APPIC
Association of Psychology Postdoctoral and Internship Centers
October 24, 2005
To the APA Education Directorate:
APPIC Central Office
10 “G” Street, NE Suite 440
Washington, DC 20002
(202) 589-0600
Fax (202) 589-0603
www.appic.org
On behalf of the Association of Psychology Postdoctoral and Internship Centers
(APPIC), I am writing to comment on the report from the Board of Directors
Work Group on the Recommendations of the Commission on Education and
Training Leading to Licensure in Psychology.
APPIC Board of Directors
Chair
Steve McCutcheon, Ph.D.
VA Puget Sound ,Seattle
Stephen.McCutcheon@med.va.gov
Vice Chair
Joyce Illfelder-Kaye, Ph.D.
Pennsylvania State University
Jxi1@psu.edu
Treasurer
Jeff Baker, Ph.D., ABPP
University of Texas Medical Branch at
Galveston
jbaker@utmb.edu
Secretary
Karen M. Taylor, Ph.D.
The Ohio State University
taylor.45@osu.edu
Jeanette Hsu, Ph.D.
VA Palo Alto Health Care System
Jeanette.hsu@med.va.gov
John Robinson, Ed.D., MPH, ABPP
Howard University Hospital
Jdrobinson@aol.com
Sharon Berry, Ph.D.
Children’s Hospitals and Clinics
Sharon.berry@childrenshc.org
Past Chair
Greg Keilin, Ph.D.
University of Texas at Austin
gkeilin@mail.utexas.edu
Public Member
Mona Koppel Mitnick, Esq.
monamitnick@starpower.net
Executive Director
Connie M. Hercey, MPA
Herco1@aol.com
As the association representing nearly 700 pre-doctoral internship and
postdoctoral programs throughout the United States and Canada, the APPIC
Board supports any thoughtful examination of the sequence of professional
training in psychology. Along with you, we are committed to encouraging the
development of reasonable and sensible standards that allow full access to the
profession without unreasonable barriers, while still providing safety for the
public by maintaining minimum standards for professional competency.
However, we wish to express our very serious concern about the
recommendation of the Commission and ensuing Work Group to eliminate the
postdoctoral year of supervised professional experience as a requirement for
licensure in the absence of a more complete evaluation and assessment of the
entire sequence of training.
As you may know, APPIC was a member of the APA Commission on Education
and Training, and in fact, originally voted to support the Commission’s report.
However, subsequent to the Commission action, the APPIC Board of Directors
carefully re-examined a number of issues regarding the implementation of the
Commission recommendations. The Board undertook this review due to
concerns expressed by both our internship and postdoctoral membership. As a
result of this review, the APPIC Board developed serious concerns about the
Commission’s recommendation to abandon the postdoctoral requirement, and in
fact, wrote a letter to APA withdrawing its support for its vote at the
Commission. APPIC continues to oppose this Commission recommendation.
Moreover, we were startled to read in the Work Group report the additional
proposed changes to Commission Recommendations A and B. These changes
move beyond the language of the original Commission and threaten the very
existence of the internship year:
“The American Psychological Association recommends that for admission to
licensure applicants demonstrate that they have completed two years of
supervised experience, which can be completed prior or subsequent to the
granting of the doctoral degree”. (Work Group report, Section I)
Unlike the original Commission recommendation, this language has been crafted to remove any mention of
internship training, and could easily be interpreted to allow students to complete the experiential
requirements for licensure solely on the basis of practicum. Even if this was not the original intention behind
this change in language, APPIC is deeply concerned that, if adopted, it opens the door to elimination of the
internship year as well as the postdoctoral year. We oppose this particular recommendation in the strongest
possible terms.
This letter expresses a series of concerns regarding specific elements of the Commission and Work Group
reports. We had hoped to be included in the Work Group meetings because we believed that as an
organization of internship and postdoctoral training directors, we could provide data that would help to
inform this discussion. We are grateful to have this opportunity for comment.
The inflation of practicum hours and the need to review the entire sequence of training
As the national association that represents postdoctoral training programs, APPIC continues to believe in the
importance of and need for high quality postdoctoral training as an element of the sequence of training in
psychology. Delegates to the Boulder, Vail and Gainesville conferences have consistently asserted the
importance of postdoctoral training. Any decision to retreat from these conference recommendations should
be based on data rather than polemics. We firmly believe that the developmental experience of postdoctoral
education and training can not be viewed as interchangeable with hours gained in practicum experiences.
What are the arguments that have been put forward to support elimination of the requirement for a
postdoctoral year, and do they stand up to the test of evidence? It has been asserted repeatedly by proponents
that students currently accrue significantly more hours of clinical experience prior to the postdoctoral year
than was envisioned even twenty years ago, in effect shifting the location of clinical experience to earlier in
the training sequence. However, there are a number of errors in this argument. APPIC is unaware of reliable
and valid data on the amount of practicum training preceding the advent of the universal internship
application (AAPI). Moreover, as the publisher of the AAPI, we are concerned that the introduction of the
AAPI has led to a serious overestimation of the amount of practicum hours reported by training directors to
the Committee on Accreditation (the data upon which APA estimates are presumably based). Prior to the
development of the AAPI, internship sites used their own forms that asked applicants to account for
practicum hours in different ways, often focusing on hours spent in direct service to clients. With the advent
of the AAPI, applicants were asked to document supervision and support hours, in addition to direct
intervention and assessment hours. We believe that this has significantly contributed to the perception that
practicum hours have increased, more so than documenting a real change.
If this overestimation of practicum hours is an artifact of the AAPI, it is important to know something about
the support activities that are actually driving this apparent increase in hours. These support activities include,
but are not limited to, such things as chart review, treatment planning, audio/video tape review, report
writing, and attending didactics at practicum sites. In 2005, 43% of the 2100 mean total practicum hours were
derived from such activities. Only the very broadest definition of practicum would include such elements,
and there is great doubt that they should be counted toward licensure requirements (Thorn, B., Kaslow, N., &
Pate, W. (2005). Professional Psychology: Research and Practice, 36, 3, 307-317). Although important as
graduate-level educational experiences, the inclusion of these activities on the AAPI has contributed to an
illusion that true practicum hours have grown dramatically.
In addition, we believe that the pressures that students experience to document a high number of practicum
hours results in the counting of experiences that should not be included. Based on the hundreds of inquiries
we receive each fall from applicants, we have serious concerns about what activities are being included in
these hours and being verified by training directors. Anecdotally, we can all point to intern applicants who
have indeed accrued substantial practicum hours. However, this does not negate the inflation created by the
AAPI, nor the huge variability in practicum hours reported by students. In the most recent APPIC post-Match
survey, applicants reported intervention and assessment practicum hours ranging from 4 – 6019 (median =
906, mean = 1023, SD = 567). Ko and Rodolfa (2005) emphasized the need to bring together representatives
of the training councils to more accurately define a practicum hour. If the training councils do not do this and
the Work Group recommendation is adopted by APA, state licensing boards will be left to their own devices
to create such definitions. The current chaos and uncertainty in Washington State is an example that will be
repeated nationwide. In summary, as currently organized, practicum experience is widely variable, both in
quantity and quality, and the experiences gained clearly are not a substitute for training at the postdoctoral
level.
Although some graduates may be ready to practice independently upon completion of two years of predoctoral supervised experience, the percentage of graduates who are ready to practice independently at degree
is not sufficient to warrant the elimination of the postdoctoral year. This perception is widely shared among
internship Training Directors, who see at close quarters the competency level of trainees as they near
completion of their training [Rodolfa, E., Ko, S. & Peterson, L. (2004). Professional Psychology: Research
and Practice. 35, 4, 397-404.] In the absence of an established measure of competency for independent
practice, the judgment of internship training directors is the single best indicator of readiness for practice.
The results of the most recent APPIC survey should concern all who are considering this change. In that
survey, training directors were asked to respond to the question:
“Considering the psychology interns who completed your program in the last few years, what percentage of
interns do you believe possessed the competencies, skills and readiness for licensure [as an independent
practitioner] at the end of the internship year?”
Only 37% of 273 respondents reported that 80% or more of their interns were ready for licensure without a
postdoctoral year. That is, roughly 2/3 of internship training directors report that some substantial number of
their trainees are unready for independent practice at the end of the internship year. In contrast, 96% of
postdoctoral training directors (n=46) reported readiness for licensure at the end of the postdoctoral year for
more than 80% of their postdoctoral fellows. In sum, the data we have available suggests that a substantial
majority of internship training directors judge a significant number of their interns as lacking readiness for
independent practice.
The need for practicum training standards
If the requirement of the postdoctoral year is going to be eliminated, then the profession must concurrently
turn its attention to the other end of the training continuum, by improving the organization, structure and
accountability of practicum training. The current state of practicum training is devoid of national standards.
The Association of Directors of Psychology Training Clinics (ADPTC) competency guidelines provide the
beginning of national standards, but much work needs to be done to develop formal standards that all
doctoral programs in professional psychology will accept. Standards are needed to insure that practicum
training will be essentially equivalent across doctoral programs. These standards should be recognized by the
academic training councils and the Committee on Accreditation, and cited in the Accreditation Guidelines
and Principles.
With the lack of reasonable practicum standards, voting to approve the Commission recommendation to
include practicum training as an acceptable alternative to postdoctoral training would be putting the cart
before the horse. In fact, the effect of implementing the Commission recommendations will be to de facto
substitute practicum training for postdoctoral training, and possibly even predoctoral internship training.
While practicum training is a worthwhile vehicle for beginning students, it can in no way be seen as
equivalent to the advanced training that occurs at the internship and postdoctoral levels. To accept 2000
hours of practicum training in lieu of 2000 hours of advanced training is to essentially reduce the minimal
standards for professional psychology training.
The need to establish competencies in professional psychology training
The Education Directorate is very familiar with the work already completed by many to define competencies
in psychology practice. We won’t spend time in this letter to review these efforts except to acknowledge that
the passage of time, in and of itself, does not produce competency. Instead, competence is achieved through a
process of structured educational practices and carefully supervised experiences that, in fact, occur over time.
That is, competence relies upon both intentional educational interventions and the passage of time that allows
for development. While the motivation to eliminate the postdoctoral year is understandable from the
perspective of the student eager to join the workforce, it is incumbent upon the profession to first delineate
the competencies that are expected, and to determine those educational and experiential elements that
predictably lead to competence for most students. To eliminate the postdoctoral year without first agreeing
upon minimal competencies – and the means to achieve them – is premature. APPIC requests that the
question of the postdoctoral year be considered as one element in a review that includes the sequence of
training, as well as the expected competencies that result from such training.
Impact on other agendas of importance to psychology
At a time when psychology seeks to broaden its scope of practice, particularly in the area of prescription
privileges, this is the worst possible time to create an impression that educational standards are in decline.
The goal of eliminating the postdoctoral year is directly at odds with the goal of widening the scope of
practice. According to the newsletter of the Washington State Psychiatric Association, this argument already
is in readiness for the next legislative session that will consider prescription privileges in light of Washington
State’s abandonment of the postdoctoral requirement.
Moreover, at a time when ASPPB and other national organizations are working hard to establish licensure
mobility, this is a poor time for states to open their licensure laws. The APPIC Board would like to
emphasize our concern regarding the implications that this proposed change may have on psychologists'
mobility, as well as the potential for unintended consequences that may occur if third parties introduce hostile
elements to the laws when they are opened for review. We will leave this aspect for a more complete
discussion by ASPPB but wish to make note of it.
Summary and recommendations
APPIC believes that professionals best serve the public after achieving competency in the complexities of
modern health care. Both published and unpublished evidence cited here indicates that those most familiar
with psychology training at the internship level do not endorse interns’ readiness for independent practice
without additional supervised training. It would be a serious mistake to substitute the beginning experiences
of practicum training for the advanced experiences of the postdoctoral year. They are both valued and
necessary segments of the training sequence, but they are not equivalent and not interchangeable. While we
empathize with those who are impatient to see this change enacted, we also believe that APA must take the
long view and make wise decisions that take into account the entire sequence of training, such that graduate
education from beginning to end culminates in the production of competent professionals. As a consequence,
APPIC does not endorse the Commission and Work Group proposals in their current forms. At the same
time, APPIC does not ask that the Commission recommendations be set aside or that the postdoctoral year be
set in stone. However, APPIC does request that APA examine the elimination of the requirement for
postdoctoral training as part of an overall review of the entire sequence of training (practicum, internship and
fellowship). This could occur in the near future at a conference convened by APA and partner organizations
involved in this sequence (including APPIC). Such a conference, perhaps modeled on the APPIC
Competencies Conference, can provide benchmarks for competencies at all levels of the training sequence
that are integrated and coordinated, so that potential elimination of the postdoctoral year can be
accommodated by corresponding changes to the practicum and internship curricula.
We appreciate your thoughtful review of these comments and recognize that we all share a concern for
improving our profession and better serving the public. We hope these comments will add to your
deliberations.
Sincerely,
Steve McCutcheon, PhD
Chair, APPIC Board of Directors