Commission on Accreditation (CoA) Update August 2012
Elizabeth Klonoff, PhD
Carl Paternite, PhD
Associate Chair, Program Review
Joyce Illfelder-Kaye, PhD
Associate Chair, Quality Assurance
CoA Summer Meeting Actions
The Commission on Accreditation (CoA) held its first program review meeting of the year on July 19-22 in Washington, D.C. The CoA reviewed 48 doctoral, internship, and postdoctoral residency programs for either initial or continued accreditation along with 13 requests for changes to programs’ accredited status (e.g., “Accredited, inactive” status for a training year). Decisions made at the meeting are available on the Office of Program Consultation and Accreditation (OPCA) website. Also, complete listings of accredited and applicant programs have been updated to reflect actions taken at the July meeting.
The Roadmap: Revising the G&P
The current Guidelines and Principles for Accreditation (G&P) were initially adopted in 1995 and implemented in 1996. Much has changed since then in higher education, education and training in professional psychology, and the health and mental health infrastructure in the United States. Although the Commission on Accreditation (CoA) has made changes to the G&P since 1996, these changes have been minor. Rather CoA has relied on writing and adopting a number of Implementing Regulations to clarify what is expected of programs seeking either initial or continuing accreditation. Given the contextual changes since 1996 noted above and the need for greater clarity, the CoA has decided to take a fresh and thorough look at its requirements for accreditation at the doctoral, internship and postdoctoral residency levels. In moving towards a new set of standards, the CoA is mindful of the requirements for recognition by the Secretary of the US Department of Education and those of the Council of Higher Education Accreditation (CHEA).
To guide the development of a new set of accreditation standards, the CoA has designed a "Roadmap" as a four phase process. This systematic process will rely on input from all of the relevant publics at each phase. The CoA is asking its many communities of interests to engage in open, needed discussions about standards for accreditation. The CoA will review all phase-specific input prior to creating the next wave of questions for a subsequent phase, so that thorough input from the field will inform the drafting of the new set of standards. Much of the input will be requested through electronic means. In addition, the CoA will be sending Commissioners to meet in person with the training councils and plans on holding at least one open meeting at APA convention in 2013. The CoA wants to remind you that it seeks and appreciates input from all interested groups and organizations, as well as individuals involved and concerned about education and training in psychology.
The public comment period continues through Oct. 10, 2012 and is available at the Accreditation Public Comment website.
This is the sixth installment of a planned series of educative topics to be featured within the periodic CoA Updates. Please let us know if there is an area related to CoA's policies, procedures, or processes that you would like to see addressed in a future edition.
Revised Implementing Regulation: D.4-7(b)
At its July 18-22 meeting, the CoA reviewed the comments received from the public in response to setting the accredited internship placement threshold for doctoral programs, based upon data collected as part of the Annual Report Online (ARO), to 50 percent. In reviewing the public comment, it became clear to the CoA that there remains a great deal of confusion about how the CoA uses these ARO thresholds and the consequences to a program of not meeting a set threshold.
First, it is important to stress that the threshold does not represent a "bright line;" that means a program's accreditation status may not be revised solely on the basis of this threshold in between periodic reviews. As part of its responsibility to ensure quality, placement of students in accredited internships is one of the criteria used by the CoA to monitor and ensure quality between periodic reviews. The majority of accreditation decisions will continue to be based on a full review of a self-study, site visit and any third party comments received from the public.
Second, although a discrete threshold has not been included in IR D.4-7 in the past, this does not represent a new policy. During its fall meetings (typically held in late October of each year), the CoA reviews the data from all accredited program and, based upon its professional judgment, the CoA may request additional information from programs reporting data that appears inconsistent or varies significantly from normative levels. The establishment of a threshold serves to further clarify the review process utilized by the CoA and to provide programs with advance notice that placement of students in accredited programs is a critical aspect of quality assurance at the doctoral level and it is the only way CoA can a priori be assured of the quality of an internship program.
Third, this threshold will not go into effect until a review of the 2013 ARO data. As with all of the ARO thresholds, this 50 percent will be reviewed in three years based upon the data in the ARO and on match issues at that time.
The CoA voted to approve the threshold for implementation in 2013 based on the results obtained from the 2011 Annual Report Online (ARO). The goal of this approval is to remind programs of the importance of working to increase the number of students in internship programs that have been reviewed for external quality while working with others in the field to increase the number of quality internships. A number of individuals and one training council expressed displeasure with the threshold and how it may adversely affect some students. Conversely, other constituencies felt that the threshold should have been set higher. Again, no program will be subject to an adverse accreditation decision based solely upon this metric on the ARO; the CoA will continue to thoroughly review doctoral programs at the time of a self-study and site visit to determine the quality of all aspects of the education leading to the doctoral degree. Since the internship is one required element of an accredited doctoral program, the CoA reviews the quality of the internship. When doctoral programs place students in accredited internship programs the CoA can be assured of the quality of those internships. If students are not placed in accredited internship programs, doctoral programs have a responsibility to demonstrate that they have substantial, systematic mechanisms in place that, in the professional judgment of the CoA, ensure quality for the internship component of the doctoral training sequence. The CoA will continue to review doctoral programs at the time of a self-study and site visit to determine how the program ensures a review of the quality of that aspect of doctoral education and training.
The CoA approved revisions to the Accreditation Operating Procedures (AOP) allowing for an accreditation "eligibility" status and a new accredited status of "accredited, on contingency" for internships and postdoctoral residencies. This would provide an alternative developmentally sequenced path to full accreditation for programs choosing not to follow the existing application process toward full accreditation. As required, the revised AOP will be forwarded to the APA Board of Educational Affairs and the APA Board of Directors. Pending approval, the revised AOP are expected to become effective early in 2013.
Conduct of Doctoral Reviews: IR C-31(a-d)
Also at the July meeting, five new implementing regulations (IRs) were approved to clarify the process used by the CoA for full review of doctoral programs (i.e., periodic review) as well as reviewing programs' continuing assurance of quality (i.e., annual review). Four specific issues reflected in decision letters from the CoA are addressed by this IR series: student selection and admission; student attrition; internship placement; and licensure. View the current IRs (PDF, 415KB) on the CoA webpage.
CHEA Recognition Review
During the summer program review meeting, the CoA hosted an observer from the Council for Higher Education Accreditation (CHEA) as part of CoA's review for re-recognition. Just as programs complete self-studies and are visited by a team of observers as part of the periodic review process, CoA undergoes similar reviews to maintain its recognition as an accrediting body. Further information on the review will be provided in the November CoA Update.
The following two proposed CoA actions are currently out for public comment. All comments will be reviewed at the CoA’s Oct. 18-21, 2012 meeting.
Roadmap: Phase I Questions
To guide the development of a new set of accreditation standards, the CoA has designed the “Roadmap” as a four phase process. This systematic process will rely on input from all of the relevant publics at each phase. The CoA is asking its many communities of interests to engage in open, needed discussions about standards for accreditation. There are four sets of questions: General; Doctoral; Internship; and Postdoctoral. Commenters are encouraged to review and provide responses to the questions for each of the training levels. Public review and comment on this first phase of questions is available through Oct. 10, 2012.
Doctoral Data IR
To clarify the information required to make an accreditation decision on a doctoral program, the CoA has proposed an IR that defines the types, level of specificity, and presentation of outcome data. This policy is similar to IR C-30 for Internship and Postdoctoral Residency Programs that became effective in 2011. Public review and comment on this proposed IR is available through Sept. 15, 2012.
To download the proposed policies, view comments received, or register to post comments, visit the Accreditation Public Comment website. Comments may be submitted as an individual or as part of a group.
Upcoming Important Dates
Reminders for Accredited Programs
Notify the CoA of Program Director Changes
Please remember to notify the OPCA in writing (by email is fine) if there is a change in the program’s training director and provide the contact information (including the email address) for that individual. If the new training director was not previously involved with the program, his/her CV should also be provided for office records. This is consistent with IR C-19 (PDF, 374KB), which requires programs to notify CoA in advance of any substantive changes. This will also ensure that the correct individual(s) receive all of CoA’s correspondence.
2012 Annual Report Online (ARO)
The 2012 Annual Report Online (ARO) opened on June 4, 2012. All accredited programs are expected to complete the ARO by Sept. of each year. Please contact the Research office at (202) 336-6016 (or by email) with questions.
Implementing Regulation (IR) C-20
The CoA updated Implementing Regulation C-20 at its March meeting. By Oct. 1, 2012 all accredited doctoral programs are to report data on education/training outcomes using the required table templates (XLS, 97KB ). Although the tables are not to be altered, programs are encouraged to include clarifying information below the corresponding table that will assist potential students and the public in making informed decisions. These tables must be updated by October 1 of each year.
Other CoA news
Site Visitor Corps
Recruitment is ongoing for new site visitors and several training workshops will be offered early in 2013 at the midwinter training council meetings. There is a serious need for “generalist” site visitors (i.e., psychologists in areas other than clinical, counseling, and school) and site visitors with VA and/or postdoctoral residency program expertise. Also, current site visitors that have not attended a workshop within the past 3 years are urged to attend a workshop to learn about recent policy and procedural changes to the review process. Please review the FAQ on Becoming an APA Site Visitor on the OPCA website or email OPCA for more information.
The systematic implementation of the revised accreditation fee schedule began on July 1, 2012. According to the APA governance documents, the CoA is a self-supporting entity within APA. Due to higher operating costs, combined with the costs involved with transitioning to an online infrastructure, the CoA increased its fees. In order to minimize the increases for internships and postdoctoral programs, the fees for doctoral programs were increased significantly, based on a two-tier approach, contingent on program size.
Accredited Programs (as of Sept. 1, 2012)
Postdoctoral Residency Programs
Traditional – Clinical
Specialty – Clinical Neuropsychology
Specialty – Clinical Health Psychology
Specialty – Clinical Child Psychology
Specialty – Rehabilitation Psychology
Specialty – Forensic Psychology