Virginia Regulatory Town Hall View Comments

Department of Health Professions

Board of Psychology

Regulations Governing the Practice of Psychology [18 VAC 125 ‑ 20]

6 comments

All comments for this forum

Back to List of Comments

12/28/07 7:33 pm

Commenter: Sam Mela

No improvements at DMHMRSAS

From Washington times December 28:

A lack of understanding of the system's complexities and pitfalls has kept lawmakers from acting on it until now, said Delegate Phillip A. Hamilton, an authority on mental health legislation. But the shootings fast-tracked the issue to the top of the agenda, he said."

"If no Virginia Tech parent or victim even contacted us or came forward, I think you're going to see some significant changes," said Mr. Hamilton, Newport News Republican.

The families are not uniform in their beliefs, however. Holly Sherman, whose daughter Leslie was killed in the shootings, understands that it may be healing for some of the families to lobby for changes to gun and mental health laws. But to her, the effort is futile.

Mrs. Sherman hopes others will focus on what she feels are common-sense measures: running public service announcements to educate parents about potentially dangerous behavior in their children, ensuring schools properly handle troubled students and holding surprise emergency drills at schools.

Someone needs to inform Ms. Sherman that the Virginia Department of Mental Health, Mental Retardations, and Substance Abuse is still completelyly ignoring people who are asking for help.

I have copies of emails in which help has been repeatedly requested from James Martinez, director of Mental Health in Virginia, but no help has been provided.

If you want to see the complete disorganized mess that mental health planning is in Virginia, look at their minutes on http://www.dmhmrsas.virginia.gov/MHPC/Minutes.htm.

Jo-Amrah McElroy has something to do with it. You can't figure out what from reading their pages.

Minutes are missing, inconsitently documented, completely in violation of Virginia law. No one cares. No mystery why there is a lack of accountability in Virginia Mental Health Services. It starts with gross disorganization at the top.

Parents of Virginia Tech victims need to understand that Jo-Amrah McElroy, James Martinez, and the rest of the crew in the Virginia Department of Mental Health have done nothing that would result in direct improvement of quality control or quality assurance at the New River Valley Communiy Services Board, which means people are no safer from attacks by people like Seung Hui Cho now than they were 8 months ago when the attack happened.

CommentID: 587

1/4/08 10:08 am

Commenter: Patricia J. Marterer, Ph.D., Central State Hospital

petition to require one continuous year of residency within psychology doctoral programs

I am a licensed clinical psychologist in the state of Virginia, and I wholeheartedly agree with the recommendation in this petition. The awarding of a doctoral degree in a healthcare profession such as psychology solely through on-line and distance education is a frightening prospect for the consumers of services from such persons. It is incumbent upon the licensing boards for each state to ensure a minimum standard for face-to-face contact/assessment of stability and skills for seekers of psychology doctoral degrees as criterion for licensure.

CommentID: 589

1/8/08 8:52 am

Commenter: Greg Wolber, Ph.D., ABPP

Residency requirement

I agree that there should be at least a one year residency requirement. Physical presence provides an opportunity for professors in doctoral programs to work face to face with students. I believe this interaction is important to student learning and for the doctoral progam to be able to adequately assess student functioning and provide feedback. Also, it allows for students to learn by first hand observation that which is modeled by mentors. A residency requirement promotes student interaction that not only provides support but also promotes learning through shared information. Given that most communication between individuals is nonverbal, physical presence seems important.

CommentID: 590

1/21/08 5:56 am

Commenter: Rebecca Stredny, Psy.D.

Clinical psychology doctoral program residency

I support a minimum standard for face-to-face contact between students and faculty in professional psychology training, as opposed to the briefer residency periods that occur in distance-learning programs. Sustained contact is essential for role modeling, socialization into the profession, and faculty assessment of students’ emotional stability and interpersonal competence. Given the nature of clinical psychology as a profession, competent and ethical practice depends on students receiving long-term observation, feedback, and interpersonal shaping from faculty mentors.

Another concern is the degree to which distance-learning programs establish oversight and quality assurance for practicum and internship experience. Such programs have hundreds of students dispersed geographically throughout the country. It seems unlikely that programs are able to establish meaningful relationships with all of these practicum sites in order to ensure quality training experiences for students, and receive reliable feedback on trainees’ acquisition of clinical skills. Likewise, APPIC statistics suggest very low internship match rates for distance education programs, and it appears that many students arrange informal, local internships. This practice raises significant questions regarding the quality of the capstone clinical training experience for such individuals. For example, they are unlikely to have an internship cohort or an organized didactic training experience, both of which are APA accreditation standards for internship.

Distance learning should not be the sole delivery method for the bulk of educational requirements for a doctoral degree in clinical psychology. This approach undermines an essential aspect of training, which is long-term, in-person mentoring in multiple contexts (clinical, research, teaching, etc.). Such mentoring requires extensive consideration and modification of one’s interpersonal style, biases, and effect on others, and should be a prerequisite for engaging in intervention in the lives of others. If we do not place enough value on this aspect of training for it to be a minimum requirement for licensure, then we begin to lessen the standards and rigor that are associated with doctoral-level training and the profession of clinical psychology.

CommentID: 598

1/22/08 11:09 am

Commenter: Ted B. Simpson, Psy.D. DMHMRSAS, Central State Hospital

Residency requirement amendment comments

I am writing in support of the amendment which would require (at least) 12 months continuous residency at the degree-granting institution as a condition for licensure as a clinical psychologist in the Commonwealth of Virginia. Though frequently found in a multidisciplinary team setting, clinical psychologists function professionally in their clinical roles as independent practitioners, largely without continuing scrutiny following the period of licensure supervision. Traditionally, the gate-keeping function that acts to assure that a doctoral candidate possesses the clinical and interpersonal skills that will provide for both public safety and general competency in service delivery has resided first with the graduate school, then with the pre-doctoral internship and finally with the pre-licensure, post-doctoral supervision by one or more licensed practitioners.

Item 8 of the membership criteria for doctoral psychology internship programs prepared by the Association of Psychology Postdoctoral and Internship Centers (APPIC), notes that, “Internship training is at post-clerkship, post-practicum, and post-externship level, and precedes the granting of the doctoral degree.” In the following clarification section it is further explained that, “INTERNS MUST HAVE COMPLETED ADEQUATE AND APPROPRIATE PREREQUISITE TRAINING PRIOR TO THE INTERNSHIP. This would include both: completion of formal academic coursework at a degree-granting program in professional psychology (clinical, counseling, school), AND CLOSELY SUPERVISED EXPERIENTIAL TRAINING IN PROFESSIONAL PSYCHOLOGY SKILLS CONDUCTED IN NON-CLASSROOM SETTINGS.” (emphasis added)

Doctoral degrees which are granted without the completion of a continuous residency requirement of at least one year lack the needed opportunity during early training to observe and shape the clinical work of the candidate. While a student may be required to complete clinical practica approved by the graduate school, no provision is made for the graduate school core staff to provide the direct supervision and observation of their student, over time and across settings. A clinical program whose sole opportunity for thorough in-person scrutiny of their students consists of several brief on-campus sessions must, perforce, rely too heavily on the evaluative accuracy and sophistication of far-flung practica staff who, in addition, often have a financial arrangement with the student and/or graduate school. This lack of systematic, in-person evaluation by core clinical training staff and an over-reliance on the due diligence of distant practica staff does not act to ensure the quality and level of supervision essential to prepare a clinician who will act in such a fashion as to further public safety while practicing at a reasonable minimum level of professional proficiency.

The inadequate supervisory relationship described above places an unwarranted burden on the final two supervisory periods which occur prior to licensure. Any adjustments which must be made to address weaknesses in the knowledge, attitudes and skills requisite to independent clinical functioning must therefore occur at a point in time after which the primary training of the candidate is expected to have occurred. I would argue that it is during the graduate training period that basic and indispensable clinical skills should be fostered through professional mentorship which includes extended observation of, and feedback to, the candidate. This resource intensive process is not appropriate, in my opinion, for the internship year because internship training positions assume a certain basic mastery of clinical skills and are generally intended to refine, not instill these skills.

On a related front, there is an increasing awareness that the requirement for two years of practice experience prior to licensure, one pre-doctoral (the internship) and one post-doctoral (pre-licensure), creates a significant hardship for new psychology doctorates who must arrange for their post-doctoral licensure supervision in the world of managed care. In that setting a completed license is essential in order to be able to bill third parties, a condition which excludes the newly-minted doctorate from many entry level positions which might otherwise provide for pre-licensure supervision. There are increasingly energetic efforts to have State Licensure Boards revise their supervisory licensure requirement to allow for two clinical practice years both of which would be completed before the doctorate is granted. This would allow for licensure to occur upon graduation or shortly thereafter.

Proponents of this change employ the rationale that, though in the early days of psychology training the pre-doctoral internship year was frequently the only clinical training provided during the graduate school experience, this is no longer the case. A recent letter sent to State Psychological Associations by the American Psychological Association of Graduate Students (APAGS) and the American Psychological Association’s Committee on Early Career Psychologists (CECP) cited a 2005 survey of internship applicants conducted by the Association of Psychology Postdoctoral and Internship Centers (APPIC) which showed that the average internship applicant had completed practica and other clinical experiences that totaled the equivalent of slightly more than a year of full-time work, during graduate school. The letter concluded, “These findings emphasize the effects of training changes over the past 24 years, and they highlight our belief that the requirement for an extra year of supervised experience for entry level practice is no longer needed.”

Perhaps change may be needed in licensure requirements in order to reflect the new realities of managed care and to take into account the expanded clinical training occurring during graduate school. If the clinical training that supposedly occurs during graduate school is used as a justification for diminishing or doing away with the post-graduation, pre-licensure supervisory period, then certainly heightened care must be taken to avoid diminishing the quality and quantity of the training received during the graduate program. Failing to require at least one year of continuous, full-time residency during graduate school would do just that at the very moment such a reduction in professional training standards can least be afforded, if the quality of the profession and safety of the public are to be assured for the future.

In summary, I believe that an mandatory residency requirement of at least one continuous year during graduate training in clinical psychology will better provide for appropriate training of the doctoral candidate and will further the dual goals of enhancing public safety and ensuring higher quality service delivery by clinical psychologists.

CommentID: 600

1/23/08 3:31 pm

Commenter: Patricia Bruner, Ph. D., Central State Hospital

residency requirement

I support this petition. As with other healthcare professions, the practice of psychology requires not only learning didactic material, but also having the interpersonal skills to use that knowledge with people whose mental illnesses or subjective distress may make them difficult. Developing the skills to work with patients requires mentoring over an extended period, not brief interactions several times during a year. Distance learning has a place, but so does mentoring, observing, and critiquing the work of psychology students over an extended period to assure that their interpersonal skills and knowledge are used effectively with patients. This is the job of the institution granting the degree. While placements where students work may provide some supervision, they have jobs that must be accomplished and time limits in which to complete them. This limits the time for supervision of actual interaction with patients and for developing skills through observation of mentors with extensive experience.

CommentID: 602