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Virginia Regulatory Town Hall
Department of Health Professions
Board of Psychology
Regulations Governing the Practice of Psychology [18 VAC 125 ‑ 20]
Action Result of Periodic Review
Stage Proposed
Comment Period Ends 1/24/2020


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1/23/20  12:26 pm
Commenter: Capella University

Proposed 18 VAC 125-20
January 23, 2020
Virginia Board of Psychology
Jaime Hoyle, Executive Director
9960 Mayland Drive, Suite 300
Richmond, VA 23233
RE: Proposed 18 VAC 125-20
Dear Director Hoyle and Members of the Board:
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.
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.
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.
Richard Senese, PhD
Capella University
1 Virginia Register of Regulations, Vol. 36 Iss. 7 on the internet at
2 Virginia Department of Health (VDH), Shortage Designations and Maps, on the Internet at:
3 U.S. Department of Labor's Bureau of Labor Statistics, Occupational Employment Statistics (OES) and Employment Projections, on the Internet at:
4 American Psychological Association, Search for APA accredited programs, on the Internet at:
CommentID: 78910

1/24/20  4:10 pm
Commenter: Dr. Shana Garrett, Dean of the Walden University School of Psychology

Walden University Comments Re: Regulations Governing the Practice of Psychology [18 VAC 125 ? 20]
Virginia Board of Psychology
9960 Maryland Drive, Suite 300
Henrico, Virginia 23233-1463
Attn: Jaime Hoyle, Executive Director
January 24, 2020
RE: Regulations Governing the Practice of Psychology [18 VAC 125 ? 20]
We ask that this letter be submitted for your meeting record on this day.
Walden University (“Walden”) submits this letter in response to the proposed regulatory changes outlined in 18VAC 125-20, particularly the language that would remove the option for graduates of non-APA accredited psychology programs the opportunity to obtain full psychologist licensure in the state of Virginia. We respectfully request the board reconsider the proposed changes and present further information below in support of our position.
Recognizing an Equivalency Pathway Helps Address Virginia’s Mental Health Professional Shortage
The proposed changes to Virginia’s psychology licensure rules will limit or prevent the current pathways that qualify distance education Psychology students to become licensed in the Commonwealth of Virginia. Restricting licensure to only graduates from APA-accredited programs will only exacerbate the behavioral health workforce shortage and deny countless non-traditional students the opportunity to pursue their career and professional development goals.
According to the U.S. Department of Health and Human Services, Virginia faces a pervasive shortage of behavioral and mental health professionals. Eighty areas in Virginia are classified as Federally Designated Health Professional Shortage Areas in the latest U.S. quarterly summary.1 Guided by its social change mission,2 Walden is committed to training scholar-practitioners to serve the Virginia’s current mental health needs. In fact, nearly a third of Walden’s PhD in Psychology students overlap with the mental health HPSAs, while many of the others live proximate to these areas of need. Unfortunately, distance education programs in psychology sometimes confront an uneven playing field as requirements of continuous physical presence can be defined too narrowly for students enrolled in hybrid programs. This comes even as many specialized accreditors now embrace this modality, including Council for Accreditation of Counseling & Related Educational Programs (“CACREP”) for mental health counseling and Counsel on Social Work Education (“CSWE”) for social work.
Presently, online graduates of licensure-leading programs, including Ph.D. in Psychology, Clinical Specialization; PhD in Psychology, Counseling Psychology; PhD in Clinical Psychology (hereafter referred to as the “Programs”), are eligible to apply for licensure as licensed psychologists in Virginia through an “equivalency” pathway. Currently, there are 48 students in Walden’s PhD in Psychology programs in Virginia. The Virginia Board of Psychology has since 2011 conferred its approval of Walden graduates, along with graduates of hybrid programs at other universities. To date, this Board has approved 13 graduates of Walden’s PhD in Psychology programs for licensure, most recently in winter of 2019. Walden’s School of Psychology faculty include a number of Virginia residents, including Jack Kitaeff, who also serves on the faculty at an on-the-ground Virginia public research university.
Overall, Walden graduates are eligible for licensure as psychologists in 17 states that recognize psychologists equally from substantially online programs. These states, which comprise more than 50 percent of the total U.S. population, recognize the benefits of maintaining licensure standards that assist in addressing the acute shortage of mental health professionals particularly in rural areas. States with this structure, ranging from Arizona, California, Texas, Illinois, and Ohio, all offer a pathway to licensure for competent graduates of doctoral clinical or counseling psychology programs from regionally accredited universities to be eligible for the psychologist license in their states.
Additional Information on Walden University and its Psychology Programs
For the past 50 years, Walden has been a university with curricula that emphasizes a scholar-practitioner philosophy: Applying theoretical and empirical knowledge to professional practice with the goal of improving organizations, educational institutions, and entire communities. Walden University is regionally accredited by the Higher Learning Commission. Walden’s mission and commitment are to positive social change. Accordingly, we celebrate the diversity of our student body. Ethnic minority students comprise more than fifty-two percent (52%) of Walden’s student body, and women account for upwards of seventy-six percent (76%) of all Walden students. Walden is number one among 373 accredited U.S. institutions for awarding doctorates to African Americans, according to the Survey of Earned Doctorates, National Science Foundation (2016).
Walden’s Programs provide an educational pathway for students whose life circumstances prevent them from relocating and attending a traditional brick and mortar institution. Ninety percent (90%) of our students work full-time, part-time or are self-employed. Eighty percent (80%) of our students are 30 years and older. It would be challenging for many of these students to pursue their educational and career goals without programs like those of Walden. Furthermore, many of the mental healthcare providers that we graduate would never have had the opportunity to enter the field and be of service in their many diverse communities.
The one-year, four-consecutive-quarters of Blended Academic Year in Residence (“BAYR”) establishes residency for our students and offers faculty critical opportunities to observe and provide feedback to students regarding professional development and behavior. A majority of coursework occurs in-person and in-residence during the intensive nine days each quarter in Minneapolis, MN. Professional concerns that might not emerge in a few hours in class over each week can be much more apparent in condensed intensives where students must demonstrate professional behavior over an extended period of hours and days.
The faculty believe in the value of person-to-person, face-to-face interaction with students in the Programs. During BAYR, students attend academic classes, practice clinical skills and competencies, participate in professional development sessions, and meet with the psychology faculty for mentoring.
In addition to the four consecutive quarters of BAYR courses, Walden graduate students are required to attend four Ph.D. research residencies, each of which involve four concentrated days of programming over a 5-day period. One or more psychology faculty residency administrators are also present for these residencies. This provides an additional eight to 16 intensive days of in-person, face-to-face interaction beyond the time described above.
Following the completion of BAYR, students in the program are required to complete extensive supervised field training experience. Supervision takes place on-site, in-person, and face-to-face with a licensed doctoral-level licensed Psychologist. Walden requires two quarters of practicum, consisting of a minimum of 750 clock hours. We also require a full year of internship, consisting of a minimum of 2,000 clock hours, with at least 900 clock hours of direct client contact that must be documented. Thus, two and one-half to three years (or 50 to 60 percent) of the 5-year program involves direct, person-to-person, regular contact with core faculty, contributing faculty, and field training supervisors.
Our students’ achievements across the country clearly demonstrate that our graduates are competent in their professional endeavors. Our graduates contribute professionally to the behavioral health community and serve as much needed providers to often under-served populations in urban and rural communities.
Walden’s position in regard to 18 VAC 125-20
If the Board were to adopt the current proposed language, applicants from non-APA accredited program, including those from Walden’s hybrid program, would become ineligible for licensure in Virginia. This move would effectively close the door on your own residents who are seeking to become future psychologists in Virginia through the pathway currently available to them through an equivalency evaluation. Adoption of this regulation will close the path to licensure for 48 students currently enrolled in Walden’s Programs.
Virginia residents who have graduated from Walden University and have been licensed by
this Board now practice successfully in the Commonwealth. These licensed Psychologists serve the needs of residents at a time in which the pervasive behavioral healthcare provider shortage presents continuing peril to public safety and mental health.
Our goal is to continue as a partner with the State to help address this healthcare shortage in Virginia, as we do in many other states across the country. We respectfully ask the Board to retain a licensure equivalency pathway in its consideration of the pending rule change.
Thank you for your time and consideration.
Dr. Shana Garrett, PhD, CRS, LPC, NCC
Dean of the School of Psychology
College of the Social and Behavioral Sciences
Walden University
1 U.S. Department of Health & Human Services map:
2 Walden 2020: A Vision for Social Change 2017 Report:
CommentID: 78927