1. Removing constraints to innovation and barriers to education pathways, and the shift to a competency-driven approach

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1 11 th July, 2014 The Australian Psychology Accreditation Council (APAC) GPO Box 2860 Melbourne VIC, 3001 RE: Core Standards Consultation: Response from the Melbourne School of Psychological Sciences to The Second Consultation Draft of the Accreditation Standard for programs of Study in Psychology, (released by APAC on 27 May, 2014.) The Melbourne School of Psychological Sciences welcomes the opportunity to contribute to the second consultation draft of the APAC accreditation standards. Our submission outlines the principal concerns we have with some of the proposals in the second draft. It should be viewed as a complement to the submission made on behalf of the Go8 schools, and to the submission from HODSPA, both to which we contributed, and endorse. 1. Removing constraints to innovation and barriers to education pathways, and the shift to a competency-driven approach We welcome the shift towards the specification of outcomes over inputs and the competency-driven approach, but note that the retention in the current draft standards of the proposed increase in the required undergraduate study program from the current minimum of 42% to 58% is antithetical to these objectives, and is inconsistent with the COAG Principles for Best Practice Regulation requirement to reduce unnecessary restrictions, and with the requirement for efficiency under the AHPRA Procedures. Rather than removing constraints, the additional semester s worth of Psychology load imposes unnecessary restrictions on the flexibility and breadth of undergraduate options within Australian generalist undergraduate degrees. Furthermore, the proposed increase in undergraduate content introduces a severe impost on graduates of other disciplines who wish to transition to a career in Psychology. The draft consultation paper provides no compelling arguments to justify the proposed increase in undergraduate content, and fails to consider the serious costs to students who would otherwise undertake broadening studies in disciplines which embrace ways of thinking and knowing that are complementary to the study of psychology and which ultimately 1

2 enrich the knowledge and skills of those students who go on to undertake professional training in psychology. The move towards broadening undergraduate programs of study as preparation for specialized professional training at higher levels is not only central to the Melbourne Model, but is a now a core pedagogical principle embraced widely by Australian Higher Education providers. As we noted in our submission to the initial consultation draft, the proposed increase to 58% psychology content in the undergraduate program simply cannot be accommodated within the degree structures of the Melbourne Model; it represents a 40% increase relative to the current requirement. The suggestion in the draft consultation document that institutions simply offer unaccredited sequences fails to recognize the cost to students who would be unable to undertake an accredited undergraduate education in psychology in the highest ranked Psychology School in Australia. This cost would not be unique to the University of Melbourne and its undergraduate model, but would be shared by many of the other highly ranked Schools in the country, including a majority of Schools in the Group of Eight. 2. Alignment with the Australian Qualifications Framework We note with concern that the current consultation draft maintains the approach of using the AQF Levels 7-10 as the organising principle for the sequence of accredited qualification. In our view, this reflects an overly restrictive interpretation of the AQF guidelines, imposing unnecessary restrictions on the flexibility of Universities to provide innovative training pathways in psychology. As we noted in our response to the initial consultation draft, this is a particular problem for graduates of other disciplines wishing to transition to a career in psychology; under the proposed standards these students would be required to undertake a Bachelor degree despite the potential to develop graduate programs to more appropriately accommodate their career goals. 3. Alignment with international standards One justification provided for the proposed increase in psychology content in the undergraduate program in the initial consultation draft was a desire to align with EuroPsy standards. However, much of the justification for doing so is now obviated by the removal in the current consultation draft of the previous proposal to include pre-professional skills training in the undergraduate curriculum. As such, it could be 2

3 argued that the current consultation draft now sits much more naturally aligned with the North American model in which post-graduate qualification in professional psychology is the norm. 4. Content and graduate attributes in the undergraduate program It is pleasing to see that the foundational skills in interviewing and basic counseling that were previously proposed as graduate attributes for level 7 programs in psychology have been moved to the AQF level 8 programs, consistent with the proposal we made in our response to the initial consultation draft. As noted above, this welcome change would seem to obviate the need for additional content in the undergraduate program, removing the key justification for the proposed increase in undergraduate psychology. In fact, the remaining pre-professional skills at level 7 in the current consultation draft which appear under Graduate Attribute 5 (Communication and interpersonal skills in psychology), and include basic interviewing skills, and the ability to use flexible techniques to communicate sensitively with diverse ethnic and cultural backgrounds are arguably skills that are already part and parcel of any broad undergraduate degree undertaken in Australian Universities. For example, under the Melbourne University Graduate Attribute for Active Citizenship, all Melbourne graduates of any discipline:.are aware of the social and cultural diversity in communities and can work collaboratively with people from diverse linguistic and cultural backgrounds. In particular, they have an understanding of and deep respect for Indigenous knowledge, culture and values. This redundancy of psychology graduate attributes with the graduate attributes of broad undergraduate degrees in Australian Universities underscores our previous point relating to the importance of retaining a broad undergraduate curriculum, ensuring studies in diverse discipline areas that complement the skills and knowledge required for training in psychology. 5. Benchmarking and quality improvement We support the proposal that APAC should require education providers to demonstrate regular benchmarking of their programs and/or evidence of quality improvement activities, and agree that the continuous quality improvement is essential for the protection of the public, and is 3

4 meaningful only when education providers themselves are responsible for pursuing it. 6. Change to practicum and supervision requirements for post-graduate professional programs We support the increase in supervised Practica hours to 1,200 from 1,000 for the Extended Master Degree. This proposed Standard is in line with the stated aims of the Second Consultation Draft of the Core Standards in that it assists in bringing training standards in Australia more in line with international standards in terms of Practica hours. The proposed requirement that 80% of all Practica hours be logged as supervised Client contact and Client-related Activities (5.6.14) is an advance. The proposed Standard reflects a better understanding of the complexity and diversity of clinical practice and allows for flexibility in placement learning experiences. Nevertheless, we wish to highlight a number of areas of concern in the current consultation draft. The proposed standards relating to staff-student ratios represent a substantial reduction from the levels included in APAC 2010 Standards and, in our view, would lead to the undermining of professional standards. In particular, the proposed staff: student ratio of 1:15 (p. 7) is insufficient for training in Clinical Psychology and Neuropsychology and is highly likely to contribute to reduced quality of training, with consequent effects on professional standards. Hence, we strongly recommend continuation of the ratio set out in relevant Standard in the APAC 2010 Accreditation Guidelines. Postgraduate training in Clinical Psychology and Neuropsychology is necessarily highly resource intensive. Unquestionably, it is the high level of staff/student engagement that ensures the highest standards of clinical training are met. Similarly, supervisors of Clinical Psychology and Neuropsychology Practica must be adequately trained. Hence, Sections (iv) of Level Nine Masters Extended Degrees should be altered to require that supervisors of Practica hold qualifications and maintain experience applicable to the area of psychology endorsement for which the student is training. Further, we strongly argue that the proposed Standard that only two supervisors be required for training across all placements in the Extended Master Degree for Clinical Psychology is inadequate. To ensure students on placement experience diversity in clinical experience across a range of 4

5 clinical domains, at least three supervisors, one for each placement, is required. The very marked reduction in the ratio of supervision hours: number of hours worked in 1:17.5, raises grave concerns regarding the quality of training provided to students by Practica supervisors and, significantly, student safety. The proposed ratio is seriously inadequate for postgraduate Clinical Psychology and Neuropsychology training. This equates to a total of 55 hours of supervision across an Extended Master Program and represents an undermining of current standards, and greater distance between Australian and international standards. We contend, also, that the proposed proportion of group supervision permitted under the Standards is inadequate and submit that that 25% of total supervision hours in each placement would be adequate. Finally, we contend that high quality postgraduate training in Clinical Psychology and Neuropsychology is predicated on the scientist practitioner model, with emphasis being given to the nexus between research and clinical practice. It is essential that Extended Masters and Doctoral research remain focused on research that is clinically relevant and based on study of clinical populations. 6. Changes to postgraduate bridging program specifications The standards for crediting of Bridging or Conversion Programs, as proposed, are unacceptable for the Areas of Endorsement of Clinical Psychology and Neuropsychology. Specifically, they are incompatible with current University of Melbourne regulations regarding credit for study undertaken at other educational institutions. In order to ensure University of Melbourne Clinical Psychology and Neuropsychology graduates achieve graduate outcomes, regulations require that all Bridging or Conversion Programs into Clinical Psychology and Neuropsychology must be equivalent in every aspect to the degrees (or part thereof) for which they are to substitute. Further, they must comply with the same eligibility requirements for entry to the Program and to Practica as the Level 9 Extended Master Degree. Hence, the proposed Standard of 48 Credit Points, or a single year of training, is totally inadequate for Bridging or Conversion Programs. Further, we contend that the proposed Standard of the awarding of up to 22 Advanced Credit Points (up to a total of 26 Credit Points) in Clinical Psychology to enter the Psychology Registrar program, as opposed to the standard pathway of 5

6 96 Credit Points leads to an undermining of standards for Clinical Psychology and Neuropsychology. Closing remarks The Executive of the Melbourne School of Psychological Sciences recognizes the complexity and challenges of the task that APAC has faced in drafting the accreditation standards. We see merit in many of the proposals and applaud several of the desired changes to postgraduate professional training, as well as the emphasis on benchmarking, in which we already actively engage. However, we believe that very significant problems remain with the draft standards. If left uncorrected these would have serious repercussions for psychology education at undergraduate and postgraduate levels. We are gravely concerned in particular that APAC does not appreciate that the proposed 58% psychology-related learning requirement is simply impossible to meet under our model, and cannot be ameliorated by addition of electives or the offering of nonaccredited programs. This concern is not isolated to us, but is very widely shared among the country s top-ranked Schools of Psychology and indeed throughout the sector, and we do not believe that an adequate case has been made for such a massive increase in the requirement. We also believe the current implementation of the AQF guidelines is overly restrictive and would stifle educational innovation, and that a one-size-fits-all alignment with European training models is misplaced when many of the leading institutions and training models in the field are based elsewhere. We strongly urge APAC to reconsider these proposals. Professor Nick Haslam Head of School Melbourne School of Psychological Sciences 6