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.
