I would have be in full support for the petition for rulemaking
?However, I would like to point out the following and would hope the board of psychology would address this
?This is just a small tangent 
https://www.npr.org/templates/story/story.php?storyId=121092295
http://www.washingtonpost.com/wp-dyn/content/article/2009/11/13/AR2009111302221.html
http://scienceline.org/2010/01/getting-scientific-with-psychotherapy/
?See this opinion of:http://www.apa.org/science/about/psa/2009/11/edcol.aspx
?Also another opinion:https://www.psychologicalscience.org/observer/update-on-the-psychological-clinical-science-accreditation-system

?Most PCSAS accredition for universities  is taking place after 201_ no?
Like this: https://psychology.unc.edu/2017/01/30/clinical-psychology-program-accredited-by-pcsas/

Virginia-licensed psychologists have an annual license renewal deadline around the end of June every year
?Let us take a look at the requirements

CE Required: 14 hours per year
Online CE Allowed: 8 hours (6 hours must be interactive)
License Expiration: 6/30, annually
National Accreditation Accepted: APA
Notes: 1.5 hrs in ethics, standards of practice or laws governing the profession of psychology

The American Psychology Association doesn't accredit any wholly online programs, The APA only accredits doctoral (PHD) programs and requires students to spend two or three years on campus (clinical) and complete a full-time residency

Regarding psychology, some doctoral programs  around the U.S. do not require in-person interviews or campus visits (see online courses¹ ) so applicants must meet the other requirements after applying online....

Doctoral programs typically require 4 or 5 years of postgraduate work in order to obtain a Ph.D

For transfers up to a certain number of (credit) hours of equivalent graduate coursework can be transferred for either a psychology doctoral program or a psychology master’s program dependent on what the college/department requirements are...
The APA is typically used for in order to find equivalent course requirements


?Does PCSAS have the same rigourious standards as APA when it comes to online courses and or transfer course equivalency?



https://www.psychologytraining.va.gov/eligibility.asp

When PCSAS Accreditation was recognized by Veterans Health Administration in September 2016 I was slightly concerned 

At this time I do not support the petition for rulemaking



1.) https://www.fhsu.edu/virtualcollege/degrees/bachelors/psychology/