I share your concern about correspondence training, though many NPs elect this route, which is probably going to make it harder to enforce a residential requirement. I also believe that the supervision requirements are light and need to be increased, though hopefully this consideration will be accepted before the final bill is signed.
I believe the burden of proof is on the professionals who want to prescribe, and not on the medical community to prove it is not safe. However, the attempts made by the professional in favor of prescription seem to be met by accusations that patients will die and other related and unsubstaintiated mudslinging, which is the exact response mid-levels received when they were lobbying for prescribing rights. Both sides are guilty of throwing mud, so instead I'll refer to a formal evaluation of the DOD study, which you have called "a failure"
As for safety, while the DOD comparison has flaws as a direct comparison, I think it provided some insight into the feasibility of a psychologist being able to seek additional training and then being competent to safely prescribe (and unprescribe) psychotropic medications.
The DOD project was not a failure, as it showed that psychologists who were given additional training could safely prescribe psychotropic medications. The cost-effective nature of the DOD project is a separate consideration.
According to the American College of Neuropsychopharmacology ACNP Evaluation Panel Report from May 1998:
In regard to effectiveness: All 10 graduates of the PDP filled critical needs, and they performed with excellence wherever they were placed. It was striking to the Evaluation Panel how the graduates had filled different niches and brought unique perspectives to their various assignments
In regard to medical safety and adverse effects, I agree that there is not equivalency to a psychiatrist, which seems to be a popular straw-man argument against RxP, though in a collaborative setting the prescribing psychologists prescribed effectively and without adverse events, per the ACNP report. The other popular stra-man argument is that, you dont know what you dont know, though the panel found that in fact the prescribing psychologist did have an awareness, and they were able to consult a physician when they needed additional assistance.
As for critiquing the 10 people to sign up, anyone who has done any formalized research understands that recruitment is a complex issue, and simply chalking it up to, "no one wanted to do it" is both ingenuine and inaccurate.
Are there limitations to the DOD
absolutely. Here are the limitations that I see:
1. Small N. Obviously I would have like to see more people, though for a first study it is understandable that they didnt have 100+ people.
2. The training required more direct supervision hours than what is required now under present legislation in NM and LA, so it is not an equitable comparison. I think this is the biggest weakness of the comparison, and an area that has not been sufficiently addressed in the new legislation.
3. Specialized population. Yes the military does not include peds and geriatric patients, however the report said dependants and Veterans were seen by some of the prescribers, with no reported adverse effects (ref. Variety v. Restricted Caseload in the report). Id like to see more data with these populations, but it is a start.
4. More oversight than a private out-patient provider. I believe that the collaborative piece is very important to not only training, but overall effectiveness. This limitation was clearly noted in the report, and I believe the new legislation is reflective of this limitation by requiring collaborative agreements with a physician. I believe the collaborative requirement will provide an adequate answer to this concern.
As an aside, the report found that while it was a restricted population, they essentially mirrored what psychiatrists did with the same population, and, in fact, they differed little from the private practices of the psychiatrists on the Evaluation Panel
Would you mind asking Dr. Ally if it is okay to share that e-mail here, as I'd like to see exactly what was said.