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.