NCAPP response to the APA draft SoA HSP - Masters:

We, the board members of the North Carolina Association of Professional Psychologists (NCAPP), have reviewed the draft Standards of Accreditation (SoA)in Health Service Psychology – Master’s, and appreciate the opportunity to comment. We are interested in this effort hoping that this would be a signal that the American Psychological Association’s (APA) recognizes the important contributions of master’s degreed psychological professionals and practioners. Unfortunately, this draft SoA does not seem to account for the required coursework, competencies, and standards necessary for licensure in states where master’s degreed psychologists practice. There are numerous concerns with this SoA with regard to content, expectations, and perhaps most importantly, intent. Some of those concerns are contained in the following comments and questions:

Type of Program: Health Service Psychology.

• Does this draft SoA support Independent Practice for master’s degreed professionals?
   
• Is this draft SoA consistent with the scientific model? If not, what provides the foundation for these SoA?
   
• As evidenced by APA’s Division of Health Psychology, Health Psychology is already a defined practice area of Psychology. Is Health Psychology included in Health Service Psychology? Clinical Psychology, Counseling Psychology, and School Psychology all have very different skill sets, client populations and responsibilities. There is little benefit to each of those practice areas or to the profession by including them under one title.  

  Institutional and Administrative Structure: Program Context and Resources

• The SoA includes Program Administration and Structure, that appears to be aspirational as opposed to standards that can be observed and measured. How does this improve on current SoAs already well accepted and integrated into state and provincial licensing boards? 

  Institutional and Administrative Structure: Program Context and Resources: Length of Degree, Delivery Method, and Design

• Why is there no set or recommended number of required graduate hours or semesters? Why does this draft SoA, section Discipline Specific Knowledge and Profession-Wide Competencies, provide that only a “general knowledge base in the field of psychology” need be acquired? These should be core components and foundational for psychology. How is it that bachelor’s courses could be applied here? These tenets leave open the door for programs that will meet very minimal standards according to this SoA, that may graduate students ill prepared for the practice of psychology. Does it seem to make sense that the APA, an organization that should represent the field of psychology the best, provides vague and undefined SoA for students? 

  Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession: Required Clinical Training Elements

• Supervision is a key element for early career psychologists, such that it is important to have a knowledgeable, experienced, psychologist providing this necessary teaching element. What is meant by this draft SoA supervision specification that provides only that supervision should be provided by “appropriately trained and credentialed individuals”? 

  Aims, Competencies, Curriculum, and Outcomes: Aims of the Program

• For any program to be credible, it should meet observable, measurable standards for success. This includes setting a realistic expectation for the rate of “success” by its graduates, by measuring the rate of their licensure, certification, and employment. A program which does not meet even a minimum standard should attempt to determine the cause.  It would be unfair to future students not to disclose the rate of “success” in the program’s communications. As required in Section V. A. 2. b., program is expected to “describe accurately and completely in documents that are available to current students, prospective students, and other publics. This information should be presented in a manner that allows applicants to make informed decisions about entering the program.” How does this draft SoA meet this expectation? 

  Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession

• Psychology and behavioral sciences licensing boards across the nation already specify education and institutional requirements toward licensure, which includes accreditation. Currently, a number of states provide a full spectrum of psychological services provided by master’s degreed practitioners who have attended accredited institutions. Is this to provide a foundation toward assisting other states to license master’s degreed psychologists to provide much needed psychological services, or to strip the ability of master’s degreed practitioners to provide the full scope of services to which they have been trained?
   
• Psychology consistently and continually has been losing ground to our allied fields (e.g. counseling, licensed clinical social workers, etc) to the detriment of the people who need our care. Overall, there is a shortage of psychological services, which adversely affects those in need. In NC alone, there are 20% of the counties where mastered-degreed psychologists are the ONLY psychologists available. How does this effort expand psychological services and benefit those who need services, in particular, how does the SoA better prepare graduates to become master’s credentialed practioners?
   
• Only in the behavioral health area of psychology, do we find, via the APA, attempts to suppress, marginalize, and block access to care from master’s- degreed practioners.  This increases the divide between master’s and doctoral psychologists and reduces the numbers of psychologists coming together to grow and strengthen the field, and does not best serve the public. This leads to the issue of title. The APA has an opportunity to generate an accurate and respectful title for master’s-degreed psychologists. A title that does not intend to portray well qualified professionals as assistants, interns, associates, students, or some other, if not ancillary, staff as indicated in the associate/assistant title or Health Services Provider. Does the APA offer this SoA toward increasing access to psychological services by including master’s degreed professionals with a title specifying the provision of psychological services? Or is this SoA, which appears to be less robust than other already in place SoAs, an attempt to water down the quality of education provided to master’s students and therein, preclude master’s qualified professionals from securing licensure?
   
• What is the benefit of this APA accreditation over other credentialing agencies, such as MPCAC, which provide more specificity regarding course content, hours, etc? And what is the benefit of allowing bachelor’s degreed courses required master’s credit hours? 

  Discipline-Specific Knowledge, Profession-Wide Competencies, and Learning/Curriculum Elements Required by the Profession: Discipline-Specific Knowledge and Profession-Wide Competencies

• Our allied professionals, including Licensed Clinical Social Workers, Licensed Professional Counselors, and Licensed Clinical Mental Health Counselors, are thriving despite doctoral-degreed psychologists' effort to thwart their independence and scope of practice over the years, in part because they are unified within their discipline and thus have greater numbers. Social workers and Counselors do not discriminate and undermine professionals in their field based on their degreed of education. How does this draft accreditation model promote master’s degreed psychologists toward practice within the full scope of their teaching and training?
   
• Master’s Degreed Psychologists have been recognized and credentialed by State Behavioral Sciences Regulator and Psychology Boards, and have served in a competent and professional manner for the last three decades. The current education, training, examination for license (EPPP) and credentialing is equivalent to or exceeds those of other professional groups who enjoy the recognition and privileges of practice and service. Psychologists at the master’s degreed are an integral part of multiple states' behavioral health care systems and provide those skills uniquely Psychologist's in assessment, diagnosis and treatment. Many rural and underserved areas rely upon master’s degreed clinicians to help deliver mental health services to individuals who are traditionally underserved by medical and behavioral specialists. We advocate for stringent standards in education and training for the practice of psychology as provided by credentialing models currently in place (e.g. MPCAC). This APA draft, however, includes vague and non-descriptive language that seems to do little to augment existing standards. Further, these draft standards seem to be insufficient to meet the standards set by state licensing boards for practice. As such, this is tantamount to lowering the bar of educational standards, and thus, does a disservice to the populations we serve.
   
• Master’s-Psychologists are currently taught by doctorate-degreed psychologists in graduate school the same as doctorate-degreed psychologists. Courses are completed with the PSY designation in the department of psychology, and with a thesis contributing to the body of knowledge in the field of psychology. Master’s students graduate with not only credits requirements, but also, practicum/internship, and subsequently, the same EPPP examination that the doctorate-degreed psychologists take, many passing at the doctorate-degreed (>500), with some scoring higher than the doctoral supervisors. Master’s students are trained in and follow the same APA ethics code and obtain licensure under the same licensing boards within the respective states as doctoral psychologists. Why does the APA continue to hold the position that master’s degreed professionals are not qualified to practice, despite successfully having done so in numerous states for more than three decades? What does this draft SoA represent regarding the APA’s view of master’s degreed professionals? 

  Summarily, we would expect that a master’ program accreditation developed and implemented by the APA, would graduate the most qualified students with the highest levels of competence. This draft document of Standards of Accreditation in Health Service Psychology – Master’s, seems to fall well short of that goal when compared to other standards of accreditation already accepted and integrated into institutions that provide psychology programs.

  This United States is in the midst of a mental health crisis, while facing a tremendous shortage of available psychologists. In North Carolina alone, there are twenty counties that are served only by Licensed Psychological Associates (master’s degreed). We would hope that the APA reconsider the draft, at least with regard to the concerns provided here, with the goal of graduating future master’s degree practicing psychologists to help fill the gaps and to increase access to mental health care.