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