PhD/PsyD Number of licensed psychologists

[Intern2223]

Do provisionally licensed psychologists count in the number licensed psychologists listed on the appic directory? For apa accredited internship sites, is it okay for them to be counting provisionally licensed psychologists in the required 2 full time supervising psychologists needed?

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[PsyDr]

" ...must be provided by psychologists on the program's staff members who are licensed (certified or registered) for independent practice at the doctoral level... "

 

[Intern2223]

" ...must be provided by psychologists on the program's staff members who are licensed (certified or registered) for independent practice at the doctoral level... "

That’s what I thought. My internship site currently has 1 full time licensed psychologist, 2 part time licensed psychologists (one working ~7-10 hours a week and the other working ~5-10 hours a week - so the two of them do not equate to one full time), and then 1 full time provisionally licensed psychologist (the current postdoc). We’ve raised concerns, and keep being told that provisionally licensed is a license - so that counts - but the postdoc still is required to have supervision under that license - so she isn’t licensed for independent practice.

Recommendations for how to bring this up? Considering this concern has been brought up by one of the current interns and we were given inaccurate information when interviewing and when starting internship and inaccurate information continues to be presented to the incoming interns and prospective applicants.

This is just the tip of the iceberg with this site.

 

[summerbabe]

Recommendations for how to bring this up?

I supervise but am generally out of the loop on broader program admin/grievance/accreditation/etc topics so hopefully others with more experience can chime in.

But broadly speaking, the objective that you want to achieve should guide your next steps.

It sounds like the program is either not aware of APA's distinctions (unlikely) or are very aware and trying to wiggle by on a misinterpreted technicality.

APA has a formal complaint process. Looking at the FAQs, complaints are not anonymous but they do need to be responded to by the program in a timely fashion.

And since postdocs absolutely should not count as full-time supervisors because that's a tiered supervision model operating under a single full license, I would assume the program would need to make changes to maintain their accreditation status with loss of accreditation a possibility down the line if they are unable to correct this within whatever timeline APA sets to resolve issues like this.

If you were to formally complain, it would probably be a good idea to have your ducks in a row (e.g., started your next job/postdoc, don't need any future refs/letters from this site, etc) especially since I wouldn't anticipate any change between now and the end of your internship. If you plan on remaining local to this area versus moving elsewhere, that could be considered as well since an aggrieved person (especially if they have some pull) can potentially negatively impact your career prospects or reputation.

There may also be options locally if this internship is housed within a broader healthcare system since that system would have an interest in their programs being in compliance. If so, reaching out to the hospital ombudsman or another management entity involved with accreditation could be an option. Good luck!

 

[AcronymAllergy]

I may be missing it, but I don't see that APA stipulates the two psychologists on-site must be full-time, just that there must be two psychologists on-site, per standard IV.A.3.b:

"The program must have a sufficient number of supervisors to accomplish the program’s service delivery and to supervise training activities and program aims. An accredited internship program must have a minimum of two doctoral-level psychologists on-site"

But yes, in the Implementing Regulations document, they are pretty specific that supervisors must be independently-licensed:

"In interpreting this provision for internship programs, the CoA looks to determine appropriate credentialing of the supervisor on the basis of jurisdiction governing the practice or service that is being supervised, provided the credential is generic in legally qualifying the holder for the independent practice of health service psychology."

So basically, someone who requires their own supervision wouldn't be allowed to be a primary supervisor, and I believe any supervision they provide would not count toward the required 2 hours per week of supervision provided by a licensed psychologist (unless their supervisor were also in the room, perhaps). There may be some sort of technicality if the supervised provider is receiving supervision on their supervision (as confusing as that seems), but if I were a director of training, that's not the kind of situation I'd want to put myself or the program in, nor is it something I'd want to have to try to explain to APA.

Edit to ask: how many interns are there, and are you all receiving the necessary number of hours per week?

 

[summerbabe]

But yes, in the Implementing Regulations document, they are pretty specific that supervisors must be independently-licensed:

"In interpreting this provision for internship programs, the CoA looks to determine appropriate credentialing of the supervisor on the basis of jurisdiction governing the practice or service that is being supervised, provided the credential is generic in legally qualifying the holder for the independent practice of health service psychology."

So basically, someone who requires their own supervision wouldn't be allowed to be a primary supervisor, and I believe any supervision they provide would not count toward the required 2 hours per week of supervision provided by a licensed psychologist (unless their supervisor were also in the room, perhaps). There may be some sort of technicality if the supervised provider is receiving supervision on their supervision (as confusing as that seems), but if I were a director of training, that's not the kind of situation I'd want to put myself or the program in, nor is it something I'd want to have to try to explain to APA.

Great points.

At my postdoc, many postdocs supervised interns. However, those interns still received their minimum 2 hours of supervision from their primary supervisor(s) so this was on top of, not in lieu of. And the postdocs were never designated as the responsible on-site person - that was still the primary rotation supervisor (or their coverage if they were out).

During my grad program, some of the professors in our program were not independently licensed so they received tiered supervised from our TD (but that unlicensed prof would sign off on our hours/clinic reports). Not sure how this might apply to APA internships so there's probably one scenario where all of this is technically kosher but that process is probably looking like an Escher design.

Overall, I agree that this does not sound like an ideal situation and would also hate for any trainees to run into licensing problems because of this. My state is super hands off but that's definitely not the case everywhere.

 

[smalltownpsych]

Sounds like they are a little short staffed and trying to make it work. It happens. They could just shut the program down and then the interns would really be in a bad situation. Interns are a bit idealistic and often struggle with the shortfalls of the real world implementation of what we do. Being frustrated because there are lots of problems at a site and then focusing on all of the details of those problems is probably the norm. I know it’s what we did. 😁