January 10, 2018

 

Virginia Board of Psychology

Ms. Jaime Hoyle, Executive Director

9960 Mayland Drive, Suite 300

Richmond, VA 23233

 

RE: Proposed changes to 18 VAC 125?20

 

Dear Ms. Hoyle and Members of the Board:

 

As you consider changes to the educational requirements for licensure, Capella University writes to express our concerns with adopting standards that will limit many qualified graduates’ ability to be licensed and further extend the shortage of qualified mental health professionals in Virginia. We appreciate your consideration of our comments.

 

Capella University

Capella University is accredited by the Higher Learning Commission (HLC). We have built our reputation on delivering high quality, online graduate-focused programs to working adults. Capella University currently offers 54 undergraduate and graduate degree programs with 155 specializations and more than 1,900 courses. More than 37,000 students from all 50 states currently attend Capella University. Over 70 percent of our students are enrolled in master’s or doctoral level degree programs in business, counseling, education, health care, information technology, nursing, psychology, public administration, public health, public safety and social work, among others. Close to 20% of our students serve in the military, 15% reside in rural areas and over 50% of all students are students of color.

 

Capella University’s Program

Capella University offers a PsyD, Clinical Psychology degree program that is designed to prepare graduates for psychologist licensing. Capella’s program is a blended model of professional training in psychology that includes web-based didactic coursework, along with intense face-to-face training and supervised clinical training experiences. Capella’s Year-in-Residence experience is designed to meet APA’s requirement for one year in full-time academic residency. It includes a minimum of 500 formal, face-to-face interactions with faculty and students over the course of a calendar year. Graduates of our program are licensed, practicing psychologists in many states, including Virginia.

 

Blended programs like Capella’s are designed to meet the educational needs of underserved populations, including working adults, military personnel with their frequent relocations, rural residents, and those whose family commitments may prevent relocation to attend a campus-based graduate program, who aspire to become psychologists and serve their communities.

 

Proposed Programmatic Accreditation Requirement

Capella understands the Board is considering a change to current education licensure rules that would require graduation from an American Psychological Association (APA) or Canadian Psychological Association (CPA) accredited doctoral program in order to qualify for a license starting January 1, 2019.

 

Virginia, like much of the U.S., is experiencing a shortage and uneven distribution of licensed clinically-trained mental health professionals, including psychologists.[1] Much of the state has been designated a mental health professional shortage area, with just 41 percent of mental health providers that are needed available.[2] The Bureau of Labor Statistics (BLS) predicts the need for clinical psychologists in Virginia will continue to grow with employment expected to experience significant growth – +22 percent from through 2024.[3] With only 10 institutions offering APA accredited doctoral programs in Virginia, none of which offer a blended model, closing the door on other programs will only exacerbate the shortage of qualified professionals. [4] Many rural, military affiliated and other working adult students enrolled in blended programs like ours that provide flexibility will not be able to complete programs at a traditional campus.

 

APA Guidelines and Implementing Regulations currently prohibit blended programs from qualifying for review. Specifically, Implementing Regulation C-11 D. states that “a doctoral program delivering education and training substantially or completely by distance education is not compatible with the SOA and could not be accredited.”[5] Guidance from consultants and other individuals deeply familiar with APA’s processes and requirements has determined that Capella’s program does not currently qualify for APA accreditation review. While we are hopeful that APA will allow blended programs to seek accreditation in the future, until such time, the Board’s proposal to require APA programmatic accreditation would significantly impact students in programs such as Capella’s and would adversely limit well-trained students from entering practice in Virginia.

 

Graduates of Capella’s PsyD, Clinical Psychology program have been able to demonstrate that they are prepared for the practice of clinical psychology as defined by state law and have been licensed in Virginia and many other states over the past several years. Capella strongly believes that requiring programmatic accreditation will impose unnecessary barriers to qualify for a license, exacerbating the shortage of clinical psychologists, particularly in the rural, military and underserved populations our program supports.

 

We propose two alternatives for recognizing graduates of blended programs such as Capella’s:

 

1. Allow for Program Evaluations

Capella acknowledges that evaluating individual transcripts and clinical training experience takes a significant investment of resources and time from any Board.

 

In a number of states, Capella has been able to work with licensing boards through both formal and informal program review processes to determine if our program is equivalent to an accredited program or otherwise fulfills requirements in law. Additionally, when engaging in these reviews, Capella believes it is completely appropriate and reasonable for a Board to be remunerated for reviews.

 

As our program and curriculum does not change significantly over time, these reviews are usually only revisited every few years. A similar multi-year review cycle for program equivalency, with review fees paid by the University to help offset costs, could help reduce the ongoing financial and time commitment from the Board.

 

Capella respectfully asks the Board to allow for program evaluations as it considers licensure changes.

 

1. Allow Grandfather Period to Protect Existing Virginia Students

If the Board moves forward with the requirement of APA or CPA accreditation, the effective date or grandfather period should be extended to provide currently enrolled students the ability to complete their program. Any effective date should be extended to at least January 1, 2025 to allow students currently enrolled in a non-APA or CPA accredited program the opportunity to finish their degree. Alternatively, the Board could revise requirements to indicate students from these programs must be enrolled by January 1, 2019 to be considered for licensure.

 

Capella has nearly a dozen students currently enrolled in our PsyD, Clinical Psychology program that reside in Virginia or intend to seek a license in Virginia after graduating. These students chose our program because of the flexibility our blended model provides. Based on current academic plans, some of these students will not graduate until the end of 2024. If the Board implements the proposed changes, these students will likely be compelled to transfer to another university, resulting in significant additional costs to the student and increasing the time needed to complete their degree. In some cases, students will be left with no options to finish their training and enter the profession.

 

Capella respectfully requests an extended grandfather period to allow students of blended programs to complete their degree.

 

Conclusion

Any changes to Virginia’s licensing standards needs to recognize and allow for high-quality, flexible programs such as Capella’s that offer a pathway to training that most traditional, campus-based programs cannot. Capella offers a training program that creates opportunities for aspiring psychologists who are excluded from most traditional programs through various life circumstances.

 

If blended doctoral programs are no longer accepted, we strongly believe the shortage of qualified mental health providers in Virginia will likely grow. We hope the Board will thoughtfully consider our concerns, so that we may continue offering this pathway to the psychologist profession to Virginians.

 

Respectfully,

 

Andrea Miller, PhD, LP, LSSP, HS-BCP 

Dean of Psychology

Harold Abel School of Social and Behavioral Sciences

 

Kristian Maul, JD

Principal Licensure Consultant

Capella University

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[1] Virginia Department of Health (VDH), Shortage Designations and Maps, on the Internet at: http://www.vdh.virginia.gov/health-equity/shortage-designations-and-maps/.

[2] Bureau of Health Workforce, Health Resources and Services Administration (HRSA), U.S. Department of Health & Human Services, Designated Health Professional Shortage Areas Statistics: Designated HPSA Quarterly Summary, as of December 31, 2016, on the internet at: https://ersrs.hrsa.gov/ReportServer?/HGDW_Reports/BCD_HPSA/BCD_HPSA_SCR50_Qtr_Smry_HTML&rc:Toolbar=false.

[3] U.S. Department of Labor's Bureau of Labor Statistics, Occupational Employment Statistics (OES) and Employment Projections, on the Internet at: https://www.bls.gov/oes/current/oes193031.htm.

[4] American Psychological  Association, Search for APA accredited programs, on the Internet at: http://apps.apa.org/accredsearch/?_ga=2.208328535.479727381.1515627248-584238456.1513802582

[5] American Psychological Association Commission on Accreditation, Implementing Regulations, on the Internet at: http://www.apa.org/ed/accreditation/section-c-soa.pdf