Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Psychology
 
chapter
Regulations Governing the Practice of Psychology [18 VAC 125 ‑ 20]

64 comments

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8/12/24  5:15 pm
Commenter: Anonymous

Support
 

I support this! 

CommentID: 227330
 

8/12/24  5:25 pm
Commenter: Anonymous

I support this.
 

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. 

CommentID: 227331
 

8/12/24  6:04 pm
Commenter: Anonymous

EPPP Reform
 

I support this!! It’s time for a change!!!

CommentID: 227333
 

8/12/24  8:14 pm
Commenter: Anonymous

Amendment
 

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worth and value of these dedicated individuals and provide them with the opportunity to flourish without the burden of outdated and biased tests.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!

CommentID: 227335
 

8/12/24  8:20 pm
Commenter: Anonymous

Finally!
 

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!

CommentID: 227336
 

8/12/24  8:28 pm
Commenter: Leanne

I support this !
 

I support this ! 

CommentID: 227337
 

8/12/24  8:28 pm
Commenter: Anonymous

Amendment!!
 

I support this amendment!! 

CommentID: 227338
 

8/12/24  8:40 pm
Commenter: Anonymous

Changes
 

I support this entirely. One day our children may grow up and face this exact obstacle, let us pave the way for our future. 

CommentID: 227339
 

8/12/24  9:34 pm
Commenter: Rebecca

I support this!
 

I support this!

CommentID: 227341
 

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
 

8/12/24  9:49 pm
Commenter: Anonymous

Support
 

I support this!

CommentID: 227343
 

8/13/24  7:39 am
Commenter: Anonymous

Support
 

I support! 

CommentID: 227344
 

8/13/24  9:09 am
Commenter: Anonymous

Support
 

I support this

CommentID: 227346
 

8/13/24  11:39 am
Commenter: Anonymous

I support
 

I support 

CommentID: 227348
 

8/13/24  12:15 pm
Commenter: Anon

I support this
 

I support this 

CommentID: 227349
 

8/13/24  3:50 pm
Commenter: Virginia Academy of Clinical Psychologists

Opposition to Virginia Board of Psychology Petition filed on 7/18/2024
 

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

CommentID: 227357
 

8/13/24  6:49 pm
Commenter: CB

Time for change is overdue
 

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.

CommentID: 227360
 

8/14/24  12:32 am
Commenter: A concerned professional

Collectively enhancing the field of psychology.
 

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

CommentID: 227366
 

8/16/24  3:15 pm
Commenter: Anonymous

I support this.
 

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 

CommentID: 227390
 

8/16/24  7:07 pm
Commenter: Cynthia M Favret

Disagree Strongly with Petition
 

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. 

CommentID: 227392
 

8/17/24  5:35 pm
Commenter: Jewel L. Wigglesworth

Time frame & score which should be allowed
 

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.

CommentID: 227395
 

8/19/24  11:17 am
Commenter: Anonymous

Support Support.. Remove Barriers Improve Access
 

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.

CommentID: 227401
 

8/19/24  2:40 pm
Commenter: Anonymous

Support of changing the score
 

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

CommentID: 227402
 

8/26/24  3:23 pm
Commenter: Anonymous

I support this
 

As a licensed psychologist, I support lowering this score. Unfortunately, my experience with this test has been less than positive. I passed the EPPP on my third attempt.

I received excellent training through graduate school, practicums, an internship, and a postdoc. The EPPP was discussed, and we were encouraged to take it as soon as we could and felt able to.

This test claims to protect the public and keep them safe. However, many graduate students must postpone or give up their choice to become psychologists because they need a passing score of 500, and the cost of retaking the test is high (unlicensed folk don't make a lot of money), which reduces the number of licensed clinicians available to provide services, which inadvertently hurts the public by limiting access to care.

The first time I took the test, I was highly anxious- more anxious than I had ever been in my whole life. As a result of trying to manage my anxiety, I missed answering 20 questions due to running out of time. I was three questions away from passing. I had studied for months and felt prepared, but reading the questions, I suddenly felt like I was spending five minutes just trying to understand what the question was asking me (English is my first language, but I was not born or raised in the USA).

Again, I took the test a second time and missed one question. I had again studied the material and felt at a loss to pass the test. The last time I took the test, I did not restudy the materials; I studied how the questions were written and what potential answers they were looking for. This test isn't based on psychological knowledge, ability, or morality but on how well you can take a test.

I agree that there should be a licensure process. However, research has shown that the EPPP has an adverse impact, which needs to be addressed. Additionally, the EPPP includes non-scoreable test items to create items for subsequent tests. We do not get the option to opt out of this, which may increase the chances of confirmation bias in the test taker, leading to a negative performance.

CommentID: 227443
 

8/26/24  4:06 pm
Commenter: Anonymous

I support
 

I support

CommentID: 227444
 

8/26/24  9:04 pm
Commenter: Anonymous

Support
 

I support this!!!

CommentID: 227447
 

8/28/24  11:53 am
Commenter: Kim Smith

I support this.
 

I support this petition. The Examination for Professional Practice in Psychology (EPPP) has been increasingly criticized for its perceived unfairness in evaluating the competence of aspiring psychologists. One major concern is that the exam heavily emphasizes rote memorization of theoretical knowledge rather than practical, real-world skills that are crucial for effective practice. Additionally, the EPPP's standardized format does not account for the diverse educational and cultural backgrounds of candidates, potentially disadvantaging those who may excel in clinical settings but struggle with standardized tests. The high cost associated with the exam, coupled with limited transparency in scoring, further exacerbates its inequity, making it a barrier rather than a bridge to professional licensure for many qualified individuals. It has come to my attention that other states, such as Texas and Michigan, are working to enact changes regarding the EPPP. In Michigan, the EPPP passing score was changed to 350 for Master's Limited License graduates. If Michigan can set their own range of scores, certainly Virginia can follow. I am asking the board to seriously consider this petition. 

CommentID: 227468
 

9/3/24  9:30 pm
Commenter: Anonymous

I support the change
 

I’m in support of changing the passing score. 

CommentID: 227595
 

9/3/24  9:41 pm
Commenter: Kay

I support this!
 

I support this!

CommentID: 227596
 

9/4/24  6:01 am
Commenter: Kelly O’Connor

I support this
 

The EPPP has been a barrier for many psychologists, especially those with minoritized identities. Years of graduate training and supervision and a score of 400 is sufficient for licensure imho. This will hopefully expand a workforce that is direly needed at this time. 

CommentID: 227598
 

9/4/24  9:59 am
Commenter: Dr. Garrick Beauliere

I support this!
 

This exam is SO FLAWED. It’s so much stuff to study for and you don’t even see MORE THAN half the information you studied. My brain is filled with a bunch of information I will have ZERO reasons to use/apply in my career now that  I am licensed. But hey, at least I can explain the difference between Weber, Fechner, and Steven’s law to folks (sarcasm). This test is NOT a reflection of a person's knowledge in psychology but a reflection of how toxic, prejudicial, and greedy the ASPPB is.

CommentID: 227601
 

9/4/24  10:11 am
Commenter: Brit P

Please lower the passing score
 

This exam is a terrible measure of what is needed to be a competent and thorough clinical psychologist. This exam is not a measure of knowledge needed for most aspects of the psychology profession. 100% of the work I do is with individuals with severe and persistent mental illness who are involved in the legal system (competency, sanity), and almost no questions on this exam, with the exception of maybe 2 or 3 had anything to do with the skills I need to do my everyday job. The exam should be eliminated, but in the meantime, lowering the passing score to 400 is a more than reasonable request. 

CommentID: 227602
 

9/4/24  10:33 am
Commenter: DeMia Bullock-Smith

I support this!
 

I support this!

CommentID: 227604
 

9/4/24  11:02 am
Commenter: Anonymous

I support this!
 

I support this!

CommentID: 227607
 

9/4/24  12:29 pm
Commenter: Rashida

Eppp reform
 

Please change the passing score for the eppp. Thank you! 

CommentID: 227611
 

9/4/24  4:56 pm
Commenter: Ana Z

Support
 

I support this!

CommentID: 227617
 

9/4/24  5:33 pm
Commenter: Anonymous

I support this
 

I support this. As a psychologist who is currently studying for this exam I have identified many problematic aspects of the test which I list below. It is in infuriating to be encouraged to practice from a social justice lens while also being forced to study information that is rooted in white supremacy.

Please see some of my notes below: 

There is virtually nothing about same sex parenting in regard to child rearing or development 

Queer/trans children a grossly overlooked. 

Sex/gender are used interchangeably which is incorrect usage of the terms (which I am sure I do not need to explain) 

The EPPP definition of Bilingualism referred to as someone who speaks English and another language which centers English language, another perspective that is rooted in white supremacy 

The EPPP definition of code-switching is based on a linguistics definition in which many of us know as culturally responsive practitioners there is a completely different definition in the psychology field (https://www.psychologytoday.com/us/blog/achieving-health-equity/202012/what-is-code-switching). However EPPP fails to acknowledge this. 

Lastly, I was appalled at how outdated racist theories remain in the study material and for what reason? Not only does the EPPP grossly ignore any nonwestern psychological theories and ideas, it further perpetuates anti-xyz (you name it), we are forced to learn this information to prove we are competent enough to practice. One of the disgusting theories of development was Khlobergs 1966 gender identity model which perpetuates gender stereotypes and completely ignored gender queer, fluid, trans, and questioning people. I could go on an on but as I study for this flawed test, I am reminded by unethical gatekeeping like this needs to end now. I support the petition. 

CommentID: 227619
 

9/4/24  6:45 pm
Commenter: Sabrina Scott-Lorestil

Support Lowering EPPP Passing score
 

I support lowering the passing score for the EPPP to be 400 in the state. Additionally I am in support of removing the 2 year requirement for passage within 2 years of application for licensure.

CommentID: 227620
 

9/4/24  7:27 pm
Commenter: Anonymous

Change the passing score.
 

Change the passing score. 

CommentID: 227621
 

9/4/24  9:18 pm
Commenter: Naudia Moorley

I support this!!
 

The EPPP has been an unnecessary barrier to so many highly trained and very competent clinicians. We have spent many years and significant sums of money to obtain research and clinical competence through various APA accredited programs only to be hindered from independent practice by this single exam. I am absolutely appalled that this has continued for decades despite many complaints from licensing candidates as well as peer-reviewed publications on the unfairness of this exam. 

CommentID: 227636
 

9/4/24  10:07 pm
Commenter: Cheryl Talley Virginia State University

Regulations Governing the Practice of Psychology
 

I support the proposed change

CommentID: 227649
 

9/4/24  10:43 pm
Commenter: Dr. Lex Crenshaw

I support this petition!
 

This exam is by no means a measure of competence, but indeed a measure of how well you can study to master it. Years of coursework and practicum experiences prepares you to be a well rounded clinician, not how well you can determine the likeness of waist to hip ratio for the male gaze. During this mental health epidemic, with a lack of professionals to meet the needs of the community, change is imperative within our field. It starts with this process in changing the score required for licensure which will then, emphasize equity and increased access to care.

CommentID: 227650
 

9/5/24  12:09 am
Commenter: Anonymous

EPPP reform!
 

As a clinician who has been struggling to pass this exam, shy of only a few points, along with many of my former classmates/colleagues, we need change now! Not only is the exam taxing on us financially but it also does a number on our own mental wellbeing. I’ve heard and read countless horror stories of fellow colleagues falling into depressive bouts, experience suicidal ideation, lose jobs, hope & self esteem over a failing score for an exam that is in itself a FAILURE. If we have to jump through another hoop to make a living, let’s make the hoop accessible to all rather than those with copious amounts of money to take this atrocity several times or to take much needed time off, which is not a reality for many of us. Going through countless years of education, CCEs, internship applications, dissertation and making it to graduation with 6 figures in debt, to then being met at the end of that road with an abomination of an exam that forces us to learn I/O psych & the mental gymnastics to decipher the riddle like questions of the EPPP is insulting, infuriating and wakes me up at night. Future psychologists deserve better- we need change now!

CommentID: 227652
 

9/5/24  3:59 pm
Commenter: Anonymous

Justification for 400?
 

This is an interesting proposal and I am sympathetic. It would be important to justify this particular pass point on the the 200-800 scale, though. Why 400? Why not 475 or 350 or 300? Have any calculations been done to determine what the implications would be for VA applicant pass rates? I am not sure how thoroughly the EPPP people have justified their own pass point of 500, but I worry about potential implications for PSYPACT and licensure mobility for every provider in state if this is applied without a very good and data-driven reason for the change.

 

CommentID: 227668
 

9/6/24  2:17 pm
Commenter: Anonymous

I support this petition.
 

As a licensed clinician myself, I am in favor of reform regarding the licensure process. Virginia is currently facing various challenges with access to mental health services. Individuals disproportionately impacted by the opioid crisis in underserved communities, particularly in rural areas,  are already struggling to receive the proper treatment necessary. As psychologists, we are aware of the empirical support for mental health treatment in addressing these issues, and we are not bringing forth any meaningful progress if there are systemic barriers such as the EPPP to hinder our resources. 

Not only does the exam carry a significant financial burden, we already understand that individuals of certain demographics,  including those who learned English as a second language, are more likely to be unsuccessful in passing on their first attempt. This is clearly unfair - and not only does it penalize them for being bilingual, but it prevents them from being able to serve individuals we have in Virginia who may benefit from treatment in a language other than English. 

 

It is my hope that the passing score is lowered to 400-450 to address the systemic inequities that have only served as a profit for the developer of the exam. 

Thank you 

CommentID: 227706
 

9/6/24  4:26 pm
Commenter: Anonymous

In strong support of reform, but opposed to lowering the score.
 

Lowering the score does nothing to facilitate confidence in either the field of psychology or in the practitioner. What does need to change is pretty much everything else. 

CommentID: 227707
 

9/9/24  2:47 pm
Commenter: Anonymous

I support this!
 

I am in strong support of lowering the score. 

CommentID: 227745
 

9/9/24  2:51 pm
Commenter: Anonymous

Reform
 

I support this petition in its entirety and would like everyone to consider this change. In my opinion, a passing rate of 400 is sufficient. However, even a score of 450 will help many clinicians pass the exam. Many exceptional clinicians may be stuck in that range; therefore, this change will open doors for them. These scores do not determine their value or competence, as I have had the opportunity to be treated by pre-licensure clinicians. Some of the most dedicated and passionate people are not yet licensed. Please allow these individuals to move on and practice independently so that they can continue to change the lives of others. 

Sincerely,

A Concerned Citizen 

CommentID: 227746
 

9/9/24  2:52 pm
Commenter: Anonymous

I support this!
 

I am in strong support of lowering the score and removing the 2 year time limit. 

CommentID: 227747
 

9/9/24  8:01 pm
Commenter: Anonymous

In response to VACP argument. In support of lowering score and removing time limit.
 

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.

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