23 comments
With information available at our finger tips, this test appears to be written in an informal version of English language. It is confusing and at times unclear. Also, with so many unscored items, it leads to fatigue of the test taker. Programs should be made to teach the test and not the field since learners cannot retain everything that has been written in the field of psychology. There are too many in need of psychiatric services that can be tailored to areas of competency for those in the process of licensure.
I support this!! It’s time for a change!!!
Let us transform the lives of psychologists across our nation by challenging the status quo of testing scores and licensure requirements. As a community, we have the strength and collective responsibility to demand change. By supporting the petitioner's request and amending 18VAC125-20-80, we can break down the barriers that hinder the progress of mental health professionals. It is time to recognize the worth and value of these dedicated individuals and provide them with the opportunity to flourish without the burden of outdated and biased tests. Together, we can make a difference and create a brighter future for all!
I urge the Board to revise 18VAC125-20-80 for the reasons stated in the petition. A minimum score of 400 will not only improve the quality of life for test-takers but also reduce excessive testing expenses. The EPPP has long been a stressor for mental health professionals, causing them to spend extensive time and money on exam preparation, resulting in time away from their families. The current passing score may not accurately reflect a professional's ability to assess and treat clients. I support granting practitioners who may face biases the opportunity to practice and contribute positively to the community. I urge you to take action and address this issue, ensuring psychologists are treated fairly and with dignity. We, the undersigned, believe that lowering the score would be a significant step towards resolving this problem and improving the lives of those affected. We ask that you consider the petition and take immediate action to effect positive change. Thank you!
I support this entirely. One day our children may grow up and face this exact obstacle, let us pave the way for our future.
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.
The Virginia Academy of Clinical Psychologists (VACP) is the only statewide professional membership representing and advocating on behalf of Doctors of Clinical Psychology in the Commonwealth of Virginia. Our organization represents over 550 licensed professionals. VACP’s purpose is "the advancement of Clinical Psychology as a science, as a profession, and as a means of promoting human welfare by developing and encouraging high standards of ethics and training; by providing the opportunity for the exchange of experience and research through discussions, presentation and publications; and by educating the public in the purposes and goals of the art and science of the practice of clinical psychology for the promotion of the public welfare."
As an organization VACP has some grave concerns about the petition for rule making that was filed by Tisha Juggins. Our main concern is how these changes might impact clinical psychologist training and qualifications and ultimately public safety. According to ASPPB, a passing EPPP score is 500 (70%), and most states adhere to this standard. Some states, like Michigan, use 450 score for master’s level practitioners, but a score of 400 (60%) is lower than any state's current passing score. ASPPB data indicates that 80% of individuals from accredited schools pass the EPPP. For an additional perspective we would also note that most medical schools and boards require a 70% pass rate.
Changing the passing score could also affect our adherence to the PsyPact agreement, potentially impact our participation/reimbursement with insurance companies, and increase the hurdles for in-network providers
Regarding the timeframe, two years seems sufficient to pass the exam. Many individuals take the EPPP during graduate school or up to two years after signing up. The Virginia Board of Psychology has been accommodating to granting appropriate extensions for those with life circumstances that require it. Removing the time limit might not help those dedicated to taking the EPPP and could potentially lead to calls for removing the test altogether. It could also impact our ability to gain reimbursement for training psychologists if they are perceived as being in training indefinitely. Eliminating the window to take the exam might also affect reporting data on schools nefariously using students as an income source and allow e-commerce entities to exploit individuals who cannot pass the exam.
In conclusion, VACP opposed the petition for rulemaking as presented in it’s entirety.
Kindly
VACP Board of Directors
I am commenting in support of the revision of 18VAC125-20-80 for the reasons identified in the petition. Lowering the passing score will have a considerable impact on the lives of those pursuing a license to practice psychology, particularly for those who have found the test to be a significant barrier to career advancement.
I would also like to directly address one of the “grave concerns” raised by the Virgina Academy of Clinical Psychologists (VACP), for I believe that sentiments such as these often stand in the way of progress in favor of maintaining the status quos. Regarding EPPP pass rates, one of the largest issues being raised by those in support of this petition is racial inequity; specifically, Black and Hispanic/Latinx applicants having lower pass rates than their white counterparts. While VACP touts the ASPPB statistic of an 80% pass rate for individuals who attended accredited programs, they fail to acknowledge the concerns about racial disparity in pass rates raised by the available literature and the noticeable absence of exploration into this matter by ASPPB. When concerns about pass rates were raised in the field of social work (after the ASWB revealed this data), there was an immediate call for change that has resulted in exploration and the successful development of alternative pathways to licensure (https://www.naswil.org/post/illinois-breaks-barriers-in-mental-health-workforce-achieving-remarkable-growth-in-licensed-social). Another important point to make is there is currently no evidence that a score of 500 indicates that an individual who has passed the exam is more qualified for independent practice than someone who has not received this score. If there were reliable proof that someone with a score of 400 was more of a threat to the public than someone who scored 500, then those who oppose this call for change may have more of an argument. It is concerning that there are those who believe that people who achieved (and the use of “achieved” is intentional) scores between 450-499, which is roughly 12 missed questions at most for those who score 450, are incapable of independent practice. The absurdity of it all becomes more obvious when one considers how much of the information that applicants are being tested on is irrelevant to clinical practice. If someone who practices industrial and organization (I/O) psychology does not have to hold a license to do their job, why must someone trained in clinical psychology know the ins and outs of I/O to be licensed? Given these observations, I believe it would be irresponsible to disregard this petition due to the absence of evidence to support the necessity of 500 being the passing score (which I would like to gently remind the board is only a recommended score).
VACP also expressed worry about the potential impact that lowering the score would have on adherence to the PsyPact agreement and participation/reimbursement with insurance companies. Potential being the operative word here, I think it is important to explore the pros and cons so as to make an informed decision regarding this matter. These concerns should be a call for more consideration, not an indicator that this petition should not move forward.
In the midst of a mental health crisis, now is not the time to close ranks around an archaic gatekeeping practice that has fostered a culture of silence, shame, and neglect of those who have not met this arbitrary standard. Years of training and met competency benchmarks should not be neglected because of a single score. The board, and organizations like VACP, should be prioritizing finding solutions to the ongoing shortage of mental health professionals, especially since Virginia is included in the Health Professional Shortage Areas identified by the Health Resource and Services Administration. Taking this petition seriously would demonstrate a commitment to this, and in the long term change the lives of so many who have only ever wanted to serve their community. Thank you for taking the time to consider this comment.
I support this petition.
It is important that we not lose sight of the purpose of this petition.
Advocating for policy changes that address systemic barriers to licensure, such as reducing the passing score on the EPPP, or modifying licensure requirements to be more inclusive, is essential to creating a more equitable path to professional practice for all individuals. Presumably, this is the goal of the petition.
Noteworthy, The VACP was founded in 1975 "when patients' rights to receive mental health services directly from clinical psychologists were threatened by insurance requirements that clinical psychologists be personally supervised by physicians." The VACP sued the insurance company so that psychologists in Virginia could practice independently (VACP, 2023).
History continues, and in 2024, this petition will ensure that all psychologists can practice independently, thereby limiting the barriers to passing an exam that, according to research, does not fully assess clinical competency and skills. I do not think those in favor of the petition are seeking monetary compensation, nor are they gloating about suing any organizations. I am asking the board to consider the ethics code and introduce a fair scoring system that reflects inclusivity, and one that does not harm its professionals.
The Examination for Professional Practice in Psychology (EPPP) is a critical hurdle for aspiring psychologists in the United States and Canada. It serves as a standardized assessment of the knowledge and skills deemed necessary for the independent practice of psychology. However, this has been challenged and concerns have been raised about the disparities in pass rates, cultural biases within the exam content, and systemic barriers to licensure.
Research indicates that some groups often score lower on the EPPP, leading to lower pass rates; and consequently, fewer opportunities for licensure and professional advancement. These disparities can be attributed to test bias, economic barriers, content relevance, and cultural bias. Reducing the passing score creates access to the psychology field for those who have given years of their lives to earn their PsyD or PhD. Reducing the score will increase representation for many people in the field of psychology, which is so desperately needed, given the limited amount of representation for some groups of people.
I am asking the board to consider these issues and address these concerns. Addressing these challenges requires a concerted effort to reform the EPPP scoring, and dismantle the systemic barriers that hinder one's access to licensure and professional advancement. By taking these steps, the field of psychology can move toward greater inclusivity, equity, and representation, ultimately improving mental health outcomes for all communities.
Respectfully,
A concerned professional
I support this petition, and I am asking the board to consider lowering the score to remove barriers to licensure. This is an issue that can be fixed.
Thank you
I strongly endorse the well-reasoned and researched comment submitted by the VACP. I see no reason to effectively do away with the existing assessment mechanism, particularly in a field that was defined by measuring individual differences.
I'm an aspiring counselor, and I'm completing my master's degree. In my opinion, I'd appreciate it if the exam didn't have a timeline. The timeline can be an issue, because if someone is unable to take the test for medical, or any other reason, it prevents great and qualified counselor/PsyD graduates from accomplishing their goal of finishing their degree in full. Also, the score of 400, is more than reasonable, to pass the exam.
I fully support the petition to lower the passing score on the national examination in regulatory language. The current score requirement can be a barrier for many competent and skilled professionals who are eager to enter the field of psychology and contribute to the well-being of individuals and communities.
By lowering the passing score, we can create a more accessible path to licensure without compromising the quality of care provided by future psychologists. The skills and knowledge required for practice can be honed through practical experience, continuing education, and supervised training—ensuring that practitioners are well-prepared and supported as they advance in their careers.
This change also addresses the evolving needs of the mental health profession and ensures that diverse and capable individuals have the opportunity to serve the public, particularly at a time when access to mental health care is more critical than ever.
I strongly urge the board to consider this petition as a positive step towards fostering inclusivity and accessibility in our field.
there’s a lot of research supporting the challenges of EPPP and African Americans specifically but it’s challenging all around. Completely unfair and unrelated to the actual practice of psychology