As you finalize changes to the educational requirements for licensure, we write with gratitude for incorporating a “grandparent” provision, to provide important clarifying information about our program, and with a continued concern about requiring programmatic accreditation. Further, we would also like to propose an alternative for recognizing graduates of non-APA or CPA accredited blended programs.
Background
Capella University
Capella University, established in 1993, has built its reputation on delivering high quality, online graduate-focused programs to working adults. Approximately 70% of Capella’s students are currently 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. Capella also offers bachelor’s level programs in areas such as business, information technology, nursing, psychology and public safety.
Innovation has always been at the core of Capella’s history and contribution to higher education. Expertise in competency-based education enabled Capella in 2013 to become the first institution approved by the Department of Education to award Title IV aid to eligible bachelors and masters level degrees based on the direct assessment of learning, rather than the traditional model built around the time-based credit hour. Capella’s FlexPath direct assessment programs also offer the potential to significantly reduce the cost of a degree and accelerate the time required for degree completion.
Capella University currently offers 53 undergraduate and graduate degree programs with 128 specializations and more than 2,050 courses. Capella enrolls approximately 38,000 students, representing all 50 states and 54 other countries and territories. Capella is accredited by the Higher Learning Commission and is based in Minneapolis, Minnesota.
Comments on Proposed Rules
Grandparent Provision
We appreciate the delayed implementation timeframe the Board has adopted, allowing current students in non-APA or CPA accredited programs the opportunity to finish their program and still qualify for licensure. This measure best protects Virginians, and those intending to practice in Virginia, who have already invested significant time and money into a graduate program.
Capella University’s Program
We were surprised to read, in reference to Capella’s program, in the November 2019 Department of Planning and Budget's Economic Impact Analysis that “According to the Department of Health Professions (DHP), it is unlikely for these programs to become accredited because one of the issues that the APA has with accrediting online programs is their lack of internships.”1
We want to be sure the Board and DHP understands that Capella University’s program requires a 2,000 hour face-to-face internship as well as 1,000 hours of practicum experience supervised by a licensed psychologist. Our program does not lack supervised clinical experience, formal face-to-face interactions with faculty and students, or other components that traditional on-campus programs provide.
As we indicated in prior written comments on this proposed rule change, Capella University offers a PsyD, Clinical Psychology degree program that is designed to prepare graduates for licensure as a psychologist. 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, observation, and evaluation by faculty that begins with the in-person pre-admission interview and progresses through the in-person, face-to-face clinical skills labs with faculty and student cohort.
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.
Programmatic Accreditation Requirement
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. 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.
Virginia, like much of the U.S., is experiencing a shortage and uneven distribution of licensed clinically-trained mental health professionals, including psychologists.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 of more than 22 percent through 2024.3
With only 10 institutions offering APA accredited doctoral programs in Virginia, (some of which who have small cohorts with only 10-20 students accepted per year) and 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 which provide flexibility will not be able to complete programs at a traditional campus.
As in our prior written comments, we propose an alternative for recognizing graduates of non-APA or CPA accredited blended programs such as Capella’s: program reviews.
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 APA 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 reviews as an alternative to APA or CPA accreditation.
Conclusion
If program reviews for non-APA or CPA accredited programs are not adopted and blended doctoral programs like ours 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.
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.
