be competent for entry-level practice upon completion of the
internship and doctoral degree (when they have completed two years of
organized, sequential, supervised professional training experience
predoctorally). At the same time,
the Commission explicitly and strongly wished to affirm the value of
organized, sequential, supervised postdoctoral experiences for those who wish
to receive further training. Obviously,
psychologists who do not receive two years of such training predoctorally
should have the option of receiving it postdoctorally.
In addition, for those psychologists who have received two years of
training predoctorally, the Commission saw organized postdoctoral training
programs, postdoctoral consultation, and postdoctoral supervision as an
important mechanism for the development of advanced competency and expertise
for professional practice.
The Commission was aware that
implementing changes in APA policy and in licensing laws and regulations would
require significant commitment of time and both human and financial capital
and a significant shared commitment among the various communities within
organized psychology. The
Commission was further aware that changes in APA policy do not automatically
translate into changes in legislation and regulation.
Further, decisions about implementation and the impact of efforts to
implement policy changes will need to be considered in the context of
legislative priorities in a given state, but also in the context of other
priorities and initiatives underway within organized psychology.
At the end of its first meeting, the Commission voted on a draft statement that proposed altering the education and training recommendations for licensure in the Model Act. Between meetings, commissioners reviewed the draft statement carefully with their constituency groups, and through a series of working groups, outlined its implications for each stage of the education and training process. An Implementation Working Group focused solely on the legal and political challenges of implementing the draft statement recommendations in actual state licensure acts.
reviewed the implications of the draft statement compiled by the working
groups during the second meeting of the Commission.
Discussion of these implications led to revision of the Commission’s
statement. The Commission voted
and approved the statement below. A
second series of working groups convened to develop recommendations and
implementation strategies for each constituency group that would be
responsible for implementing various recommendations.
These recommendations and strategies are presented in Section 2.
Please note that the commissioners felt strongly that the
recommendations in Section 2 are interdependent.
They did not feel that APA policy could simply be changed without
parallel supporting action as outlined in the recommendations.
The Implementation Working Group reconvened to develop a list of
implementation issues and implications that should be considered if APA
contemplates a policy change. These
issues and implications are presented in Section 3.
of the Commission
Commission on Education and Training Leading to Licensure in Psychology
recommends that psychologists be eligible to sit for licensure upon completion
of the following education and training:
A doctoral degree from an APA- or CPA-accredited program in psychology.
Where accreditation in the program’s substantive area is not
available, the program will be required to be designated as a doctoral program
in psychology by the Association of State and Provincial Psychology Boards or
the National Register of Health Providers in Psychology.
The equivalent of two years of organized, sequential, supervised
professional experience, one year of which is an APA- or CPA-accredited
predoctoral internship, or one that meets APPIC membership criteria, or, for
school psychologists, a predoctoral internship based in a school setting which
meets CDSPP Doctoral Level Internship Guidelines.
The other year of experience also may be completed prior to receiving
the doctoral degree.
An aspect of this
training is the ongoing assessment of competence in a breadth of professional
areas. Postdoctoral education and
training is an important part of the continuing professional development and
credentialing process for professional psychologists.
Section 2: Commission Recommendations
Section 3: Implementation Elements
The proposed policy changes from the Commission are destined to remain historical artifacts unless issues of implementation are seriously addressed. The Implementation Working Group of the Commission believes that for APA to entertain the possibility of movement from proposed policy to large-scale implementation of psychology license statutory change, it must, by definition, agree to address the changes outlined in this report. In addition this will require major financial, intellectual and personnel resources of the APA. Moreover, this will not be enough in and of itself, and must also coincide with similar priority setting and resource commitment by groups outside of APA such as State and Provincial Psychological Associations (SPPAs), educational institutions, the COA, state Political Action Committees (PACs), and the Association of State and Provincial Psychology Boards (ASPPB).
section outlines the issues needing attention as well as a preliminary
template for organizing the necessary support, data, money and advocacy to
move from policy to implementation through licensing law and regulatory change
and accreditation standards modification.
recognize that the requirements outlined below may seem daunting.
However, please bear in mind that changes of this nature while they
have been daunting, have been achieved in the past and can be achieved in the
future if it is clearly determined to be in the best interests of the
Board of Directors
Council of Representatives
its related committees
and its related committees
and BPA and related committees
Committee of State Leaders
External entities that will be affected include:
and Provincial Psychological Associations
of psychology at universities and professional schools
and post doctoral programs
and accrediting groups
and Provincial licensing boards
regulatory, and other governmental bodies
APA needs to craft the case for policy change in a clear, comprehensive, and convincing way for the various constituencies to fully understand the impact of their vote. To change policy without emphasizing the dependence on changing statutory requirements for psychology licensure may leave future psychologists out of compliance with licensure requirements, since this is regulated by state/provincial law.
plan to change state/provincial law will require an appreciation for the
complexities of these processes as well as an understanding of how this new
policy initiative could negatively impact current psychology policy priorities
that are in place at this time. These
complexities must be explained,
the alternatives must be demonstrated
to be inadequate in addressing the problems, and those voting must be willing
to allow for changes in the existing professional psychology
priorities. The following partial
list of issues should be considered in decision-making.
states/provinces need to change licensing law to accommodate change to
two-year predoctoral experience requirement
states can change through regulation but this is also a political/advocacy
will be costly (see funding)
needs to be general psychologist and SPPA board buy-in that this is a priority
for the state legislative agenda
is always risk of unintended and unwanted language being inserted into
psychology licensing law as well as more substantive reorganization when
licensing laws are “opened up” for legislative changes
level issue – what could be seen (and would be described by other
professions with their own agendas) as downgrading of psychology requirements
would conflict with attempts to contain the statutory scope of practice of
groups trained at the master’s level and helps discriminate psychology from
other “psychotherapy” providers
authority legislation attempts to broaden and increase the scope of practice
for psychologists while the proposed APA policy change could be seen (and
would be described by our opponents) as decreasing psychologists’ training
states have just completed legislative efforts to comply with the current
model psychology act in terms of postdoctoral experience requirements and
report that they do not feel that they could “come back to the well” (the
legislature) again for years
states are in a constant battle to retain the uniqueness of their psychology
board from the threat of being subsumed under an omnibus board of licensed
mental health or health professions
efforts at the state/provincial level would be impacted by any perceived
dilution of licensing standards
effort to implement the new APA policy would need careful crafting of
arguments and rebuttals and would probably need to be done in a sequenced and
and licensing boards will have to be convinced that this change will not in
any way have a negative impact on the consumer
initiative needs to be considered within the list of other legislative
priorities determined by the Board of Directors of the SPPA
states have legislative priorities laid out for years in advance, and few have
planned to work on this policy change at this point in time
SPPA priority setting is controlled by the SPPA and some is not (e.g. outside
groups filing bills antithetical to the needs of psychologists require
legislative resources from the association)
setting depends on the political climate within the state.
A bill might be ready to go but wait years for a favorable political
landscape. SPPAs must take the
lead role in coordinating the decision of when and how to file a bill.
policy change will be expensive and should not be seen as only a practice
issue. Since practitioners
comprise a good part of the membership of the SPPAs, APA-wide acceptance of
the issue and APA funding will be needed.
This change must also be seen as an APA priority since political
contributions to state PACs are lowest from the constituencies which most
desire this change, e.g. students, educators, internship directors, etc. Thus, funding will need to be association-wide and will need
to address the issues below, among others.
funds will be needed at the state association level, particularly for
of APA, CFO will need to develop cost estimates
academic resources available
SPPA membership will increase the financial base through dues
will need to work with their PACs
university lobbyists will be an added resource
Education Directorate funds to train key faculty at state universities in
Rural and Special
small and rural states need outside financial help just to maintain part-time
executive directors, so additional funding for legislative initiatives is
rural states have few or no APA-accredited training programs and internship
sites. There is currently a
necessary economy of scale which must be met for it to be feasible for a
program to apply for APA accreditation, so if this is to be the norm, some
accommodations need to be met to deal with this issue.
Concern was expressed that if APA program accreditation is required,
support will be lost from the schools who now train psychologists but feel
they are too small or under-funded to apply for accreditation.
In addition, expecting legislative changes to eliminate licensure of
graduates from schools in a state that is too small to support an APA-
or CPA- accredited program will never happen.
In addition, some legislatures are not willing to endorse professional
association accreditation as education or training standards for licensure
but, instead, adhere to other accrediting entities.
internships geared to special populations, especially those representing
ethnic, cultural, and other minority groups, provide an important service but
may not have economy of scale factors for accreditation purposes.
internships need to be allowed to accommodate legitimate personal, family, and
areas of the country have fewer internship slots than students seeking
internships. Some students cannot
leave or choose not to leave their
geographical area to train. The system of
matching students to internship sites and the impact on licensure
needs to be addressed, especially if the impact of not finding an
appropriate internship is failure to achieve licensure.
information identifying students and their educational programs is needed to
determine if additional internship training sites are required.
students can get licensed without accredited internships but if this criterion
is required, the stakes become higher to get one and so will the competition.
above for special issues of rural and diverse areas and populations.
such as school psychology and IO have not developed extensive
Since these systems are not
primarily healthcare, the necessary work and expense may not be a priority for
them and they may even be opposed to a policy change.
There needs to be an alternative or process to address licensure needs
for these groups.
of legislative and regulatory change could take 10-20 years or more.
the period of licensing law change, attention to educating students and
faculty of the changing and differing requirements of each state would be
would have to be informed about the possible need to complete three years of
supervised experience (two predoctoral and one
would need to address the needs of small or rural states and small services to
insure that psychologists can continue to be trained in those localities to
work with those special population groups.
would need to address a process such as provisional accreditation of programs
and sites if they are starting up and if accreditation is required for
general, one positive aspect of this process is that this might be the time to
step back and look at the whole accreditation process to see if it needs
modification as well.
states/provinces allow students to sit for the EPPP
exam after completion of the doctorate. Students may be able to take
the exam in those states and transfer their scores to the board in another
state that does not allow them to sit for the exam until some months after
completion of the postdoctoral year. This
may cut up to six months off of the wait for some students. Working to make
this option possible in all states could be explored.
Also, beginning next year, the possibility to take the EPPP through
computer administration at any time the student is eligible, should help
alleviate the problem.
between states with different licensure requirements needs to be addressed.
Since 25 jurisdictions have agreed to accept the ASPPB Certificate of
Qualification for individual mobility and since this requires a postdoctoral
experience, the Commission recommendations will have a major impact on
mobility. The Commission may have to decide on priorities, or work with
ASPPB to accommodate the proposed policy changes. Attention
and accommodation needs to be made for mobility of people licensed under the
old/current criteria of the model act and to states who change their
requirements as well as for people getting trained as systems evolve to a new
Data from the Education Directorate, Science Directorate and Public Interest Directorate will be needed to present a case about most or all of the representations we make in our arguments for the proposed changes. These data need to be compelling enough to sway groups of professionals such as licensing boards, educational institutions and our own APA boards. Data is needed in the following areas:
e.g. how many hours of predoctoral training are students currently doing?
Is the increase in hours related to the competitiveness of the APA
internships or some other factor? How many practicum hours do students
complete now as compared to the past?
Is there resistance to decreasing practicum hours?
Are there stakeholders in maintaining the number of hours?
Do APA (or CPA/ APPIC) internship sites produce psychologists
better qualified and/or prepared for independent practice?
How many programs and internship sites would be unable to meet the new
criteria for training leading to licensure?
How many states would be without programs or internships that would
meet the proposed new licensure standards? Difficulties in acquiring
postdoctoral supervision and the variability of quality must be documented.
Is there any vehicle for improving postdoctoral training?
Would new approaches to payment for postdoctoral training improve the
quality of the supervised experience? Is
there evidence that the postdoctoral experience is unnecessary for licensure
for practice at journeyperson level must be demonstrated through treatment
outcomes data and compared to similar data for other professional groups.
increased predoctoral experience years need data to develop argument that
there is more quality control over training if done under the auspices of the
should show that the level of training prepares an individual for the scope of
practice granted under licensure.
need to be collected related to general and specific
consumer protection issues such as, impact on training psychologists
who represent diversity and who treat diverse populations, quality measures
for treatment provided by psychologists trained under the new model, impact on
rural states and populations in terms of programs acceptable under the new
criteria, and access to psychologists in the future.
data on the economic impact of the change to current system and reimbursement,
student loan programs, training funding issues, and managed care
reimbursement. Are there
alternative methods to subsidize training programs and students that address
the current specific problems in postdoctoral training as well as the length
of training in general? What
additional efforts could APA make to promote Federal initiatives in mental
other questions and challenges which might arise through the legislative
will insurance companies be affected – NCQA standards, Medicare and
Medicaid, and other third party payers?
estimate of time and materials that need to go into training of people that
will sell this argument
Does This Fix the Problem? – Additional SPPA Advocacy
issue, which sparked the creation of the Commission, was the problem of third
party reimbursement for psychology interns.
This policy change does not specifically address that problem.
Advocacy for state, federal, and third party reimbursement would need
to continue and be coordinated with this effort.
Advocacy may be made more difficult, particularly with third party
payers, by what may be perceived as a reduction in training requirements, so
the argument emphasizing “time shifting” not “training reduction”
needs to be strongly crafted.
extent that this is seen as a move to a more medical model of training, which
it will be by some, attention needs to be paid to the issue of medical
residencies as they relate to specialty care.
The postdoctoral year has been used in this way for some people and
models of further utilizing and organizing this process might be made.
Academic Community Buy-In
education community must address the issue of buy-in of the academic
departments to the proposed APA policy change, and moreover must convince them
that for this to occur, it must be seen as a high priority.
argument made that regulation of the profession is improved by bringing the
pre-licensure training under the purview of the academic department must be
supported by data, which need to be collected.
buy-in for the recommendation that the graduate department will approve and
monitor both of the required two years of experience, it is necessary to
clarify this expectation and the responsibility this entails.
We must make it clear that academic programs are not being asked to
sign off that the student is
competent to practice, but that the student has met the established
criteria for the granting of the degree.
This expectation will probably not work for the postdoctoral year, and
should be reviewed by COLI.
institution faculty will need to be on-board with the policy change and the
impetus for this buy-in needs to come from the educational community.
statewide political/lobbying mechanisms within state universities will be
needed. Therefore it will be imperative to obtain agreement
to set our issue as a high priority and work with the SPPAs as the lead
those who might disagree with policy within universities, and try to
neutralize the opposition.
the association of psychologists who work in medical schools for support.
development of student groups within state associations.
with academic institutions to get their students and faculty in support of the
change and trained in advocacy.
and new professionals need to push their academic departments to get involved
in this issue.
APAGS to set this change as one of their top priorities.
Selling the Proposal
Meeting the data needs and processes outlined above must alternate with work to achieve buy-in and support from necessary constituencies to authorize the resources necessary. To gain this support, the following things need to happen:
materials need to be developed with content adjusted for internal and external
marketing of the new policy.
Data must be available for distribution.
constituencies must be convinced at the onset that the policy change is a
solution to the problems and should consider it a high priority.
· All the data, goals and proposals must be concise and in place before moving to the external education and advocacy plans.
that SPPAs reach out to their members and state educational institutions
through their training committees, coordinating this effort with academic
programs encouraging states to establish training committees, and reaching out
to academic programs and internship sites.
associations need to use their coalition base (like in the parity coalition)
to inform and address any opposition.
must develop a coordinating mechanism for state associations as laws are being
passed to coordinate the legislative activities.
cogent arguments for policy change, provide data to describe the current and
projected training elements, and describe implementation needs
buy-in plans and implementation
buy-in plans and implementation
development of cogent arguments to address all of the potential implementation
problems and arguments
of grass roots network – both state associations and academic programs
other supporters, such as parents of students and internship sites (a move to
a national standard of program hours should
lead to better quality and uniformity)
potential opponents, such as schools and internships that will be eliminated,
get data on who they are, and try to generate alternatives and neutralize
EDUCATION AND TRAINING
Norine G. Johnson, PhD
F. Levant, EdD
Ullmann Paige, PhD
Psychological Association of Graduate Students
Carol Williams (May)
Marcus Patterson (September)
Diana Salvador, M.S.
Task Force on New Professionals
Corey Habben, PsyD
of Counseling Center Training Agencies
Joyce Illfelder-Kaye, PhD
Jennifer Erickson Cornish, PhD
of Psychology Postdoctoral and Internship Centers
Emil Rodolfa, PhD (May)
Nadine Kaslow, PhD (September)
Emil Rodolfa, PhD (September)
of State and Provincial Psychology Boards
Asher R. Pacht, PhD
for the Advancement of Psychology in the Public Interest
Jessica Henderson Daniel, PhD
of Educational Affairs
Virginia A. Mathie, PhD (May)
Robert G. Frank, PhD (September)
of Professional Affairs
Toy Caldwell-Colbert, PhD (May)
Suzanne Bennett Johnson (September)
of Scientific Affairs
Christopher Peterson, PhD
of State and Provincial Representatives
Barry Anton, PhD
of State Leaders
Anne Cowardin-Bach, PhD
Thomas Jackson, PhD (May)
D. Phillips, PhD (September)
Elizabeth Davis-Russell, EdD, PhD
of Chairs of Training Councils
Beverly Thorn, PhD
of Counseling Psychology Training Programs
Rodney K. Goodyear, PhD
of Credentialing Organizations in Professional Psychology
Judy E. Hall, PhD
of Directors of School Psychology Programs
Stephen T. DeMers, EdD
of Executives of State and Provincial Psychological Associations
Elena Eisman, EdD
Sally R. Cameron
of Graduate Department Chairs in Psychology
David Scott Hargrove, PhD
Florence L. Denmark, PhD
of Health Psychology Training Programs
Gary Geffken, PhD
of Specialties in Professional Psychology
Neil S. Grossman, PhD
of University Directors of Clinical Psychology Programs
Daniel W. McNeil, PhD
of Veterans Affairs
Robert C. Gresen, PhD
Peggy J. Cantrell, PhD
Council of Schools and Programs of Professional Psychology
Joseph W. Bascuas, PhD
Kathi Borden, PhD
for Industrial and Organizational Psychology
Richard M. Klimoski, PhD
Presidential Appointee: Kathleen
Mary Brabeck, PhD
APA Board of Directors: George
P. Taylor, PhD (May)
Nathan W. Perry, Jr., PhD (September)
Cynthia Belar, Ph.D.
Christopher J. McLaughlin
Paul D. Nelson, Ph.D.
Geoffrey M. Reed, Ph.D.
Carol Williams, Psy.D.
with doctoral degrees in psychology who wish to respecialize may complete
the education and training requirements described in this document
By 2010, all internships shall be APA- or CPA- accredited.
 The Council of Chairs of
Training Councils (CCTC) consists of the following member organizations: Association of Counseling Center Training Agencies (ACCTA),
Association of Directors of Psychology Training Clinics (ADPTC), Association
of Medical School Psychologists (AMSP), Association of Postdoctoral Programs
in Clinical Neuropsychology (APPCN), Association of Psychology Postdoctoral
and Internship Centers (APPIC), Canadian Council of Professional Psychology
Programs (CCPPP), Council of Program Directors in Community Research and
Action (CPDCRA), Council of Counseling Psychology Training Programs (CCPTP),
Council of Directors of School Psychology Programs (CDSPP), Council of
Health Psychology Training Programs (CHPTP), Council of University Directors
of Clinical Psychology (CUDCP), National Council of Schools and Programs of
Professional Psychology (NCSPP), and VA Psychology Training Advisory
Committee (VA PATC).
CCTC has liaison
relationships with the following orgainzations: Association of State and
Provincial Psychology Boards (ASPPB), American Psychological Association of
Graduate Students (APAGS), Council of Graduate Departments of Psychology (COGDOP),
Committee for the Advancement of Professional Practice (CAPP), Committee on
Accreditation (CoA), Council of Specialties (CoS), and The National Register
of Health Service Providers in Psychology (NR).