Since the new G&P became effective on January 1, 1996, no program has been accredited as a doctoral program in an "emerging substantive area". Programs that might prefer to seek accreditation in an area other than clinical, counseling, and school psychology – such as "clinical child" or "clinical health" program – can and have obtained accreditation under the more general categories such as Clinical or Counseling programs (e.g., "Clinical with an emphasis in child," or "Clinical with an emphasis in health").

Unfortunately, the language of clause (c) appears to have created considerable confusion and disagreement. While some understood "emerging substantive areas" as synonymous to "specialties," the CoA reserved the language of "specialties" to apply exclusively to the post-doctoral scope of accreditation and viewed training in existing areas of specialties as too narrow to qualify as an emerging substantive area that is new and emerging and that should be added to the scope of accreditation at the doctoral level.

Together with that, since the "emerging substantive areas" language was added to the G&P, there have been efforts by the CoA to define the phrase. After a discussion of this issue in the 1996-1997 period, the following definition was adopted in the CoA's glossary of accreditation terms and Concepts (First Edition, October, 1997):

"Emerging substantive areas" refer to those areas of professional psychology not clearly subsumed under the "traditional substantive areas" of clinical, counseling, and school psychology, or combination thereof.

… Note therefore that the term "emerging substantive areas" does not define an accreditation status, category, or designation, nor does it refer to "substantive areas of specialty practice,"…

…the term 'emerging substantive areas' either needs to be modified as post-doctoral or deleted from the G&P. In the interim, the definition in the glossary could be modified and the CoA will continue to accredit doctoral programs in clinical, counseling, school, or some combination of these three areas of professional psychology.

In October, 2000, the CoA adopted an Implementing Regulation designed to provide a clearer definition to the phrase "emerging substantive areas." The Committee reiterated that the phrase is not equivalent to "specialty" areas and that specialty programs would only be accredited at the postdoctoral level. The CoA further explained that from its perspective "emerging substantive areas should be identified, comprehensively recognized, and delineated by the professional psychology community. This recognition and delineation must be reflected in a broad endorsement from the profession; Emerging substantive areas would not be determined in the context of an individual program, or through the recognition of an area by a narrow group of professional committees, councils, or other entities." (CoA Implementing Regulation C-14, adopted October, 2000 following a period of 6-month public comments).

While CoA was wrestling with the meaning of "emerging substantive areas" and its implication for accreditation of doctoral programs, APA's Council of Representatives had acted to give APA a more direct role in the recognition of specialty areas through the creation of the Commission for the Recognition of Specialties and Proficiencies in Professional Psychology (CRSPPP). CRSPPP has now recognized eleven specialties. These include the three traditional substantive area identified by the CoA (Clinical Psychology, Counseling Psychology, School Psychology) and – on the same level of recognition – eight additional specialties (Clinical Neuropsychology, Clinical Health Psychology, Psychoanalytic Psychology, Clinical Child Psychology, Industrial-Organizational Psychology, Behavioral Psychology, Forensic Psychology, and Family Psychology).

While APA (Association Rule 90-5) provided that CRSPPP's function is to "review petitions from petitioning organizations requesting the Association's recognition of a professional specialty or proficiency," APA Council did not adopt specific provisions regarding the relationship between CRSPPP and CoA and, in particular, did not specify that CRSPPP recognition of various specialty areas would be binding on CoA for accreditation of doctoral and internship programs.

It should be noted that CoA functions differently from CRSPPP and other organizations involved in the recognition of specialties (ABPP, and the Council of Specialties). Although these organizations have been involved in the recognition of specialty areas, it is not their function to determine the appropriate scope of accreditation of doctoral programs and whether particular areas are appropriate for doctoral training. This is a central mission of CoA. Thus, given that the CoA faces a different set of dilemmas and responsibilities than the organizations currently involved in the recognition of specialties, the logic underlying the list of recognized specialties may not be directly relevant to accreditation.

Identifying additional areas that are appropriate for doctoral accreditation requires (a) a solid definition of what qualifies for such an area, and (b) a clearer consensus than currently exists in the profession. So far, both have been lacking. Six years of attempts to clarify the G&P language stated in clause (c) did not yield a solid definition of what are "emerging substantive areas." Moreover, three surveys – aimed at determining if there is consensus in the field for whether new areas should be added to the existing ones and if so, which areas should be considered for doctoral accreditation purposes – rendered neither vast enthusiasm nor consensus. Yet, the language in clause (c) is still there, a continuous invitation for confusion and dissatisfaction with accreditation guidelines.

The decision to move forward in the process of requesting public comment was made at the CoA meeting in April 2002. In seeking public comments this time, the CoA wishes to do things differently. We are embarking on a process that should lead the field to clarity, one way or another. CoA is hoping to hear arguments for either (a) reworking of the text that would delete the phrase "emerging substantive areas," or (b) reworking of the text to recognize a process for defining and determining emerging substantive areas. By the "field" we refer to a broad range of academics and practitioners whether they are or are not members of APA. In addition to the breadth of responders, CoA will make each and every comment accessible to all who wish to read it, thus the data available to the CoA will be available to the profession at large. At the end of the comment period the CoA will reach a decision based on the quality of the intellectual arguments speaking for and against either course of action and addressing the questions that CoA had put forward for comments.

The CoA believes that the decisions taken on these issues will have substantial impact on the field for years to come as they pertain to the entire landscape of the profession as we know it. We wish to listen to the field, broadly defined, and we hope that this background information underscores the seriousness in which we take the prospect of either course of action.

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