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AMERICAN PSYCHOLOGICAL ASSOCIATION
APPROVAL OF SPONSORS OF CONTINUING EDUCATION
FOR PSYCHOLOGISTS:
Criteria and Procedures Manual
November 1996
(updated July 2002)
PREFACE
This 1996 Manual is a revision of the
document APA Approval of Sponsors of Continuing Education for Psychologists,
approved by the American Psychological Association Council of Representatives
in January 1987. Adopted by Council as APA policy at that time, the criteria
and procedures in this document have been reviewed annually by the Continuing Education in Psychology Committee and the Board of Educational Affairs.
The Manual was updated to reflect changes in policies and procedures.
The Criteria have not been revised. Please discard any previous
versions of the Manual you already have.
TABLE OF CONTENTS
SECTION ONE
SECTION TWO
APPENDIX ONE
APA Ethical Principles of Psychologists
APPENDIX TWO
Guidelines for Specialty Changes
APPENDIX THREE
SAS Fee Structure
APPENDIX FOUR
Procedures for Reconsideration and Appeal of Adverse Decisions
APA APPROVAL OF SPONSORS
OF
CONTINUING EDUCATION FOR PSYCHOLOGISTS:
1996 CRITERIA AND PROCEDURES MANUAL
SECTION 1
INTRODUCTION
The American Psychological Association
(APA), founded in 1892, is the largest and most prestigious psychological
organization in the United States. The purpose of APA is to advance psychology
as a science, as a profession, and as a means of promoting human welfare
by:
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Promoting research in psychology and
improving research methods and conditions;
Continually improving the qualifications and competence of psychologists
through high standards of ethical conduct, education, and achievement;
Disseminating psychological knowledge through meetings, psychological
journals, books, and special reports. |
A. Background of the APA Sponsor
Approval System (SAS)
As set forth in the APA Bylaws, APA recognizes the interest and the responsibility
of psychologists to continue their educational and professional development
beyond the level of graduate training. Because psychological knowledge
and skills are ongoing, it is necessary to have a means of updating them
through the process of continuing education (CE). The following definition
of continuing education was developed by the Continuing Education in Psychology Committee and other governance groups within APA: "Continuing Education in Psychology (CEP) is an ongoing process consisting of formal
learning activities that (1) are relevant to psychological practice, education
and science, (2) enable psychologists to keep pace with emerging issues
and technologies, and (3) allow psychologists to maintain, develop, and
increase competencies in order to improve services to the public and enhance
contributions to the profession." The Sponsor Approval System was
created by APA to facilitate psychologists' access to quality CE programs
that have come under careful review and subscribe to APA criteria as set
forth in this manual.
APA's Sponsor Approval System:
1.
2.
3.
4.
5. |
Encourages CE among psychologists;
Encourages the development of high-quality CE programs;
Offers psychologists access to CE programs offered by APA-approved
sponsors;
Provides technical assistance and guidance to organizations in the
development or improvement of existing CE programs;
Encourages the development of a network of CE sponsors for the overall
enhancement of CE programs available nationwide to psychologists. |
CE is not a substitute
for the basic academic education needed for entry to the field of psychology,
nor should it be the primary vehicle for career changes from one specialty
area in psychology to another.
(For APA's policy on training for psychologists wishing to change their
specialty, please see Appendix 2.)
Therefore, programs that cannot be considered continuing
education are:
1. Organized programs of study leading to
a degree;
2. Programs covered by APA's policy on psychologists
wishing to change their specialty;
3. Internship programs undertaken as part
of 1 or 2 above.
B. Continuing Education in Psychology Committee:
Structure and Function
The APA Continuing Education in Psychology Committee (hereinafter referred
to as "CEPC" or the "Committee") reviews and approves
organizations (e.g., universities, private clinics, professional associations,
specialty societies, consulting firms, etc.) that offer continuing education
programs for psychologists. The system is not designed to approve the
individual offerings of sponsors. Approved sponsors have the responsibility
for designing and scheduling programs in compliance with the CE-SAS criteria
provided in this manual.
The Committee is responsible for reviewing and ruling on applications
for approval. The Committee is composed of members appointed by the APA's
Board of Educational Affairs. In appointing members, every attempt is
made to select individuals who are expert in CE program planning, administration
and evaluation, and who broadly represent the major fields of psychology,
various geographic regions, and individual characteristics such as sex
and ethnic or cultural identity. Nominations to the Committee are solicited
openly by means of the regular APA nomination process. Membership on the
Committee rotates so that at least two new members are appointed to the
Committee each year.
CEPC meets twice a year, shortly after the deadlines for receipt of applications.
In reviewing applicants and monitoring approved sponsors, the Committee
is committed to following the guidelines as established in the APA Approval
of Sponsors of Continuing Education: Criteria and Procedures Manual. The
Committee reports to the Board of Educational Affairs and submits annual
reports of its activities. The work of the Committee in approving sponsors
of CE is kept confidential except that (a) disclosure shall be made in
instances in which APA is legally advised or required to disclose such
information; (b) information on a specific sponsor may be made available
to other accrediting agencies by which the sponsor has been approved or
whose approval the sponsor is seeking; (c) APA's legal counsel may be
requested to review application materials; and (d) approved confidential
minutes of the Committee's meetings shall be available only to the Committee,
the Board of Educational Affairs, the Executive Director of the Education
Directorate, the APA Executive Officer, the CE Programs Office staff,
and, in the case of an appeal, to the Board of Directors. The Committee
reserves the right to seek expert advice and relevant information from
other external sources when reviewing an application, provided that such
advice is kept confidential by the Committee and the advisor and that
there is no possible conflict of interest.
C. Home Study and Self-Managed CE Programming
Although most sponsors choose to offer programs such as workshops and
seminars, a variety of CE experiences is encouraged. These might include
home study and self-managed CE programming. Programs such as these increases
the flexibility of CE and help to meet the needs of psychologists who
do not have access to traditional CE learning experiences. They also offer
cost-efficient and easily accessible continuing education without sacrificing
quality.
Home study CE programming is a sponsor-created, standardized set of learning
experiences with fixed content that individuals can participate in off-site,
on their own time. Home study programs usually take the form of books,
audiotapes, videotapes, CD-ROMs, and so on, accompanied by a test.
Because home study programs are to be used by the participant on an individual
and independent basis, the standards for awarding credit are especially
important. Specifically, home study programs must:
1. Have a structured learning curriculum;
2. Indicate the method used to determine the
number of credit hours to be awarded and data to validate this method;
3. Indicate the method used to ensure that
the person to whom credit is awarded does the work.
Self-managed CE programming is an individualized program of learning that
sponsors develop to meet the specific needs of a learner based on an assessment
of the individual's professional strengths and weaknesses. The program
may be on or off-site. For example, if a psychologist identifies a need
for training in a particular area, he or she would locate a source for
that training and develop a plan for acquiring the needed knowledge or
skill, perhaps with the guidance and/or input of a mentor or counselor.
As with any other CE programming offered under the APA Sponsor Approval
System, home study and self-managed CE programs must adhere to the standards
set forth in Section 2, Criteria, Parts A through M
of this manual.
SECTION 2
CRITERIA FOR APPROVAL OF SPONSORS OF CE FOR PSYCHOLOGISTS
In this section criteria are presented
in three ways. Each is preceded by its general principle and may be followed
by a discussion of points intended to help you when filling out the application
form. Note that all criteria apply to various types of activities designated
by you as approved CE activities, including workshops and seminars, as
well as correspondence (via print or computer) learning. In some cases,
we refer to nontraditional learning activities as home study or self-managed
programs.
| A |
Goals
PRINCIPLE
The objective of CE for psychologists is to facilitate the highest
quality professional work, whether in clinical applications, teaching,
consultation, or research. CE for psychologists should be designed
to meet the specific needs of postgraduate professionals within the
field.
CRITERION |
A.1. |
CE program goals of APA-approved sponsors
must address the importance of psychologists' access to resources
that: |
a.
b.
c.
d. |
May improve their competence
in professionally relevant ways;
Make possible the acquisition of new skills and knowledge required
to maintain competence;
Strengthen the habits of critical inquiry and balanced judgment that
denote the professional and scientific person;
Acknowledge and recognize their specific CE needs. |
| B. |
Administration
PRINCIPLE
Sound administration with psychologists' input is essential for maintaining
high quality CE programs for psychologists.
CRITERIA |
B.1.
B.2.
B.3.
B.4.
B.5.
B.6. |
Psychologists
must provide direct input and be involved in all phases of the decision-making
and program-planning process for the activities you offer to psychologists
for credit.
You must have a clearly designated administrator of your program.
You must specifically indicate where CE programming fits in the
overall administrative structure of the organization, if applicable.
You must have a mechanism or procedures to maintain current and
continuing awareness of and adherence to APA CE policies and principles.
If offering home study programs or activities, you must have sufficient
staff resources to fulfill your obligations to users of such programs.
You should carefully monitor these activities to ensure educational
effectiveness and consistency.
If an APA-approved sponsor has branches or subsidiaries and wishes
to offer CE credit for psychologists through the branch or subsidiary,
complete oversight and administration of the program must come through
the parent, or approved, organization. The approved sponsor must
be involved fully in the planning and implementation of CE programs
and must assume full responsibility for these programs. If the above
conditions do not apply, the branch or subsidiary must submit a
separate application to APA for approval as a continuing education
sponsor or must establish a co-sponsor relationship with the parent,
or approved, organization.
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| DISCUSSION
Psychologists can provide direct input and be
involved in all phases of the decision making and program planning
processes through their representation on advisory boards, CE committees,
or any body with the responsibility of determining the content and
structure of continuing education activities.
Continued administrative support is essential for a program to remain
in compliance with the APA Sponsor Approval System. Although the
person responsible for the administration of the CE program need
not be a psychologist, he or she must be knowledgeable regarding
the Sponsor Approval System criteria and procedures. You must ensure
this continuity throughout administrative staff changes. For example,
members of your organization's CE Committee could serve staggered
terms, or you could develop a "how-to" booklet with policies
and procedures written down and readily available to pass on to
new personnel.
Home study programs present a special administrative challenge,
since materials must be developed, processed, reproduced, and distributed;
in addition, procedures for scoring, notification, and record-keeping
must be established and maintained. Approved sponsors of home study
programs need adequate administrative staff resources to develop,
implement, and maintain appropriate procedures and records. |
| C. |
Co-sponsorship
PRINCIPLE
Co-sponsorship occurs when an APA-approved sponsor maintains full
responsibility for a continuing education program, while joining
with one or more organizations to offer CE activities leading to
CE credit for psychologists.
CRITERIA |
C.1.
C.2.
C.3. |
Co-sponsorship is
appropriate when it enables organizations to share financial, administrative,
instructional, and other resources in a combined effort to offer
high quality continuing education.
As an APA-approved sponsor, you must assume the same responsibilities
and liabilities when co-sponsoring an activity as if you were the
sole sponsor. Co-sponsored programs must fulfill your CE objectives
and meet all criteria as set forth in this manual.
The APA-approved sponsor must have a prior agreement with the co-sponsor,
in writing, that includes:
|
a.
b.
c.
d. |
Clarification
of responsibilities of each organization, including financial, administrative,
instructional, and others;
Involvement of the approved sponsor in all aspects of program planning.
A co-sponsorship relationship must be established prior to or during
the planning stages of an activity at a point where contributions
and changes can still be made.
The approved sponsor must ensure that the Ethical Principles of
Psychologists are upheld.
In cases where each organization is APA-approved, clarification
of which organization will accept and maintain responsibility for
the activity.
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DISCUSSION
Co-sponsorship is the act of mutually planning an activity, not
to be construed as lending or transferring approval status. It does
not permit the APA-approved sponsor to act as an approval body by
reviewing a program or organization and then stating that it is,
in turn, approved by APA. Note that co-sponsorship carries with
it the same responsibilities and liabilities for the APA-approved
sponsor as preparing a program alone. Co-sponsored programs should
fulfill the CE objectives of the approved sponsor. |
| D. |
Budget and
Resources
PRINCIPLE
Sound financial planning is essential to the development,
administration, and improvement of CE programs. Sufficient resources
must be available to provide adequately for quality CE programs.
CRITERIA |
D.1.
D.2. |
You
must have documented sources of financial support for the CE program.
Your budget and resources must be sufficient to meet all financial
obligations associated with the program offerings. Resources must
be adequate to support both direct and indirect program costs, including
operational and nonoperational expenses as well as current and expected
financial liabilities. |
| E. |
Facilities
PRINCIPLE
An effective CE program requires adequate facilities and materials.
CRITERIA |
E.1.
E.2.
E.3. |
Your facilities must provide
appropriate space for the kind of educational methodology used and
be private enough to safeguard confidentiality of case material
or work samples.
Facilities are expected to accommodate and be accessible to persons
who are physically challenged. This includes the room in which the
activity is taking place, restrooms, parking spaces, overnight rooms,
and meeting rooms.
For home study programs, prospective users should be advised of
any special equipment or materials they will need to provide.
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DISCUSSION
For home study programs using technological media for learning,
an audiotape-base program can reasonably be assumed to require the
use of an audiotape player. The same can be said for video or computer
activities. If, however, special equipment or software will be needed
which cannot reasonably be inferred from the promotional material,
the sponsor should clearly indicate what equipment, supplies or
materials are needed. |
| F. |
Program
Selection and Development
PRINCIPLE
CE offerings for psychologists, and educational objectives, should
be based on the interests and needs that have been identified through
solid assessment procedures.
CRITERIA
|
F.1.
F.2.
F.3. |
You must have methods
for determining psychologists' learning needs, interests, and objectives.
You must be able to describe the basis on which program topics are
chosen.
You must incorporate the results of participants' evaluations from
previously offered activities into the planning process for future
program offerings.
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DISCUSSION
You must be able to show how CE programs relate to identified needs
and interests in order to be approved as a CE sponsor. Educational
needs and interests refer to any type of knowledge, skill or attitude
that psychologists wish to or should develop, acquire or maintain.
In addition to your own perception of need, the programs you choose
to offer will be enhanced when different sources of information
are used, including:
|
1.
2.
3.
4.
5
|
A review of evaluation
data (participant ratings) from previous similar CE activities,
when available;
A survey of learning needs and interests from different sources
(e.g., a random sample of psychologists, intended participants,
experts in specialty areas, consumers of psychological services,
instructors);
A search of the current literature;
A survey of issues and concerns of experts in a particular field;
and
Suggestions and feedback from administrators, supervisors, and patients.
|
| We encourage you
to identify a target audience of participants who will benefit from
the program being planned. Depending on the goals and content of
the activity, the target audience can be defined in terms of individuals'
current level of knowledge or skill in the subject matter, their
past professional experience, methods of learning, and objectives
in acquiring skills through the program. |
| G. |
Instructional
Personnel
PRINCIPLE
The quality and value of CE programs depend in large part on the
instructor's expertise, competence in subject matter, and ability
to facilitate learning.
CRITERIA
|
G.1
G.2.
G.3.
G.4. |
Instructors must
be competent and expert in the area they will teach.
Teaching ability must be a primary prerequisite for selecting CE
instructors.
You must have some methods for monitoring and rating the instructors'
levels of knowledge and ability to teach, such as internal evaluations
and satisfaction questionnaires.
Home study program materials must be prepared by qualified individuals,
including content and test-preparation experts.
|
DISCUSSION
Instructors' qualifications may be indicated by advanced degrees
in psychology from a regionally accredited institution or specialized
knowledge in a particular area. Some methods of determining instructors'
teaching abilities include review of records of previous teaching
experiences, evaluation forms from previous teaching positions,
personal knowledge of the instructor's teaching ability, and references.
It is not a requirement that all instructors be PhD-level psychologists;
however, you must be assured of the expertise of the instructor,
regardless of whether he or she is a psychologist.
The content materials on which a home study program is based should
be prepared with the input of psychologists. In cases where a written
publication is to be used for home study, the content should be
reviewed by a psychologist to assure its appropriateness for postdoctoral
level individuals. If testing materials are not prepared by a psychologist,
they should at least be reviewed by a psychologist. |
| H. |
Curriculum
Content
PRINCIPLE
Effective CE programs are up to date with respect to the topics
and the empirical, theoretical and practice literature, use current
data, and address predetermined educational objectives using teaching
methods and materials appropriate to the subject matter.
CRITERIA
|
H.1
H.2.
H.3.
H.4. |
CE programs must
be relevant to psychological practice, theory, and method for doctoral-level
psychologists.
CE programs for psychologists must have educational objectives.
CE programs for psychologists must be long enough to explore one
subject or a closely related group of subjects in reasonable depth,
but they must not be less than one full hour.
For home study programs, outcomes should be specified in terms of
performance expected on the test instrument.
|
DISCUSSION
The term "continuing education," as it is defined in this
manual, refers to education and training experiences "designed
to provide or update knowledge and skills above the doctoral level."
"Above the doctoral level" refers to the particular knowledge
and skill level of the individual attending a program, not necessarily
the level of the material being presented. According to this interpretation,
the overriding consideration is whether programs offered for CE
credit provide psychologists who have already obtained their doctorate
with an opportunity to improve their knowledge and skills in areas
relevant to their profession.
Every CE activity offered for credit, regardless of its length,
must have clearly defined educational objectives. You must define
carefully what will be taught and, ideally, what the participant
is expected to learn as a result of attending the program, and this
information must be made available to participants before they enroll.
The purpose of developing educational objectives is not only to
provide potential participants with information to use in selecting
programs, but also to provide a set of criteria for you to use in
assessing whether the goals you have established for your program
have been achieved.
Your CE activities should deal with subject matter that is relevant
and generally recognized within psychology. Claims made that imply
new, innovative, and/or breakthrough types of findings may require
substantiation via empirical data.
Often, longer programs that span several months and involve supervision
are offered. In order for credit to be granted for the supervision
component, the supervised activity must be a natural extension and
integral part of the structured educational enterprise that, in
its entirety, meets all other criteria for activities offered for
credit. That is, it must have predetermined and specific educational
objectives, measures to evaluate participant learning and satisfaction,
and so forth. Free-standing supervision, which involves an open-ended
approach, flexible agenda, and case discussions, would not meet
the requirements for CE credit.
|
| I. |
Program
Evaluation
PRINCIPLE
Participants' evaluation of CE activities (1) provide the workshop
leader or presenter with prompt feedback on how well he or she has
accomplished his or her objective of teaching participants new or
additional skills and knowledge and (2) provide data for your organization's
use in planning future programs or improving current ones.
CRITERIA
|
I.1.
I.2.
I.3.
I.4.
I.5.
I .6. |
You are required
to have a procedure that assesses the participants' satisfaction
with the overall program and their degree of perceived (self report)
and/or achieved (objective) learning relative to the program's specific
educational objectives. This procedure, which normally, but not
necessarily, will take the form of a written rating, must be a part
of each activity for which CE credit for psychologists will be awarded.
We encourage you to have all participants (not just psychologists)
provide this feedback to increase the validity of the results.
At a minimum, you should obtain feedback on participant satisfaction
in the following areas:
|
a.
b.
c.
d. |
The
quality of instruction and teaching ability (e.g., did the instructor
present material in a clear and orderly fashion, gear material to
a level appropriate to the audience, respond to questions and needs
of the audience, maintain interest?);
The instructor's level of knowledge and expertise;
The usefulness of the program content for meeting each of the program's
stated educational objectives;
The adequacy of the physical facilities (e.g., comfort, accessibility,
space, visual and auditory supports).
|
| You must document
and use the results of the evaluation process to modify current
programs and plan future ones.
You must be able to describe how the results of your evaluation
procedures are used to modify current programs and plan future ones
(see Section F, Program Selection and Development).
You must use a method that assures successful evaluation of home
study programs.
|
a.
b. |
Objective measures
of learning (rather than self report), designed specifically for
each home study activity, are required for all home study programs.
Although not recommended for in-person activities, a pass/fail determination
is required of home study programs where there is no actual contact
between instructor and participant.
|
DISCUSSION
Individuals who attend CE activities usually do so at substantial
expense either to themselves or to their employers; such participants
are usually highly motivated and have high expectations of the practical
nature of what they learn. You will want to obtain data, both subjective
and objective, on whether these expectations are being met by the
CE activity being evaluated.
We encourage you to obtain data on the effectiveness of teaching
strategies and communication, the instructor's ability to maintain
participants' attention and interest, and the usefulness of the
information presented. Such data are particularly valuable in evaluating
programs and activities that will be repeated at future dates and
for additional audiences.
CE activities may or may not require objective measures of learning.
However, you are encouraged to obtain data on the content areas
learned by participants as a way of determining the effectiveness
of a program. |
J. |
Standards for
Awarding Credit
PRINCIPLE
The awarding of CE credit is based on participation in an activity
that meets the criteria for activities as outlined in this manual.
CRITERIA |
J.1
J.2.
J.3
J.4
J.5.
J.6.
J.7
J.8.
J.9.
J.10. |
You must give participants documentation
that states the number of CE credits earned.
Credit must be awarded in units of whole or half-hours.
One credit is awarded for each hour of the CE activity in which
learning actually takes place. Credit must not be awarded for lunch
hours, breaks longer than 15 minutes, etc.
The statement of APA approval (see page 15) and the name of the
activity must appear on such documentation.
You must be able to verify the awarding of CE credit to participants
and provide this verification to individuals who request it for
at least three years after completion of the activity.
You must require participants to attend 100% of activities that
are short term (less than a week) if the components of the activity
run consecutively (i.e., one hour or one day after another). For
long-term activities in which components do not take place consecutively,
at least 80% attendance is required for credit.
Variable credits, depending on the percentage of attendance, may
not be offered (i.e., if an activity is 6 hours in length, all credits
awarded must be for full 6-hour attendance).
For home study activities, for which actual contact hours are difficult
to determine, you need to specify the method used for determining
the number of CE credits to be awarded for successful completion.
The method used has to be consistent from program to program so
that a uniform measure of CE credit is applied.
If you offer home-study activities, you should make every effort
to ensure that the individual returning the materials for credit
is the person who actually completed the work.
It is important that you provide concise information to users of
home study programs indicating what the requirements are for successful
completion of the CE program and subsequent awarding of credit.
|
DISCUSSION
You must develop a consistent policy regarding what constitutes
full attendance at your CE activities. This policy must ensure compliance
with other APA criteria regarding CE activities. For extended activities
in which 80% attendance is required, participants should be asked
to perform a make-up task designed by the instructor to cover the
material that was missed. |
K. |
Ethics
PRINCIPLE
CE activities and affairs associated with CE programming should conform
to the highest ethical standards available to psychologists.
CRITERIA |
K.1.
K.2.
K.3.
K.4.
K.5.
K.6.
K.7. |
You must conduct
and promote CE activities following the principles set forth in
APA's Ethical Principles of Psychologists as they apply to the conduct
of CE activities (see Appendix 1).
Any demonstrations or procedures carried out by instructors and
participants must conform to the highest ethical and professional
standards as currently established by APA's Ethical Principles of
Psychologists.
Claims made that imply new, innovative, or breakthrough types of
findings should be defined as such to potential participants and
may require substantiation via empirical data.
You cannot discriminate when hiring staff, selecting participants,
or selecting faculty.
You must maintain confidentiality regarding instructional materials
and participant disclosure. When applicable, you should explicitly
state at the beginning of the program that confidential material
may be discussed and review with the participants the limits of
that confidentiality.
If any activities are potentially stressful or upsetting to participants
(as far as most psychologists can predict), you must inform participants
before they enroll or attend.
You must develop written procedures for dealing with participant
complaints in a reasonable, ethical and timely fashion. It is not
necessary to include these procedures in promotional materials.
For samples of such procedures, contact the CE Programs office. |
|
|
|
|
L.
|
Promotion and
Advertising of Programs
PRINCIPLE
CE promotional materials must demonstrate careful consideration of
ethical principles (e.g., content of presentation, credentials of
presenters, facilities, conduct of the activity, etc.).
CRITERIA |
L.1. |
Participants must have access to the
following information prior to enrolling: |
a.
b.
c.
d.
e.
f. |
Educational objectives
(see Discussion, Section H, Curriculum Content);
Participants for whom the activity is designed and skill level for
which the activity is appropriate;
Schedule and format (including starting and ending hours);
Cost of the activity, the refund/cancellation policy and any additional
fees or expenses;
Faculty credentials, including at a minimum the highest earned relevant
professional degree and current professional positions;
The number of CE credits offered for each activity.
|
Although this information
must be made available to participants before they register for
an activity (e.g., in a brochure or descriptive document), it does
not have to be included in all promotional materials. However, the
means of obtaining this information from you must be clear.
|
| L.2. |
If you wish to mention
your relationship to APA in promotional materials such as ads, brochures,
and announcements, only the following statement may be used:
"(Your name) is approved by the American
Psychological Association to offer continuing education for psychologists.
(Your name) maintains responsibility for the program."
|
This statement,
when used, must appear in its entirety. The only time a shortened
statement may be used is when the full statement of approval is
used elsewhere in the same promotional piece. An example of a shortened
statement that may be used if the full statement appears elsewhere
is as follows:
|
L.3.
L.4. |
"CE Credits for Psychologists"
If an activity is co-sponsored, promotional
materials and documentation of credit/attendance must clearly indicate
which organization is accepting the responsibilities for upholding
APA criteria, as in the following example:
"This program is co-sponsored
by (Your name) and
(Name of "partner" sponsor).
(Your name) is approved by the American
Psychological Association to offer continuing education for psychologists.
(Your name) maintains responsibility for the program."
If you have been approved by other bodies in addition to APA you
may, under certain conditions, combine APA's approval statement
with that of ACCME, NBCC, and so on. The following conditions must
be met:
|
a.
b.
c. |
The statement must indicate
that your organization is approved, not the activity.
The statement that your organization maintains responsibility for
the program must be present.
The term "accredited" (if used by other organizations) should
either be replaced by or accompanied by the term "approved."
|
| Example: |
|
"As an organization approved by
the ACCME, the American Psychological Association, the Kansas Behavioral
Sciences Regulatory Board (social workers), and the National Board
of Certified Counselors, (your name) is offering this activity for
4 hours of continuing education credit. (Your name) maintains responsibility
for the program." |
L.5.
L.6.
L.7. |
Do not use the term "CEU"
(continuing education unit) to refer to credits earned from APA-approved
organizations. CE credit for psychologists is granted on a one credit
per one contact hour basis; the CEU, on the other hand, grants one
CEU for every ten contact hours.
Do not use the terms "accredit" or "accreditation"
in reference to the APA Sponsor Approval System, because it creates
confusion with APA's Accreditation program for graduate programs and
internships.
You may not use the APA logo when advertising your programs or on
documentation of attendance. |
| M.
|
Home Study Programs
PRINCIPLE
Home study is an alternative method to face-to-face contact for the
delivery of postdoctoral CE for psychologists. The sponsor must maintain
high standards in the design of home study materials to optimize quality
educational materials for psychologists engaging in continuing education
through this method of delivery.
CRITERIA |
| M.1. |
As an APA-approved sponsor you must
ensure that each home study program has, at a minimum, all of the
following components: |
a.
b.
c. |
A structured learning curriculum or
syllabus;
An objective assessment of content learning, including a specified
criterion level of performance (e.g., 75%), a means by which tests
are scored, and a reasonable time period within which tests will be
scored;
Validity data, including: |
| |
i.
ii.
iii.
iv. |
A method of determining credit hours
(e.g., page count)
Evidence documenting a rationale for this method (e.g., field trial)
For objective measures of learning (e.g., multiple choice, true/false),
sufficient length of testing instruments.
For essay measures, indication of content to be included and metric
for rating this (e.g., grading grid) |
| |
d. |
A method for ensuring that the individual
participated in the continuing education activity and that all work
was done by the person awarded the credit. |
| M.2. |
Regarding on-line home study offerings,
there will be: |
a.
b. |
A sufficient user ID system in place,
and
A mechanism for safeguarding the security of psychologically-sensitive
materials. |
PROCEDURES FOR APPLICATION REVIEW
A. Eligibility to Apply
The following types of organizations are encouraged to apply for approval:
APA divisions, state or regional psychological associations, departments
of psychology or other divisions within universities or colleges, private
educational organizations, professional societies or associations, hospitals,
medical schools, mental health centers, and government agencies. It may
be appropriate for other organizations to apply as well.
B. How to Apply
In order to obtain APA-approval as a sponsor of CE for psychologists, organizations
must submit an application for review by the Committee. The original application
and supporting materials must be accompanied by three collated copies of
the application and all supporting materials and a nonrefundable check covering
the appropriate application fee. Applicants who would like assistance in
completing the application may write or call the APA Sponsor Approval System.
The application and all subsequent communications should be forwarded to
the Sponsor Approval System, American Psychological Association, 750 First
Street, NE, Washington, DC 20002-4242. For costs involved in applying for
and maintaining APA approval see Appendix 3, or call the APA Sponsor Approval
System at 202-336-5990. Sponsor Approval System staff will also review draft
applications and provide feedback to applicants assuming that a draft is
received at least one month in advance of the application deadline.
C. When to Apply
The Committee reviews applications for approval twice a year. Approval will
be based on the extent to which the applicant is judged to meet the SAS
criteria specified in Section 2 of this document.
In addition to the information and materials supplied by the applicant,
the Committee reserves the right to consult other sources of information
as appropriate. Under special circumstances, the Committee may request a
site visit, with the cost of this visit borne by the Sponsor.
TYPES OF COMMITTEE ACTION
A. 2 Year Preliminary Approval
2 Year Preliminary Approval is granted to first time applicants who minimally
meet the SAS criteria as outlined in Section 2 of this manual. At the end
of the preliminary approval period, sponsors must reapply for continuation
of approval by submitting a full application. During the preliminary approval
period, sponsors will be required to address any shortcomings noted by the
Committee at the time preliminary approval was granted. At the end of the
2 Year Preliminary Approval period, sponsors apply for a five-year period
of time.
B. 5 Year Full Approval
5 Year Full Approval is granted to applicants who have successfully completed
a 2 Year Preliminary Approval period and submitted an application that satisfactorily
addresses shortcomings noted by the Committee at the time of preliminary
approval. A full renewal application must be submitted at the end of the
five-year period.
C. Preliminary or Full Approval with Inquiry
Inquiry may be made if the Committee requires timely clarification of an
apparent misuse or misunderstanding of one or more points of the criteria.
At the time of the Review Report, staff, upon direction from the Committee,
makes inquiry into the suspected criteria violation or concern and asks
for a response within a specific time frame (usually 30 days). Staff then
reviews the response for its thoroughness in addressing and/or correcting
the concern(s) and determines whether the response is sufficient. If staff
deems the response insufficient in addressing the concerns, the materials
will be forwarded to the ad hoc complaint advisors, who will determine if
probation should be put into effect. If the sponsor does not respond to
the inquiry by the specified deadline, it will be placed on administrative
probation for 30 days, after which termination of approval will occur if
a response is not forthcoming.
D. 1 Year Conditional Approval
1 Year Conditional approval may be granted to applicants who have completed,
at a minimum, a 2 Year Preliminary Approval period but do not meet all of
the SAS criteria as stated in Section 2 of this manual. Conditional approval
is for a period of one year, at which time sponsors must reapply with attention
given to the specific areas of concern indicated by the Committee at the
time of conditional approval. Conditionally approved sponsors retain the
benefits, rights, and responsibilities of preliminary or fully approved
sponsors.
Conditional approval may be granted at any point in the approval cycle after
the initial 2 Year Preliminary Approval is completed (i.e., at any time
a reapplication is required, either after the initial two-year period or
after a five-year approval period). After one year of conditional approval,
a second conditional year can be granted if issues of concern remain. Conditional
approval may be granted only twice consecutively for any approval cycle.
Should the sponsor not adequately remedy any areas of concern after the
second conditional year of approval, further approval will be denied.
E. Deferral
The Committee may defer action on an application if more information is
needed to allow the Committee to make a decision about the organization's
capability to offer CE for psychologists in compliance with the SAS criteria.
The applicant will receive a request for more information by a specified
deadline prior to the next regularly scheduled Committee meeting.
The purpose of a deferral is to allow the Committee to request clarification
on procedures that were in place at the time of the application. New procedures
adopted subsequent to a deferral will not be considered during the Committee's
review of the response to deferral. If the requested information is not
forthcoming by the next meeting of the Committee, the application will be
considered inactive. Any request for approval at a later time will require
a completely new application. Only applications submitted by new applicants
may be deferred.
F. Denial
Applicants who do not provide adequate evidence of meeting the SAS criteria
will not be approved. The reasons for denial will be specified in a written
report to the applicant. A decision to deny can be handed down (a) at initial
application review; (b) at application review after preliminary approval;
(c) at application review after first conditional approval; (d) at application
review after second conditional approval; and (e) at review after any five-year
full approval. Applicants denied approval may reapply in one-year's time
or request reconsideration or formal appeal of the adverse decision (see
Procedures for Reconsideration and/or Formal Appeal, below).
PROCEDURES FOR RECONSIDERATION AND/OR FORMAL
APPEAL
OF ADVERSE DECISIONS
The following decisions made by the Committee are
considered adverse decisions for which the sponsor/applicant may request
reconsideration or formally appeal:
1. Denial
2. Probation
3. Termination of approval
On notification of any of the above decisions, approved sponsors may either
ask for reconsideration of the decision or they may formally appeal the
decision. Although reconsideration is generally the first recourse by sponsors
receiving adverse decisions because there is no cost involved to the applicant,
it is important to note that this step can be bypassed if the sponsor wishes
to lodge a formal appeal immediately.
When making a decision between reconsideration and appeal, the sponsor should
consider that costs incurred as a result of the appeal hearing will be borne
in part by the applicant. If reconsideration is requested and the Committee
upholds its adverse decision, the sponsor may then formally appeal the decision
reached on reconsideration. Following are the instructions for requesting
reconsideration and making a formal appeal.
A. Reconsideration
If an applicant wishes the Committee to reconsider an adverse decision,
a written request must be received by the APA Sponsor Approval System within
30 days of receipt of notification of the decision. The applicant will have
the opportunity to clarify any issue raised in the notification letter.
There is no charge or fee for reconsideration.
B. Formal Appeal
Applicants wishing to formally appeal an adverse decision
must notify the APA Sponsor Approval System in writing within 30 days of
receipt of notification of the decision. Costs incurred as a result of the
appeal hearing will be borne in part by the applicant.
The document Procedures for Reconsideration and Appeal of Adverse Decisions
is included as an appendix to this Manual, and is also mailed with each
notification of an adverse decision.
TERMS OF APPROVAL
A. Responsibilities of the Approved Sponsor to APA
| 1. |
APA-approved sponsors must conform to
the APA CE sponsor approval criteria. |
Approved sponsors agree to conduct CE activities in
conformance with the SAS criteria set forth in Section 2 of this document.
Sponsors in violation of the criteria will be subject to probation or termination
of approval.
| 2. |
Sponsors must pay scheduled fees (see
Appendix 3 for amounts and schedule
of payment): |
a.
b.
c. |
Application review fee: nonrefundable,
due with any application requiring Committee review.
Recognition fee: one time only as long as approval is continuous;
due on preliminary approval.
Annual fee: due for each year of approval. |
Nonpayment of fees will result in probation and,
ultimately, in termination of approval. New applications will not be reviewed
or activated until appropriate fees are paid.
| 3. |
Sponsors must submit an annual Activity
Summary Form. |
The Activity Summary Form is sent at the same time
as the annual fee invoice in years in which a renewal application is not
due. The Activity Summary Form lists all activities offered by the sponsor
in the previous year and includes promotional pieces for each corresponding
program. Sponsors who have not offered any programs are still required to
return the form.
| 4. |
Sponsors must submit Status Reports. |
APA-approved sponsors must submit Status Reports that
respond to issues raised in the review report. "Status Report Requirements"
will be mailed approximately two months prior to the Status Report submission
deadline. Status Reports are due one year after approval for two-year and
five-year approvals. Conditionally approved sponsors will not submit Status
Reports because they will be reapplying at the end of one year. Sponsors
will be notified in advance of the due date. Failure to submit Status Reports
will result in probation and, ultimately, in termination of approval.
B. Responsibilities of APA to the Approved
Sponsor
| 1. |
APA-approved sponsors may list programs
in the "CE Calendar." |
A calendar of CE activities offered by approved sponsors
is listed on the APA website. To list offerings in the "CE Calendar,"
an approved sponsor must submit a "CE Calendar Listing Form" to
the Sponsor Approval System as far in advance of the offering as possible.
2.
3. |
APA-approved sponsors are entitled
to reduced advertising rates in the APA Monitor.
APA-approved sponsors will receive a complimentary subscription to
the APA Monitor, a monthly publication for APA members. |
CHANGES IN APPROVAL
STATUS
| A. |
APA-Approved
Sponsors May Be Reassessed
|
Approved sponsors may be reassessed
under the following circumstances: |
1.
2.
3.
4. |
Failure to comply with the terms of
approval outlined in the Terms of Approval
of this manual, including the Ethical Principles of Psychologists.
Substantial changes in a sponsor's goals, activities or administration.
Indications that a sponsor's CE activities fail to meet the requirements
of the SAS criteria outlined in Section 2
of this manual.
The planning, evaluation and other procedures followed by the sponsor
are substantially inconsistent with those described in the sponsor's
application and/or the APA Ethical Principles of Psychologists.
|
Under any of these circumstances,
the sponsor may be reevaluated and a decision as to continuation of
approval will be made. Reassessment may result in probation or termination
of approval. |
| B. |
APA-Approved Sponsors
May Request Nonactive Status
|
When no CE activities are planned
for a period of one year, fully approved sponsors may request nonactive
status for that year. The request must be made in writing prior to
the time that nonactive status will begin, and will not be granted
retroactively.
Terms of nonactive status are as follows: |
1.
2.
3.
4.
5.
6. |
The annual fee billed during
the inactive year will be one half of the amount required for active
status.
The name of the organization will remain in the APA master listing
of APA-approved sponsors.
Nonactive sponsors may not |
a.
b.
c. |
use the statement of APA approval;
list any programs in the CE Calendar;
obtain reduced advertising rates in the APA Monitor.
|
If the sponsor wishes
to regain active status at any time prior to the end of one year,
the balance of the full annual fee for active status must be paid
before action may be taken.
Nonactive status will not extend the period of approval.
Sponsors granted nonactive status for a particular year may offer
full credit for activities that began when the sponsor was active
and conclude in the inactive year. Sponsors must clearly indicate
these circumstances when preparing Status Reports for the inactive
year. |
| C. |
APA-Approved Sponsors May be Placed on Probation
|
If an approved sponsor's activities
do not meet the criteria as outlined in Section 2 of this manual,
or if a sponsor fails to comply with the Terms of Approval as outlined
in this manual, the sponsor may be placed on probation. The reasons
for and length of the probationary period will be outlined in writing
to the sponsor. Although retaining approval status, the sponsor's
activities will be closely monitored by the Committee during this
period.
At the end of the period of probation, the sponsor must provide documentation
of compliance with the issues raised in the notification-of-probation
letter. If such documentation is not provided, approval will be terminated.
If approval is terminated, the sponsor must submit a new application
in order to regain approval status. Probation is considered an adverse
decision and may be reconsidered and/or formally appealed.
|
| D. |
APA-Approved Sponsors May Not Withdraw Their Approval
if a Complaint Against Them is Pending
|
| APA has an established grievance procedure
that includes informing approved sponsors when a complaint is brought
against them by another organization or individual. Once the sponsor
has been informed of the complaint, it cannot withdraw from the Sponsor
Approval System until the complaint has been resolved. |
APA ETHICAL PRINCIPLES OF PSYCHOLOGISTS
The 2002 Ethics Code went into effect June 1, 2003.
View the 2002 Code
Adopted by the Council of Representatives
January 23-25, 1976 |
APPENDIX
TWO |
POLICY ON TRAINING FOR PSYCHOLOGISTS WISHING
TO CHANGE THEIR SPECIALTY
Inasmuch as it is to the advantage of psychology
and society to provide for a change of specialty or the development of dual
specialties so as to encourage unique contributions that might be made by
psychologists with broadly diversified backgrounds, Council adopts the following
as official policy of APA.
- We strongly urge Psychology Departments currently engaged in doctoral
training to offer training for individuals, already holding the doctoral
degree in psychology, who wish to change their specialty. Such programs
should be individualized, since background and career objectives vary
greatly. It is desirable that financial assistance be made available
to students in such programs.
- Programs engaging in such training should declare so publicly and
include a statement to that effect as a formal part of their program
description and/or their application for accreditation.
- Psychologists seeking to change their specialty should take training
in a program of the highest quality, and, where appropriate, exemplified
by the doctoral training programs and internships accredited by the
APA.
- With respect to subject matter and professional skills, psychologists
taking such training must meet all requirements of doctoral training
in the new psychological specialty, being given due credit for relevant
course work or requirements they have previously satisfied.
- It must be stressed, however, that merely taking an internship or
acquiring experience in a practicum setting is not, for example, considered
adequate preparation for becoming a clinical, counseling, or school
psychologist when prior training had not been in the relevant area.
- Upon fulfillment of all formal requirements of such training program,
the student should be awarded a certificate indicating the successful
completion of preparation in the particular specialty, thus according
them due recognition for their additional education and experience.
- This policy statement shall be incorporated in the guidelines of the
Committee on Accreditation so that appropriate sanctions can be brought
to bear on university and internship training programs which violate
paragraph 4, and/or 5 of the above.**
**The following was approved by the Council of Representatives of APA at
its January 22-24, 1982 meeting.
"The American Psychological Association holds that respecialization
education and training for psychologists possessing the doctoral degree
should be conducted by those academic units in regionally accredited universities
and professional schools currently offering doctoral training in the relevant
specialty, and in conjunction with regularly organized internship agencies
where appropriate. Respecialization for purposes of offering services in
clinical, counseling, or school psychology should be linked to relevant
APA approved programs.
AMERICAN PSYCHOLOGICAL ASSOCIATION
CONTINUING EDUCATION SPONSOR APPROVAL SYSTEM
FEE SCHEDULE
| Type of Fee |
A PA Division, State or
Regional Association |
Others |
|
| Application Fee |
$180 |
$300 |
| |
-Due with application |
|
|
| Recognition Fee |
$360 |
$600 |
| |
-Due with invoice after
initial approval, one time,
only for as long as approval
is maintained. |
|
|
| Annual Fee |
$240 |
$400 |
| |
-Due with invoice at the
beginning of each approval
year, including the first
year. |
|
|
| Innactive Status Annual Fee |
$120 |
$200 |
| |
-Inactive status must
be requested in writing. |
|
|
CE SPONSOR APPROVAL SYSTEM
Procedures for Reconsideration and Appeal
of Adverse Decisions
The Committee for the Approval of Continuing Education Sponsors shall review
completed applications at its regularly scheduled meetings and shall evaluate
the applications in reference to the APA Approval of Sponsors of Continuing
Education for Psychologists: Criteria and Procedures Manual, November
1996. The Committee's decisions must be by majority vote.
The decision by the Committee for the Approval of CE Sponsors to deny, withdraw
approval, or to place or to continue a sponsor on probation, hereinafter
referred to as an "adverse decision," shall be transmitted to
the sponsor or sponsor applicant in a notification letter.
Reconsideration or review on appeal may be sought only from an adverse decision
as defined herein. The letter of notification shall include the basis for
the decision and inform the sponsor or sponsor applicant of the right to
request reconsideration by the Committee or a hearing before an ad hoc Appeals
Panel appointed by the Board of Directors of the American Psychological
Association. A written request for reconsideration or appeal timely filed
shall automatically stay the adverse decision until the reconsideration
or hearing by the Appeals Panel is completed. The approval status of the
institution during the process of reconsideration or appeal shall remain
as it was prior to the adverse decision.
I. RECONSIDERATION
- If reconsideration is desired, a written request for reconsideration
shall be submitted to the Chair of the Committee for the Approval of
CE Sponsors within thirty (30) days following the date of receipt of
the notification letter to the institution and shall specify reasons
for requesting reconsideration.
- Reconsideration shall be based only on information submitted by the
sponsor or sponsor applicant in response to issues raised by the initial
decision, and the information before the Committee at the time of its
initial decision. If, however, the sponsor or sponsor applicant seeks
to submit new information relevant to the approval decision (e.g., changes
in the program since the initial decision), a new application must be
filed, and a petition for reconsideration will not be entertained.
- The reconsideration will occur at the next regularly scheduled meeting
of the Committee or, in cases of denial or termination of currently
approved sponsors by conference call of the Committee, and shall be
at no additional cost to the sponsor or sponsor applicant.
- If the reconsideration is conducted by conference call, all materials
in support of the reconsideration must be submitted within thirty (30)
days following the date of receipt of the notification letter. The conference
call will be conducted as soon as possible after receipt of supporting
materials.
- If, following the reconsideration, the Sponsor Approval Committee
sustains its initial action or renders a further adverse decision, the
sponsor applicant may request a hearing before an Appeals Panel.
II. APPEALS HEARING
- A sponsor or sponsor applicant who has received an adverse decision
may request a hearing before an Appeals Panel. A written request for
appeal should be received by the President of the American Psychological
Association within thirty (30) days of the date of receipt of the notification
of either (a) the Committee's initial adverse decision, or (b) the Committee's
adverse decision upon reconsideration. If no timely request is received,
then the decision of the Committee is final. The request for a hearing
shall include a statement of reasons for appealing the decision of the
Committee. Any issue not stated in the request for hearing will not
be considered on appeal. Appeals may be based only on the grounds that
the Sponsor Approval Committee's decision was (l) arbitrary, capricious
or otherwise not in accordance with the criteria and procedures of the
Committee or (2) not supported by substantial evidence.
- Composition of Appeals Panel
The Appeals Panel shall be composed of three (3) members, to be selected
according to the following procedures:
From a list of individuals qualified to serve as members
of an appeals panel, a Board of Directors Subcommittee (President, Past-President,
and Secretary) will appoint three (3) individuals, of whom two must
be APA members, to serve on the Appeals Panel for a particular appeal.
The names of the three (3) appointees who agree to serve on the Appeals
Panel shall be communicated to the appellant. If the appellant shows
good cause why a named principal is unacceptable, an alternative will
be selected who is acceptable to both parties. No member of the panel
hearing a particular appeal shall have had any prior connection with
either the appellant or with the approval process for that particular
appellant.
- Hearings, requested in conformity with these procedures, will take
place within ninety (90) days or at a time mutually satisfactory to
APA and the appellant. The appellant shall be notified of the time and
place of the hearing.
- Any additional information supplied by the appellant must be for the
purposes of clarification only and cannot describe new components of
the institution or changes made subsequent to the initial review/action.
Any such new information will not be considered by the Appeals Panel.
- Written briefs may be submitted to the Appeals Panel up to two weeks
prior to the hearing. Briefs must contain appropriate citations to the
record, as defined in Paragraph II (H), infra, and to Approval of Sponsors
of Continuing Education for Psychologists: Criteria and Procedures Manual
(November, 1996).
- In addition to the three Appeals Panel members and the Panel's counsel,
those present at the hearing will include: the representative and counsel
of the appellant (if desired), a representative of the Committee, and
the APA staff.
- At the hearing, the appellant's representative, including counsel,
shall first present arguments regarding issues raised on appeal. The
Committee's representative shall be allowed to ask questions and make
the Committee's presentation. After questions of the Committee's representative
by the appellant, both sides shall be allowed closing statements. The
Appeals Panel shall be free to interrupt with questions of its own during
any part of the hearing. The Appeals Panel may depart from this format
should considerations of fairness so require.
- The basis for the findings of the Appeals Panel shall be: (a) the
record on review, which shall consist of materials before the Committee
(initially and on reconsideration); records of a site visit, if one
was made; material obtained by the Committee from local professional
associations or specialty experts, and responsive documents filed by
the sponsor during the course of the approval process; and (b) briefs
of both parties.
- The Appeals Panel shall have the power by majority vote to grant full
or conditional approval, to place or to continue a sponsor on probation,
to deny approval, to order a site visit, or to order further proceedings
before the Committee. The decision of the Appeals Panel shall be final.
- The report of the Panel, including the decision and the reasons for
it, will be prepared within 30 days and will be addressed to the President
of APA. Copies will be forwarded to the sponsor contact person and the
Executive Officer of the Association.
- The appellant shall pay the expenses incurred in sending its representative
(and counsel) to the hearing. In addition, the appellant shall pay one
half of the expenses incurred by APA in the conduct of the hearing.
Those expenses shall consist of travel, hotel accommodations, and meals
for the three Appeals Panel members, counsel for the Appeals Panel,
and the representative from the Committee.
At the time a request for an appeal is made, the expenses to be incurred
by APA will be estimated and the sponsor or sponsor applicant shall forward
a check for the estimated payment of its share of the expenses as a deposit
to be used against such expenses. Any balance due shall be paid by the appellant
within thirty (30) days of the date of the appeals hearing. Any surplus
of the deposit shall be returned to the appellant by APA within thirty (30)
days of the appeals hearing. APA shall furnish the appellant with an itemized
statement of all expenses.
III. CONFIDENTIALITY OF RECORDS
The work of the Committee in approving sponsors of continuing education
for psychologists, including, but not limited to, all deliberations, decisions,
proceedings, records, and other materials utilized in the approval process
shall be kept confidential except:
- disclosure shall be made in those instances in which the Association
is legally advised or required to disclose such information;
- information on a specific sponsor may be made available to other
accrediting agencies by which the sponsor has been approved or whose
approval it is seeking;
- approved minutes of the Committee's decisions regarding sponsors shall
be available to the Board of Educational Affairs, the Executive Director
of the Education Directorate, the Continuing Education Program Office
staff, the Deputy Chief Executive Officer, and the Chief Executive Officer;
- in the case of an appeal, the Committee's decision as recorded in
the minutes shall be available to the Board of Directors.
- the APA's legal counsel may be requested to review application materials.
|