Comment on the petition from Dr. John Wieriman I would not know how to select a counselor. I have heard that often clinical social workers are better at counseling than psychologists or psychiatrists. There appears to be many approaches to counseling. There should be some means of evaluating the outcomes of various treatment plans. I think the suggestion that family, friends, and co-workers evaluate a person’s improvement or lack thereof as worthwhile. There are ratings for just about every service. There should be ratings for counseling. I receive emails and purchase receipts asking me for feedback on stores and services. Most businesses encourage feedback by offering the possibility of winning a prize if feedback is provided. I should think Virginia should find feedback valuable in improving mental health services.

Feedback is fundamental to every position or job role. It is only with feedback that people are able to development and grow in areas where there are identified gaps/deficiencies.  I think we should have a formal feedback or evaluation route for medical professionals that lay people can draw upon when considering the selection of a health care provider.  As such, I support this suggestion.

Comments are on behalf of the Va Academy of Clinical Psychologists which strongly opposes this petition.  The petition appears to be addressing professional counselors rather than clinical psychologists, the latter which are licensed and clinically trained to diagnosis and treat both moderate and severe mental disorders and disease.  The petition's suggestions are often contrary to standard of care, in that approaches to diagnosis and treatment are often on a case by case basis, including consideration of symptoms presented by the patient, medical history, etc.  Recognizing the vast number of diagnoses and of varied severity, it is contrary to quality of care standards to demand all patients be forced to undergo standardized tests (if such occur for that condition) and bear the cost of such when unnecessary.  As to reports, Virginia is perhaps different from other states in that copies of health care records are available to the patient (with some exceptions set in Code.) Likewise, a government mandate on providing often unnecessary testing or reports will either increase the cost to patients or reduce the time available for patient care.  In short, the petitioner's request should be denied in that it fails to recognize the services and higher level of care rendered by clinical psychologists as compared to counselors, and that clinical psychologists are evaluting, diagnosing and treating serious mental illness and disease.  The petitioner's suggestrions are not appropriate for diagnosis and treatment of these types of illness.  The suggestion is contrary to sound, recognized standard of care, has the real potential to jeopardize a doctor-patient therapeutic relationship, and will result in unjustified increases in costs for care.  For these reasons, the Virginia Academy of Clinical Psycyhologists strongly opposes the petition and urges its denial.

 

I have recently returned from a meeting of my state association leadership where this petition was discussed.  While quality care and patient satisfaction are vital, the general consensus was a lack of support for this petition.

I am opposed to this rule-making petition on several grounds; First,many of the issues of expressed concern are already covered by record-keeping requirements involving intake and discharge summaries; Second, formal testing is an added expense for families who are already struggling to afford copayments, coinsurance, and deductible payments; Third, such evaluations as proposed must be cleared by insurance carriers prior to being initiated, often slowing the providers' ability to deliver services due to the authorization process necessary for approval. 

I oppose this petition for a variety of reasons. Firstly, it is targeting "counselors" not psychologists so is an inappropriate petition for the Board of Psychology. Secondly, the idea of initiating "pre and post testing" on all clients is impractical. Clients seek psychological services for a myriad of reasons, some of which are ameanable to testing and some not. Thirdly, the cost of conducting pre and post testing is not defined by the  petition and could place an undue burden on either clients and/or the treating psychologist.

I have recently returned from a meeting of my state association leadership where this petition was discussed.  While quality care and patient satisfaction are vital, the general consensus was a lack of support for this petition. Psychologists routinely assess outcomes using pre-post assessment but valid and reliable measures must be used.

As a clinical psychologist, I am opposed to this. Individual psychologists should retain autonomy in their practice. 

I appreciate the invitation to comment on this petition.  I respect the goal of providing quality patient care, but I am NOT IN FAVOR of this mechanism.  Logistically, it places an undue burden on practitioners for an effort that is unreimbursed and requires considerable staff and practitioner managment/accountability.  As a concept, the outcome of such a subjective self-report is far from evidence-based.  In fact, in the complex arena in which we work (patients across the spectrum of complexity of mental health/behavioral health/physical health concerns), subjective patient report is often not the best measure of outcome.  Indeed, one learned perspective is that, if our patients leave the office happy, we may not have done the work justice (that is, sometimes the hard truths are hard to hear, and sometimes careful confrontation is what spurs people to movement--even if reactive and just to spite us!).

Our field is increasingly embracing evidence-based practice, and it is within that model of training, continuing education, and treatment that we bring quality to bear in our work within our profession of Clinical Psychology.

Respectfully submitted,

Cathleen A. Rea, Ph.D.

On the presumption that the proposed bill would mark as "quality care" only those assessments which resulted in a a measurably "positive" improvement on some dimension, what would we learn from data collected on: chronic and relapsing conditions; elder or end-of-life supportive care; emergency or critical interventions to self-destructive and suicidal patients who succumb in spite of efforts;  declining courses of illness which are attenuated or slowed down by treatments; and so on?  Medical necessity for care is not defined by retroactively by "outcome." 

Clinical psychologists, according to standards of care, conduct assessments during intake and at periodic intervals throughout treatment.  Formal testing will create an added, and unnecessary, burden on consumers, and can increase their out-of-pocket expense for quality mental health care.  I do not support this petition.  

As a clinical psychologist with a strong commitment to serving the public and protection of public interest, I appreciate the opportunity to comment on this proposed change in the regulations for psychologists. There is no standard of practice for subjecting patients to pre- and post-treatment assessment, nor is one needed. The current practice of diagnostic interviewing is a well established, empirically supported, and validated means of assessing for the need of treatment and the presenting problems of patients entering care. Formal assessment is usually reserved for more complex and complicated cases where the additional cost is warranted by the additional information obtained. Subjecting patients to needless and costly assessment is an undue burden, a barrier to care, and would do nothing to improve the quality of care already available from duly licensed clinical psychologists.

 

I am opposed to the suggestion in this petition. It does not seem to recognize that Clinical Psychologists are licensed to practice independently.  Certainly I support quality assurance for Clinical Psychologists as for any  other professions, but several more proven methods already exist, such as acquiring and maintaining licensure, a responsibilty of the clinician to follow ethical and evidence based practices, and grievance procedures available to the consumer.  Pre-post measures are not always the most meaningful. As others have commented, any such standard measure would not take into account the diversity of clinical issues and patients' needs.  As a Clinical Psychologist I welcome patients' feedback about the therapy relationship and my direction of psychotherapy throughout the treatment process.   When treatment goals have been reached, termination review sessions offer another opportunity for individuals to assess their progress and satisfaction with treatment.  Finally, I agree with others' comments on the unnecessary financial burden and interruption of the therapeutic process with such a requirement. 

I am a licensed clinical psychologist who uses standardized testing almost every day in my practice at a large hospital based clinic so I value this practice very much. I think standardized testing is extremely helpful in formulating diagnostic impressions for complex cases but I do not believe it is required for every single patient and certainly not for therapy patients. Standardized testing is required to help make some diagnoses such as Specific Learning Disability and Intellectual Disability for example. Interestingly, one of the tests I use to diagnose Autistic Spectrum Disorder, the Autism Diagnostic Observation Schedule, Second Edition, is considered the gold standard for diagnosing Autistic Spectrum Disorder and it doesn't even use standardized scores. It uses an algorithm and cut off scores. It is an extremely useful test and is very well respected. However, it is just a tool that adds to the essential clinical interview and information gathering about symptoms from multiple sources such as schools. 

People see licensed clinical psychologists for a myriad of presenting problems that often don't require standardized testing. In therapy,  psychologists typically conduct assessments of patients'  psychological functioning through diagnostic interviewing which is one of our most powerful tools. We work with patients to develop treatment goals which are clearly defined and easily measured without the need for standardized testing. I also agree with several of the other comments made that insurance companies often require preathorization for testing and I think there would be many denials if testing was requested for every single therapy patient. It is not the current standard of practice for psychologists to conduct standardized testing for every single patient so I request that this petition be denied. 

Respectfully,

Gregory L. Robinson, PhD.

 

 

 

I respect the opinions offered here and agree that quality care should be a top priority. However, implementation of the suggestions noted in this petition would likely serve as a barrier to treatment and recovery.  Therefore, I do not support this petition. 

As an LCP, I find standardized testing useful and important but not always necessary. To make standardized testing a must for every case seems to be an abuse of resources. I believe standardized testing should be determined on a case by case basis and not mandated. 

Respectfully, Lori Dudley, PhD, LCP

 

 

As many individuals responding to this proposed change have noted, while testing is useful, its not routinely indicated in many situations.  When standardized testing is warranted, is is almost always administered in a process that includes a battery of tests and one or more hours of clinical interviews.  I cannot imagine a administering any one standardized test as a pre and post measure that could have utility across the range of concerns that bring individuals to see a psychologist.  There is strong evidence suppporting the utility of careful clinical interviewing and testing when needed to clarify certain diagnostic concerns.  I see this proposal as overly simplistic,  expensive, and disruptive to the work of clinical psychologists.

There is no standard of practice for subjecting patients to pre- and post-treatment assessment, nor is one needed. The current practice of diagnostic interviewing is a well established, empirically supported, and validated means of assessing for the need of treatment and the presenting problems of patients entering care. Formal assessment is usually reserved for more complex and complicated cases where the additional cost is warranted by the additional information obtained. Subjecting patients to needless and costly assessment is an undue burden, a barrier to care, and would do nothing to improve the quality of care already available from duly licensed clinical psychologists.

The petitioner fails to define "standardized pre and post testing". I have no idea what the petitioner is referring to, as testing is at the discretion of the licensee, and based on the needs/clinical questions that arise in the inital assessment process, or as needed thereafter. In fact, in many cases it may actually contraindicated to conduct testing and to create a law/rule to ensure this is being done could place undue burden and costs onto the public. I strongly oppose.  

While assessment of clinical symptoms and feedback on treatment response are important components of effective therapy, it is my opinion that this petition would not be an effective way to ensure that they are implemented.  Two specific concerns are:

1-There is no single measure that would effectively assess symptoms for all patients and diagnoses.

2-Patients are entitled to refuse any aspect of treatment, including completing assessment measures.  This could potentially create a conflict between the patients' wishes and a mandate to assess pre-and post-treatment. 

For these and other reasons, I believe this petition should be denied.

I am a practcing Clinical Psychologist and trainer in the Commonwealth for more than 40 years. I train clinicians and work in University settings and independent practice. This petition lacks any clear thought or eye toward implementation. Evalution of outcomes is certainly important, but Clinical Psychologsts are involved in much more than counseling (e.g. psychological assessment, psychotherapy, health consultations, diagnosis, etc.) and evaluating their success is complicated and involves the need for many special safeguards of confidentiality and practical definitions of success. Positive outcomes are not always measurable in the short term and may involved the interaction of many dfferent interventions and professionals. Simply asking people often how they are doing does not take into account response biases, cultural and ethnic differences, psychological processes and life experiences. Accountability for practitioners is important but what is proposed here is too simplistic and not well informed by scientific method or even good practice. Please reject this petition! Most informed and well trained psycholgists would not support this petition."


 

I am in strong opposition to this proposal.  The decision to test or not to test should be a decision made by the professional on a case by case basis.

Thank you,

cjsahni  

As others have said very well, I am opposed to the proposal.