I am writing on behalf of the Argosy University, Washington DC campus doctoral program in clinical psychology regarding the Notice of Intended Regulatory Action (NOIRA) of 9/23/09, concerning acceptance of pre-internship supervised professional experience to count toward the residency requirement. As the Director of Clinical Training for the Argosy University, Washington DC Campus APA-accredited Clinical Psychology Program, I am strongly interested in the issues surrounding the use of pre-doctoral practicum hours for licensure. This letter is a follow-up to my earlier letter of April 6, 2009.

By way of background, our doctoral students currently serve at practicum sites in Virginia, Maryland, and the District of Columbia, as well as occasionally in Pennsylvania, New Jersey, New York, and other states. Upon graduation, our graduates seek to become licensed in Virginia, the District of Columbia, Maryland (often pursuing licensure in multiple jurisdictions), as well as other states. Because both students’ practica and their post-doctoral plans cross jurisdictions so frequently, we at Argosy see it as essential that documentation of practicum experiences be consistent across jurisdictions to the extent possible.

We recognize the Board’s effort to accept pre-internship supervised professional experience in lieu of all or part of the post-doctoral residency currently required. We understand the Board’s goal of eliminating any impediments to licensure for clinical psychologists. Unfortunately, the Board’s draft standards for supervised experience are not consistent either with the ASPPB, or APPIC documentation sytems. Given these discrepancies, it will be exceedingly difficult for students and doctoral programs to document practicum experiences which meet the requirements – unless several, in most cases minor, modifications to the details of the requirements are made.

Accordingly, we offer the following suggested modifications to the draft regulations:

1.    Use the terms “Supervised professional experience” to refer to the overall practicum experience, comprising “Patient/client contact,” “Service-related activities,” and “Supervision.”

2.    “Patient/client contact” should include the following activities: Treatment/intervention (direct service), Interviewing (direct service), Consultation with the client or agent of the client (direct service), and Assessment (administration and feedback) (direct service).

3.    In regards to “Patient/client contact”: Please consider dropping the “face-to-face” requirement for direct services. The reality is that videoconference, telephone, and internet-based service delivery are becoming more and more common. Appropriately monitored and supervised at the site level, these practices are emerging best practices (e.g. in the military and in rural areas). If the supervisor approves of their use, the hours spent in these activities should be allowed.

4.    “Service-related activities” should include the following activities: Scoring of assessment; Report or treatment note writing; Case conferences/case presentations; Consultation with other professionals; Video/audio review of recorded sessions; Chart review; and Case management. These categories are legitimate, important service-related activities, and are recognized by APPIC for inclusion in practicum experiences.

5.    “Service-related activities” should also include the following: Didactic training held at the practicum site; Practicum-related case consultation provided in the trainee’s academic department; and Practicum-related labs or classroom instruction. All of these activities are arguably service-related, but none of them meet the legal and ethical requirements of supervision, so they should not be termed supervision.

6.    Eliminate any reference to “Supporting activities.” This sounds too much like APPIC’s “Support Activities” but does not mean the same thing.

In addition to the above concerns, there is a concern regarding supervision. I am curious as to the meaning of the statement (p. 4): “The Board may also add a requrement for the supervisor to hold a current unrestricted license in order to be registered with the Board to provide supervison….” This appears to imply that the Board envisions supervision of practicum trainees as only being conducted by a licensed psychologist, analagous to the current Virginia provision regarding postdoctoral training that “Supervision shall be provided by a psychologist licensed to practice in the licensure category in which the resident is seeking licensure” (18VAC125-20-65 Supervised experience). Is the Board’s intent to credit only 8 hours of supervised professional experience for each hour of supervision by a licensed psychologist? This would appear to discredit the valuable, and frequent, practice of psychology trainees receiving supervision from other categories of supervisors. Both ASPPB and APPIC envision that supervision may be provided by licensed allied mental health providers, or by psychology interns or postdocs who are under the supervision of a licensed psychologist. It would be preferable if the Board adopted this more inclusive view of practicum supervision.

In conclusion, we at Argosy encourage the Board, as we have encouraged APPIC, ASPPB, and licensing boards in other jurisdictions, to adopt uniform, sensible standards for practicum training which will facilitate, not impede, trainees’ progress towards licensure. We welcome further discussion of these ideas, and eventual adoption of revised regulations.

Yours truly,

David B. Sacks, PsyD

Director of Clinical Training

dsacks@argosy.edu

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