VACP's argument relies heavily on the notion that lowering the EPPP score would compromise clinical psychologist qualifications and public safety. However, the EPPP is not a definitive measure of clinical competency. The exam primarily tests theoretical knowledge, not practical skills, and its structure has been criticized for being a poor predictor of clinical success or therapeutic effectiveness. Many graduate programs already implement rigorous clinical training, which includes hundreds of hours of supervised practice and regular evaluations by licensed psychologists. These programs ensure that candidates are well-prepared for real-world clinical work, regardless of whether they score a 400 or 500 on a knowledge-based test.

Moreover, there is no empirical evidence suggesting that practitioners who score between 400 and 499 are less competent or a greater risk to public safety than those who score above 500. A passing score of 400 still represents a strong understanding of the foundational knowledge required for licensure, and allowing a slightly lower threshold would open the door for otherwise highly qualified individuals to enter the field without compromising public safety.

The EPPP has been widely criticized for disproportionately disadvantaging certain populations, particularly candidates from minority backgrounds. Research indicates that candidates from underrepresented groups tend to have lower pass rates on the EPPP. This disparity likely stems from a variety of factors, including economic inequality, access to study resources, and cultural bias in test content. A higher passing threshold (500) exacerbates these disparities, creating unnecessary barriers for diverse candidates who might otherwise be highly competent practitioners.

Lowering the passing score to 400 would help reduce the disproportionate impact on these groups, allowing for a more diverse pool of clinical psychologists that reflects the communities they serve. This change aligns with the broader goal of promoting human welfare, a central tenet of the VACP’s mission. Expanding the diversity of psychologists would improve access to culturally competent care, which is crucial for addressing mental health disparities across different populations.

The current two-year limit to pass the EPPP imposes undue pressure on candidates, many of whom face life circumstances that delay their ability to study effectively or take the test in a timely manner. While VACP argues that the Virginia Board of Psychology is "accommodating" to those who request extensions, requiring candidates to petition for extensions adds unnecessary bureaucratic hurdles. The process often leads to heightened anxiety for candidates, especially those dealing with personal or professional challenges such as caregiving responsibilities, financial hardship, or health issues.

Extending or removing the time limit would offer greater flexibility for candidates without compromising the profession's standards. Many other professional licensing exams, such as those in law (e.g., the bar exam) or medicine (e.g., USMLE), do not impose strict deadlines, recognizing that different candidates face different life circumstances. Removing the two-year limit would create a more equitable system that respects individual needs and life circumstances while still upholding rigorous testing standards.

VACP raises concerns that lowering the passing score or removing the two-year limit could affect Virginia’s adherence to the PsyPact agreement, which allows for telepsychology across state lines. However, PsyPact is designed to facilitate access to psychological services across jurisdictions, not to enforce a single standard for passing exams. PsyPact’s primary function is to ensure that practitioners are licensed in their home state, and licensure decisions are left to individual states. As such, lowering the passing score in Virginia would not necessarily impact PsyPact, as long as the state continues to enforce other requirements for licensure, such as supervised clinical experience and adherence to ethical standards.

Similarly, insurance companies primarily base reimbursement decisions on licensure status and adherence to state regulations, rather than on specific EPPP scores. Whether a candidate passes the EPPP with a score of 400 or 500 is unlikely to influence insurance company decisions about in-network providers, as long as the psychologist holds a valid state license and maintains compliance with continuing education requirements and professional ethics.

VACP’s concern that removing the time limit could lead to "calls for removing the test altogether" or perceptions of psychologists "being in training indefinitely" overlooks the reality that psychologists are committed to their profession and their patients. Clinical psychology is a demanding field that requires years of education, supervised training, and professional dedication. Removing arbitrary barriers, such as the two-year time limit, does not reflect a lack of commitment; rather, it acknowledges that professional growth is a lifelong process, and candidates may need more time to meet certain requirements due to personal or external circumstances.

In fact, allowing more time to prepare for and pass the EPPP may reduce test anxiety and encourage a deeper, more reflective engagement with the material. Candidates who have the flexibility to study at their own pace may ultimately perform better in practice, as they have had time to integrate their knowledge with real-world experience. The goal should be to produce effective, compassionate clinicians, not to impose rigid time constraints that may hinder the development of future psychologists.