Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Psychology
 
chapter
Regulations Governing the Practice of Psychology [18 VAC 125 ‑ 20]
Previous Comment     Next Comment     Back to List of Comments
8/12/24  9:34 pm
Commenter: CPT Contessa A. Tracy, PsyD

Support EPPP Reform: Stop ASPPB from "Profiting from our resilience." - RP
 

My passion for military service and mental health care began in 2008 when I first enlisted in the Army National Guard. Following my commission as a Military Intelligence Officer in the Army Reserves, I served in various leadership roles while earning my doctorate in Clinical Psychology. My vision was clear, and I set out to become an Army Clinical Psychologist.

 

I fulfilled all academic requirements for my American Psychological Association (APA) accredited degree program by maintaining at least a B average GPA, completing over 2,000 hours of supervised practicum experience, passing a 2-part clinical competency exam, and successfully defending my clinical dissertation with original research. As of June 2020, I was reassessed onto Active Duty, received a second commission in the Army, and was accepted to one of the Army’s premier Clinical Psychology Internship and Residency programs at Brooke Army Medical Center in San Antonio, TX.

 

I have faced significant challenges passing the EPPP to remain in my position as an Army Clinical Psychologist. I have been unable to achieve the minimum required score of 500 to be an independently licensed provider, despite completing three different EPPP test preparation programs and over 100 hours of additional paid tutoring. After 8 attempts, my highest score achieved thus far is a score of 472. As a result of having not passed the EPPP, I have faced hostile work environments, discrimination, isolation, and maltreatment. I have been removed from the Army Clinical Psychology profession and must fulfill my service obligation in another career field.  These challenges have had adverse impacts on my physical and mental wellbeing. There are many more BIPOC individuals who share similar experiences.

 

Per the EPPP candidate handbook, “any Candidate who scores below 500 on either part of the EPPP will automatically receive performance feedback at the test center as part of the score report. The feedback will be reported by domain in the form of a bar graph." ASPPB refuses to provide repeat test takers with any additional feedback other than the bar graph. When ASPPB chooses to ignore the data for repeat test takers, this allows the organization to continue the highly profitable practice of mandating a multi-million-dollar generating exam with no oversight on the negative outcomes for their repeat test takers.

 

Relatedly, the selected panel of members who draft questions and the types of questions approved for the final versions of the exam raise concern. In February 2022, when I first sat for the exam, I remember a question asking who may be more likely to abuse their elderly parents when they are in a caretaker role. The answer choices listed individuals separated by race and gender. While ASPPB states that “50 questions are pretest items, which are not scored and do not count toward the final score”, it raises concern that such a question could potentially make the difference between a candidate receiving a score of 497 or 500. 

 

Given the serious concerns about the EPPP, I urge the consideration for a thorough independent investigation into the EPPP part 1 and 2 and ASPPB’s professional practices. I ask that the VA State Board consider if the cutoff score to pass the EPPP should be decreased (i.e., to 400). Furthermore, I ask that all State Board authorities take a strong stance against EPPP Part 2-Skills and follow the Texas State Board of Examiners of Psychologists’ lead in urging ASPPB to amend its bylaws so that Part 2 can be put to a vote for member jurisdictions. 

 

Thank you.

CommentID: 227342