Submission to the Australian Psychology Accreditation Council (APAC) For the APAC Second Consultation Draft of the Core Standards
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- Olivia Bryant
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1 Submission to the Australian Psychology Accreditation Council (APAC) For the APAC Second Consultation Draft of the Core Standards Prepared by: Dr. Judy Hyde, President, the Australian Clinical Psychology Association (contact:
2 The Australian Clinical Psychology Association (ACPA) thanks the Australian Psychology Accreditation Council (APAC) for the work undertaken to further develop accreditation pathways and standards for training for the professional practice of psychology. We appreciate the opportunity to review these revised pathways and Standards to ensure they are benchmarked against international standards and are sufficient to protect the interests of the public. While some aspects of the Standards are pleasing to see as they strengthen training, particularly of the Generalist Psychologist, many are severely deficient when applied to Clinical Psychology training. This may mean that a generic set of Standards for all members of the profession across all Areas of Endorsement (AoPE) is not achievable. If so Standards for Clinical Psychology will need to be developed as separate Standards by APAC or by the Psychology Board of Australia (PsyBA) as part of the requirements and competencies for Clinical Psychology. Notwithstanding the progress made, ACPA continues to hold grave concerns for the standard of training proposed in the Second Consultation Draft. We are concerned that in a push to train large numbers of Psychologists in the cheapest manner possible, to supposedly meet workforce needs, the Standards seriously underestimate the importance of quality training in ensuring the protection of the public in clinical practice. This is particularly of concern, given that Australia already has the largest per capita workforce of Psychologists in the English-speaking world, and the most poorly trained (Hyde, 2014). 2
3 Executive Summary In general, it is pleasing to see that: APAC has recommended that education providers may choose to provide non-accredited program options (p. vi) to allow for diversity in psychology training outside of clinical practice. ACPA commends retention of benchmarking and quality improvement activities are retained in order to promote and maintain high standards and the development of competence to practice. ACPA strongly supports the emphasis of the proposed Standards on competency-based outcomes, and assumes these competencies will be those established by the PsyBA until international agreement is reached on professional competencies. Benchmarking and quality improvement activities are retained to promote and maintain high standards of training. In Clinical Psychology specifically: ACPA applauds the increase in supervised Practica hours to 1,200 from 1,000 for the Extended Master Degree. It is essential that Australia move as rapidly towards international standards in terms of Practica hours. ACPA is also pleased to see a Standard requirement of 80% of all Practica hours as logged supervised Client contact and Client-related Activities (5.6.14). This allows for flexibility in the learning experiences of Practica. However, it is of serious concern that: Professional training for the Generalist Psychologist continues to occur totally (in the pathway) or substantially (in the pathway) within an unaccredited supervision program. This is particularly concerning where graduates from undergraduate programs that do not prepare them for professional practice are working independently, or with minimal supervision, in treating seriously vulnerable patients with mental health problems. International Standards, including the EuroPsy Standards, are not being met by the proposed Standards. Australia needs to move more rapidly towards International Standards for English-speaking countries. Research training via the 4 th year Honours program is being integrated into professional training. 3
4 In Particular, Standards for Clinical Psychology are Seriously Inadequate and are Not Acceptable: Bridging or Conversion Programs as proposed are totally unacceptable for the AoPE of Clinical Psychology as proposed, in particular: a. All Bridging or Conversion Programs into Clinical Psychology must be equivalent in every aspect to the degrees for which they are to substitute. b. They must adhere to all the same rules of eligibility for entry to the Program and to Practica as the Level 9 Extended Master Degree. c. The training Program itself needs to be identical in all aspects and held to the same standard as the Extended Master program in Clinical Psychology, with identical content, focus, application, learning outcomes and competencies. d. The proposed Standard of 48 Credit Points, or a single year of training, is totally inadequate for Clinical Psychology Bridging or Conversion Programs. e. The proposed Standard of the possible awarding of a further 22 Advanced Credit Points, making a potential total of 26 Credit Points in Clinical Psychology to enter the Registrar program for endorsement, as opposed to the standard pathway of 96 Credit Points leads to a serious undermining of standards for Clinical Psychology and is unacceptable. The proposed level of Advanced Credit for Level Nine Masters Extended Degrees, Level Ten Doctoral Degrees, and Bridging and Conversion Programs in Clinical Psychology is totally unacceptable. In Australia, virtually all commonality in training occurs at undergraduate level. Advanced Standing for Practica in the Extended Master Degree is excessive for Clinical Psychology, and again leads to the undermining of professional standards. The Staff: Student ratio of 1:15 (p. 7) is insufficient for training in Clinical Psychology and again leads to the undermining of professional standards. Staff need to be adequately trained (i.e. hold post-graduate qualifications in Clinical Psychology) in order to train Clinical Psychologists. It is unacceptable that Extended Masters and Doctoral research conducted is not required to address clinical issues with a clinical population for Clinical Psychology. Supervision of Clinical Psychology Trainees as per the proposed Standards has made some improvement; however, the Standards are in many areas seriously inadequate and place the public at risk, for example: a. The dramatically reduced ratio of supervision hours: number of hours worked of 1:17.5 is seriously inadequate for Clinical Psychology training. This equates to a total of 55 hours of supervision across an Extended Master Program and again leads to the undermining of current standards, and greater distance between Australian and international standards. b. The proposed proportion of group supervision permitted under the Standards is inadequate. Only 25% of supervision in each placement would be adequate. c. Supervisors of Clinical Psychology Practica must be adequately trained. For Clinical Psychology, Sections (iv) of Level Nine Masters Extended Degrees and (ii) of Level Ten Doctoral Degrees with Professional Coursework must be clarified to 4
5 state that each supervisor undertaking supervision of students who are involved in any Practica involving real Clients: Must hold qualifications and maintain experience applicable to the AoPE for which the student is training.. d. The role of Secondary Supervisors undertaking some component of Clinical Psychology Practica needs to be clarified. e. Two supervisors are insufficient for training across all placements in the Extended Master Degree for Clinical Psychology. At least three supervisors, one for each placement, is required to provide adequate knowledge, skills and assessment in a range of areas. Summary of Recommendations General Recommendations Move to a two year Master Degree for General Practice in Psychology. This would align Australia with New Zealand and adopt the level of professional training of the EuroPsy model. It would also avoid the introduction of the Bologna model by stealth. As a first step to raising standards, limit the scope of practice of the Level 8 Graduate Diploma to non-practising areas of psychology. APAC must acknowledge and take responsibility for Standards that adequately protect the public, not just notionally, but in the practical application of adequate, internationally benchmarked Standards. Standards need to be continually raised in all pathways to meet those of English-speaking countries. Benchmarking needs to be retained nationally and strengthened internationally. Clear differentiated learning objectives and outcomes are necessary for the Master Degree by Coursework to lead to registration and not provide a condensed 9 year program for entry to further training in all levels of endorsement. Research training via the 4 th year Honours program must remain separate from professional training. Recommendations Specific to Clinical Psychology If the proposed Standards are considered adequate for other areas of Psychology practice, separate Standards must be developed for Clinical Psychology in order to protect the public. If Clinical Psychology cannot be adequately structured in the Standards established by APAC, it may be necessary to incorporate separate accreditation Standards into the requirements laid down by the PsyBA for the Clinical Psychology AoPE. Bridging and conversion programs for Clinical Psychology must replicate the degrees for which they are intended to substitute in every aspect, including: selection, assessment, knowledge, research, clinical training. These must be to the same rigorous standard as required within a Master Extended or Doctoral degree in Clinical Psychology. 5
6 Specifically, applicants must satisfy the requirements of an assessment interview and/or other assessment processes designed to determine their suitability to undertake Clinical Psychology education and training contained in the Program. Students must pass an assessment of suitability and preparedness for Clinical Psychology education and training before permitting them to undertake any Practica that involves provision of Clinical Psychology services to Clients/Patients. A minimum of 80 Credit Points is absolutely necessary for any Bridging or Conversion Program in Clinical Psychology in order to ensure adequate protections for the public. No Advanced Credit can be given in Bridging or Conversion Programs in Clinical Psychology. All programs leading to endorsement in Clinical Psychology, a minimum of 80 Credit Points are acquired in an accredited Clinical Psychology program to enable sufficient integration of knowledge, research and clinical skills. It is essential to tailor the content of all Advanced Credit Points to the prior training and knowledge base of each individual student. This ensures that students of these programs attain the competencies and expertise for Clinical Psychology practice. Examination of the knowledge base, focus and application, including via viva, is essential to offer any Advanced Credit to be offered in a Clinical Psychology program. For all Programs leading to endorsement in Clinical Psychology, Standard must be included and adapted to read: total amount of Advanced standing or Credit for Placement granted to any student of the Program is never more than 25% of the total Practica Placement required by the Program of Study. To obtain Advanced Standing in Practica, it must be very clearly demonstrated that the experience is equivalent to a Clinical Psychology placement or practicum in terms of objectives, assessment, inputs and competencies. For a Clinical Psychology Placement, it must be clearly demonstrated that this was undertaken with a clinical population working with clinical mental health problems, and supervised by a qualified Clinical Psychologist, who is willing to declare that the level of practice and skill of the student has met the level of competencies that would be expected of a Clinical Psychology student on the same Placement. The previous 2010 Accreditation Standard of a Staff: Student ratios laid out in the current Standards 2.4 (2010, Australian Psychology Accreditation Council, p ) must be retained. As per these Standards, for a Clinical Psychology Extended Master program, or Bridging or conversion Program, a staff: student ratio of 1: 8 is required, with a minimum of three EFT staff per program. Rule (p, 37) of the current Accreditation Standards must also be retained, but amended for Clinical Psychology to read: For each professional postgraduate program there should be at least three staff who hold a doctoral degree in the relevant area of psychology and no less than half of the total staff EFT teaching into the program must have qualifications which make them eligible for endorsement in the relevant Area of Practice Endorsement (AoPE). All research completed as part of the training in Clinical Psychology, regardless of pathway, MUST be completed with a clinical population and address clinical questions. Retain the increase in supervised Practica hours to 1,200 from 1,000 (5.6.13) for the Extended Master Degree to move towards an increase in this Standard. 6
7 Retain the Standard requirement of 80% of all Practica hours as logged supervised Client contact and Client-related Activities (5.6.14). This allows for flexibility in the learning experiences of Practica. Retain the increase in supervised Practica hours to 1,200 from 1,000 for the Extended Master Degree and move towards an increase in this Standard. Retain the Standard requirement of 80% of all Practica hours as logged supervised Client contact and Client-related Activities (5.6.14). Ensure this Standard is applied to all pathways to endorsement in Clinical Psychology. The current Standard of one hour of supervision for every day worked must be maintained for Clinical Psychology in order to protect the public and students. Standards and must be adjusted to state: The Program of Study requires that no more than 25% of the supervision provided in each placement for Client-related Practica is group supervision. This would ensure that no student completes an entire placement with only group supervision, thus properly utilizing the benefits of both forms of supervision. If Secondary Supervisors are to be permitted, strong rules must be laid out to limit the amount of supervision provided by Secondary Supervisors. The work of the student and the Secondary Supervisor must be over sighted by a Clinical Psychologist who holds post-graduate qualifications in Clinical Psychology, undertakes the majority of supervision, views the student s work, and undertakes the final assessment of the student s work. The Principle Supervisor must sign off on all reports, case notes and log books. For Clinical Psychology the Level 9 Extended Master and Level 10 Doctoral level training at least three supervisors are necessary to examine the trainee s clinical practice in different settings, and with different populations, including child/adolescent and family and acute and chronic adult presentations. General Responses to the Proposed Revised Standards 1. Registration Standards for the Generalist Psychologist are Improved, but remain Inadequate We are pleased to see that the proposed Standards strengthen the training of Generalist Psychologists in some areas. However, the training in these pathways continues to be inadequate, especially given that the proposed Standards remain the lowest in the Western world for Psychologists. It is of concern that professional training for the Generalist Psychologist continues to occur totally (in the pathway) or substantially (in the pathway) within an unaccredited supervision program, whereby a Psychologist may be trained by a supervisor whose knowledge was gained 20 years previously from a supervisor whose knowledge was obtained 20 years prior to that. These pathways to registration remain risk points for the public. While the Psychology Board of Australia (PsyBA) is required by law to allow this pathway to registration, it is the responsibility of ACPC to limit its application. 7
8 We are pleased to note that APAC has recommended that education providers may choose to provide non-accredited program options (p. vi) to allow for diversity in psychology training outside of clinical practice. Graduates from the Level 8 Graduate Diploma program need to be limited to practice in non-clinical areas of psychology, such as, policy development, management, advertising, psychological applications to everyday problems, such as road safety etc. Until this pathway is developed to meet such needs, it must be a terminating pathway that can lead to only to general registration. Ultimately graduates from this program should become non-practising psychologists and unable to register to practise. We warn against the insidious implementation of the Bologna model through the process of allowing the inadequate pathway to strengthen without a required Honours level thesis inherent in this training. APAC has explicitly stated that this model is not its preferred model of training and must guard against moves to implement it as undergraduate programs diversify. Recommendations 1.1. Move to a two year Master Degree for General Practice in Psychology. This would align Australia with New Zealand and adopt the level of professional training of the EuroPsy model, while avoiding the introduction of the Bologna model by stealth As a first step to raising standards, limit the scope of practice of the Level 8 Graduate Diploma to non-practising areas of psychology. 2. International Standards are not being met by the proposed Standards APAC claims to move the Standard toward alignment with the European Qualification Standard for Psychologists (EuroPsy) (p.vi). However, EuroPsy Standards are well below those of Englishspeaking countries where a Doctoral degree is the minimum standard required for registration or licensure (UK, Ireland, Canada, USA and the equivalent in New Zealand). Furthermore, ACPA is deeply concerned that Australia remains significantly behind the EuroPsy Standard, which is the next lowest in the developed world. Furthermore, it is also important to note that the proposed Australian Standards fall far short of the EuroPsy requirements, as APAC acknowledges (p.vi), in both the level of supervised clinical practice (1,500 hours for EuroPsy) and psychology content at undergraduate level, despite the move to a requirement of 58% of psychology content in the undergraduate program in Australia. This places the Australian public at risk. The more psychology rich undergraduate program of EuroPsy is undertaken in three years, allowing two years of accredited professional training at post-graduate level prior to the commencement of the supervision program. In Australia, there is no adequate accredited professional training for the pathway prior to the supervision program, and only one year for the program. These pathways to registration would not be accepted as adequate in any other equivalent jurisdiction. Australian graduates are required to speak English, and are trained in English. Australia is an English speaking country. International mobility for Australian Psychologists is severely restricted to other 8
9 English speaking countries in adopting standards that do not match those of the English speaking world. In arguing its case to adopt the EuroPsy model and not the Doctoral model of English-speaking jurisdictions, APAC states that, Especially problematic is the fact that the compulsory accreditation and approval of the first four years of undergraduate psychology which is required by the PsyBA as a pillar of the Australian pathway to general registration, would be difficult to reconcile with the lack of any requirement for undergraduate psychology education in most North American jurisdictions. In doing so, APAC conflates and cherry picks standards in Canada and the USA, where the training models are different. Canada has a strong undergraduate program in psychology prior to entry to the doctoral program. Canadian standards are likely the highest standards in the world. While the USA does not specify an undergraduate program in psychology is necessary, deeming a strong science degree as equivalent for entry to post-graduate training, in practice it only occurs in extremely rare instances that a student can gain access to Doctoral level psychology training without a significant amount of psychology learning at undergraduate level. The American Psychological Society is currently reviewing to explicate the undergraduate requirements for training at doctoral level in psychology in order to make this clearer. It is important to note that undergraduate programs are not accredited in other jurisdictions as they are considered inadequate for practice as a Psychologist, and therefore do not lead to registration or licensure. Accreditation occurs only at post-graduate Doctoral level or equivalent in every jurisdiction in the English-speaking world, other than Australia, as this is considered the minimum training requirement for the protection of the public. While the PsyBA is obliged to accredit undergraduate programs in Australia as they lead through a supervision program to registration of Psychologists. This serious discrepancy continues to leave Australia with the most poorly trained Psychologists in the Western world. APAC also claims great variability in the educational and recognition requirements in place across its 50+ state-based licensing and accreditation bodies (p.vi), yet all require a Doctoral level training of four years, plus a year of supervised internship, with many jurisdictions requiring an additional year of supervised practice. It is to be noted that no Doctoral program earned in Australia would be accepted in any USA jurisdiction as adequate for licensure and practice as a Psychologist. New Zealand has an undergraduate program in psychology similar to that in Australia, plus a three year individuated post-graduate training for each scope of practice. New Zealand has a much higher standard of training than Australia, yet is forced to register Australian Psychologists, who have only an undergraduate program of study, under the Trans-Tasman agreement. Recommendations 2.1 APAC must acknowledge and take responsibility for Standards that adequately protect the public, not just notionally, but in the practical application of adequate, internationally benchmarked Standards. 2.2 Standards need to be continually raised in all pathways to meet those of English-speaking countries. 9
10 3. Benchmarking and quality improvement activities ACPA believes that benchmarking and quality improvement activities are essential in order to promote and maintain high standards and the development of competence to practice. Benchmarking needs to occur in terms of international standards as well as nationally. Until there is developed an internationally accepted set of competencies, benchmarking needs to occur on inputs and structures as well as national competency outcomes. To assume a model of training that aligns with the international competencies being developed through the International Project on Competence in Psychology (IPCP) is extremely premature. This project is currently merely in nascent form and does not address training requirements in any way whatsoever. Nevertheless, there are international standards and Australia falls well below these. Recommendation 3. Benchmarking is retained nationally and strengthened internationally. 4. Competency-based Outcomes Given that Australia has the lowest standards of training of professional Psychologists in the developed world, any further lowering or undermining of Standards in is abhorrent and must be renounced. The changes to the current Standards proposed by APAC significantly weaken training in professional psychology that is of particular concern in Clinical Psychology. ACPA strongly supports the emphasis of the proposed Standards on competencies as outcomes. This emphasis is essential in a profession where a broad and deep knowledge is required that then must be competently applied in practice in order to protect the public. However, to achieve adequate competencies inputs need to be strong and structures clearly in place to ensure proper teaching, training, evaluation, and assessment of all competencies. The training and assessment of competencies as outcomes requires more extensive resources and structures than programs that meet input Standards only. We believe this has not been adequately addressed in the proposed Standards, particularly for Clinical Psychology. The proposed Standards provide for fewer resources than the current Standards. They do not ensure adequate structures to support the current model, and fall far short of those required for a competency-based outcome model for Clinical Psychology. These may be different for differing areas of psychology training. A generic set of accreditation Standards may not be possible, given the differences in the training of Generalist Psychologists and AoPEs and between AoPEs. While the proposed Accreditation Standards may be viable for some areas of psychology, they are totally inadequate for the AoPE of Clinical Psychology, and possibly other areas where practice involves clinical populations, such a Clinical Neuropsychology and Forensic Psychology. This creates an unacceptable level of risk for the 10
11 public. The areas of grave concern for the AoPE of Clinical Psychology and protection of the public only will be addressed below. Recommendation 4. Develop a separate set of Standards for Clinical Psychology 4. Research The 4 th year Honours program is essential for research training and needs to continue to be differentiated from professional training. Given that psychology is considered a science and practice is evidence-based, competency in research is essential for proper selection of capable graduates into professional programs. Recommendation 5.1 The Honours year must remain an entry requirement for the Extended Masters degree in Clinical Psychology and all other pathways to endorsement in Clinical Psychology. 5. Standards for Clinical Psychology for Clinical Psychology are Seriously Inadequate and are Not Acceptable Clinical Psychologists must be held to a higher, more rigorous standard of training and practice than other Psychologists as their practice as experts in mental health, particularly with more seriously vulnerable patients with comorbid, chronic, and intractable problems, would place a patient s life at risk, if competence or expertise is inadequate. Evidence of the need for a rigorous training in Clinical Psychology for Psychologists practicing as experts in mental health is strong. In Victoria, over the past two years, only one Psychologist in seven coming before a Tribunal has had professional training at post-graduate level. Preliminary evidence of an analysis of members of the psychology profession de-registered due to misconduct or poor practice, currently being undertaken by the Australian Clinical Psychology Association (ACPA), demonstrates the necessity of adequate training for Psychologists dealing with mental health problems. There is a preponderance of Psychologists without undergraduate qualifications majoring in Psychology who have been disciplined by Tribunals for inadequate practice or poor conduct. While those with post-graduate qualifications are all, including qualified Clinical Psychologists, just as likely to be deregistered for misconduct related to boundary violations, Generalist Psychologists without qualifications in Clinical Psychology but practising with clinical populations in mental health, are also de-registered for poor, inadequate and/or unethical practices. Thus to lower the standard of Clinical Psychology training places the public at significant and demonstrable risk. Further weighty evidence that Psychologists practising without accredited training in Clinical Psychology with patients or clients suffering from serious mental health problems, place the public at substantial risk comes from the New South Wales Coroners Court. It is of public record that the 11
12 practices of two such Psychologists have been instrumental in the patient deaths. These Psychologists had been endorsed in professional practice AoPEs (Health and Counselling) in Psychology due to their membership of the associated Colleges of the Australian Psychological Society (APS). Standards for entry to APS Colleges have been far below those established by the PsyBA as essential. Recommendations 6.1 If the proposed Standards are adequate for other areas of Psychology practice, separate Standards must be developed for Clinical Psychology in order to protect the public. 6.2 If Clinical Psychology cannot be adequately structured in the Standards established by APAC, it may be necessary to incorporate separate accreditation Standards into the requirements laid down by the PsyBA for the Clinical Psychology AoPE. Specific Standards that are inadequate for the AoPE of Clinical Psychology include: 6. A lack of Clear Focus and Purpose of the Master Degree by Coursework and Differentiation from the Extended Master Degree Program leaves the Master Degree by Coursework Unmanageable. The Level 9 Master program is a generalist program that cannot be equivalent to the first year of an Extended Master program leading to an AoPE. It is not possible to cover to any extent the necessary first year content of all nine AoPEs in one year. This would take nine years. These programs, by necessity, have different purposes, intent, foci, and rigor. The Master Degree by Coursework is intended to produce Generalist Psychologists, while the Extended Master Degree is intended to lead to endorsement in one of the AoPEs. Professional training is not simply academic learning for which the content of programs is similar and can be equated. It is dangerous to assume that there is adequate teaching in clinical applications and competencies in a one year generalist professional practice training degree to equate to the integrated and supervised program of applied knowledge, research and learning entirely in the assessment, diagnosis, formulation, treatment, outcome measurement and research with mental health disorders of a Clinical Psychology program. The Level 9 Master Degree cannot articulate into the Clinical Psychology Extended Master Degree or a Bridging or Conversion Program with safety to the public without a clear differentiation of the purpose of the Master Degree by Coursework, and serious restrictions on the allowable Advanced Credit for graduates of these programs. This process is not evident in the Standards. Recommendations 7. Clear differentiated learning objectives and outcomes are necessary for the Master Degree by Coursework to lead to registration and cannot provide a condensed 9 year program for entry to further training in all levels of endorsement. 12
13 8. Bridging or Conversion Programs as proposed are totally unacceptable for the AoPE of Clinical Psychology All Bridging or Conversion Programs into Clinical Psychology must be equivalent in every aspect to the degrees for which they are to substitute. They must adhere to all the same rules of eligibility for entry to the Program and to Practica as the Level 9 Extended Master Degree, at every stage of the Program. That is they must satisfy the requirements of an assessment interview and/or other assessment process designed to determine their suitability to undertake Clinical Psychology education and training contained in the Program; and pass an assessment of suitability and preparedness for Clinical Psychology education and training before being permitted to undertake any Practica that involves provision of Clinical Psychology services to Clients/Patients etc. While an individual may be suitable to practice as a Generalist Psychologist or in another AoPE, they may not be suited to practice as a Clinical Psychologist. The training Program itself needs to be identical in all aspects and held to the same standard as the Extended Master program in Clinical Psychology, with identical content, focus, application, learning outcomes and competencies. If this is not the case, these pathways to endorsement in Clinical Psychology establish a two tier system of training that cannot guarantee the same outcomes or competencies for all Clinical Psychologists. Any lowered accreditation Standards of training via different pathways places the public at risk of inadequately trained Clinical Psychologists. This leaves those making referrals for Clinical Psychology services further confused as to whom to refer when they need a qualified and expert Clinical Psychologist to assess and treat patients. This is already a serious problem for Clinical Psychology where standards of training have been made highly variable through unaccredited Bridging Plans and the profession has been consequently divided. It is essential that in Clinical Psychology the integrated program of knowledge, research, clinical and professional practice is sufficiently extensive and rigorous to protect the public. In referring to programs of study that offer piecemeal learning, as evidenced previously in Individual Bridging Plans offered by the Australian Psychological Society, the PsyBA clearly states, The Board s view is these do not provide the sustained education, training and supervision that characterises the integrated experience in a specific postgraduate degree plus supervision program required for endorsement. (Consultation Paper on Codes and Guidelines April, 2010, p. 2). ACPA concurs with this view. The current Standard of 48 Credit Points, or single year of training, is totally inadequate for Clinical Psychology Bridging or Conversion Programs. The Master Degree by coursework is intended to train a Generalist Psychologist in a very broad range of applications with a much lesser lower level and standard of requirements in mental health than the first year of an Extended Master Degree in Clinical Psychology. This is not equivalent to the first year of an integrated training focused entirely in Clinical Psychology. It is also not sufficient for those converting from any other AoPE, where the content, focus and application of training is not equal to the content, focus, application of Clinical Psychology training. Furthermore, under the proposed Standards, a further 22 Advanced Credit Points is possible, making a potential total of 26 Credit Points in Clinical Psychology all that is required to enter the Registrar 13
14 program for endorsement, as opposed to the standard pathway of 96 Credit Points. This is totally and irrevocably unacceptable for Clinical Psychology. Recommendations 8.1 Bridging and conversion programs for Clinical Psychology must replicate the degrees for which they are intended to substitute in every aspect, including: selection, assessment, knowledge, research, clinical training. These must be to the same rigorous standard as required within a Master Extended or Doctoral degree in Clinical Psychology. 8.2 Specifically, applicants must satisfy the requirements of an assessment interview and/or other assessment processes designed to determine their suitability to undertake Clinical Psychology education and training contained in the Program. 8.3 Students must pass an assessment of suitability and preparedness for Clinical Psychology education and training before permitting them to undertake any Practica that involves provision of Clinical Psychology services to Clients/Patients. 8.4 A minimum of 80 Credit Points is absolutely necessary for any Bridging or Conversion Program in Clinical Psychology in order to ensure adequate protections for the public. 8.5 No Advanced Credit can be given in Bridging or Conversion Programs in Clinical Psychology. 9. The proposed level of Advanced Credit for Level Nine Masters Extended Degrees, Level Ten Doctoral Degrees, and Bridging and Conversion Programs for Clinical Psychology is totally unacceptable The claim is made that there is considerable commonality in the training of Psychologists in the different AoPEs (p. viii). This claim is incorrect. Each AoPE is unique, practises with different populations, and utilises discrete knowledge bases, with distinct expertise in relation to specific areas of psychology. While the competencies may appear common, each competency is discrete in focus and application for each AoPE. This is why AoPEs are differentiated internationally and in Australia through AoPEs regulated by the PsyBA. Post-graduate training in Sport and Exercise Psychology and Organisational Psychology are quite different from Clinical Psychology. Even amongst those AoPEs practising with clinical populations, such as Clinical Psychology, Clinical Neuropsychology and Forensic Psychology, each are quite distinct and require a different knowledge base and extensive training for safe and expert practice. This differentiation in focus and expertise is acknowledged in the differing AoPEs (See the Appendix A for an analysis of differentials for Clinical Psychology and the areas in which Advanced Credit may apply). Should an AoPE claim to have the same knowledge and expertise as another AoPE, and cannot differentiate itself from any other AoPEs, it needs to be disbanded as an AoPE, as it is not unique. In Australia, virtually all commonality in training occurs at undergraduate level. In the UK, Ireland, New Zealand, and Canada, where undergraduate psychology is strong, differentiation of professional post-graduate training, particularly for Clinical Psychology, is recognized through differentiated Degrees. Only the USA includes commonality in post-graduate psychology degrees; however, this is 14
15 due to the lack of requirement for a strong undergraduate program specializing in psychology for entry to Doctoral programs in the USA. In English speaking countries Clinical Psychology is registered or licensed at Doctoral level only (UK, Ireland, Canada, USA) or equivalent (New Zealand). Three years of accredited, differentiated professional post-graduate training is the minimum. In Australia an Extended Master degree of two years qualifies Clinical Psychologists. The international standard of three years of post-graduate training is either well beyond Australia s standards, requiring a move to Doctoral level training only for Clinical Psychology, or is accounted for in the training provided at undergraduate level. There is very minimal commonality in in content, focus and training at post-graduate level in Australia. Clear evidence in practice of the lack of alignment and overlap in training of Clinical Psychology and other AoPEs comes from New South Wales where: a) Despite careful consideration, the University of Sydney has allowed no credit for any subjects to graduates of the Master of Counselling Psychology program at Macquarie University as the courses had different emphases, foci and standards to a Clinical Psychology program, despite careful consideration. As an example, the Master of Clinical Psychology and Master of Counselling Psychology programs at Macquarie University ran different training in Cognitive Behavioural Therapy, as the requirements and standards of the two programs differed considerably. The only Advanced Credit offered was in an observational placement, with no direct Client/Patient contact. b) Where course teaching has been combined at the University of New South Wales for Clinical and Forensic Psychology and at Macquarie University for Clinical and Counselling Psychology or Clinical and Clinical Neuropsychology, the objectives and outcomes for the students in each program differ. c) Where students transfer between universities from one Clinical Psychology program to another, little credit can be given as programs are differentially organized and differing aspects of the knowledge and skills are taught in differing ways and areas, leading to a lack of equivalence of training in various areas at different stages of training. The greater innovation in training practices promoted by the Draft Standards will serve to amplify this lack of alignment. Such lack of equivalence and commonality has serious consequences for the Bridging or Conversion Programs into Clinical Psychology and for Advanced Credit being awarded for prior learning in the Extended Master or Doctoral degrees leading to the AoPE of Clinical Psychology. Recommendations 9.1 For all programs leading to endorsement in Clinical Psychology, including Bridging and Conversion programs and the Extended Master of Clinical Psychology degree, a minimum of 80 Credit Points are acquired in an accredited Clinical Psychology program to enable sufficient integration of knowledge, research and clinical skills. 9.2 It is essential to tailor the content of all Advanced Credit Points to the prior training and knowledge base of each individual student. This ensures that students of these programs attain the competencies and expertise for Clinical Psychology practice. Examination of the 15
16 knowledge base, focus and application, including via viva, is essential to offer any Advanced Credit in a Clinical Psychology program. 10. Advanced Standing for Practica in the Extended Master Degree is completely excessive for Clinical Psychology, and is insupportable. Standard evident in the Level 9 Master degree is omitted from the Extended Master degree Standards. This ensures a total amount of Advanced standing or Credit for Placement granted to any student of the Program is never more than 33% of the total Practica Placement required by the Program of Study. This allows for a contraction of training in Clinical Psychology that is unacceptable and does not ensure adequate depth and breadth of experience. However, the level of 33% Advanced Credit, is far too high for Clinical Psychology. Recommendations 10.1 For all Programs leading to endorsement in Clinical Psychology, Standard must be included and adapted to read: total amount of Advanced standing or Credit for Placement granted to any student of the Program is never more than 25% of the total Practica Placement required by the Program of Study To obtain Advanced Standing in Practica, it must be very clearly demonstrated that the experience is equivalent to a Clinical Psychology placement or practicum in terms of objectives, assessment, inputs and competencies. For a Clinical Psychology Placement, it must be clearly demonstrated that this was undertaken with a clinical population working with clinical mental health problems, and supervised by a qualified Clinical Psychologist, who is willing to declare that the level of practice and skill of the student has met the level of competencies that would be expected of a Clinical Psychology student on the same Placement. 11. The Staff: Student ratio of 1:15 (p. 7) is insufficient for training in Clinical Psychology and is untenable A single individual, regardless of their knowledge, and research and clinical skills, is not capable of training and evaluating the competencies of fifteen trainees Clinical Psychologists in all the required competencies for practice. This is akin to having no Standard. That such a lack of concern for adequate training and protection of the public has been proposed by an accreditation body is deeply disturbing. Such a low Standard affects both professional and academic staff. The current Standards of 1 : 8 go some way to ensure an integration of training by academic and professional Clinical Psychologists in professional programs. This is essential to enable the development of strong clinical competencies in evidence-based practice. The proposed Standard would see Clinical Psychologists, currently employed to supervise trainees in the Program s Psychology Clinics, significantly reduced in number, 16
17 thereby and allowing Clinical Psychologists to be trained exclusively by academic Clinical Psychologists, many of whom may have had very little recent experience of clinical practice and whose main focus is likely to be on clinical research. Furthermore, the increased requirement for teaching of clinical knowledge in mental health in undergraduate programs, such low staff: student ratios for post-graduate Programs allow for clinical staff and resources to be devolved from Clinical Psychology Programs to undergraduate and Level 9 Master programs, thereby reducing the necessary structures to enable students to reach competencies in Clinical Psychology programs. This is unacceptable. The need for staff in Clinical Psychology Programs to have obtained the qualifications necessary to meet the standard for Clinical Psychology endorsement by the PsyBA is essential. Given the low standards of training of Psychologists in Australia, staff who have not obtained these qualifications do not have the requisite training themselves to train a new generation of Clinical Psychologists. Recommendations 11. The previous 2010 Accreditation Standard of a Staff: Student ratio of 1: 10 was inadequate (2010, Australian Psychology Accreditation Council, p, 36 and p. 37,). For a Clinical Psychology Extended Master program, or Bridging or conversion Program, a staff: student ratio of 1: 8 is necessary, with a minimum of three EFT staff per program. 12. Staff needs to be adequately trained themselves in order to train Clinical Psychologists While the APS College of Clinical Psychologists and the requirements for endorsement in Clinical Psychology of the PsyBA currently align, due to previous APS procedures of entry to the area of Clinical Psychology practice there are a substantial number of endorsed Clinical Psychologists who themselves do not hold the qualifications for which they are training Clinical Psychologists. Should these unqualified Clinical Psychologists teach and train the next generation of Clinical Psychologists the required standard of competencies is not likely to be obtained. This leads to variable standards in training and inadequate protections for the public. Recommendations 12. Rule (p, 37) of the current Accreditation Standards must also be retained, but amended for Clinical Psychology to read: For each professional postgraduate program there should be at least three staff who hold a doctoral degree in the relevant area of psychology and no less than half of the total staff EFT teaching into the program must have qualifications which make them eligible for endorsement in the relevant Area of Practice Endorsement (AoPE). 17
18 13. Research theses in Clinical Psychology MUST be in Clinical Psychology, involving clinical populations and clinical questions that contribute to the field of Clinical Psychology Rule 5.6.7: The Program of Study includes some form of research project relevant to the training of a scholar-practitioner, and Rule The Program of Study includes a Doctoral-level research project that: (i) aims to generate a contribution to the discipline of psychology or its professional practice; This implies that research conducted when training for an AoPE in an Extended Master or Doctoral program is not required to be undertaken in the area of expertise of the AoPE. For Clinical Psychology, this is unacceptable. In Clinical Psychology there are unique difficulties and requirements inherent in research with clinical populations addressing clinical questions. To circumvent adequate training in this area by not ensuring those training in the discipline are not fully and properly aware of these via conducting research in Clinical Psychology, restricts learning and does not adequately prepare professional Clinical Psychologists. This is not acceptable. Recommendations 13. All research completed as part of the training in Clinical Psychology, regardless of pathway, MUST be completed with a clinical population and address clinical questions. Supervision of Clinical Psychology Trainees as per the proposed Standards has made some improvement; however, the Standards are in many areas seriously inadequate and place the public at risk 14. The increase in supervised Practica hours to 1,200 from 1,000 for the Extended Master Degree is applauded. Despite the additional demands on placements, particularly in Clinical Psychology, it is essential that Australia move as quickly as possible towards international standards in terms of Practica hours. The retention of this increase in the standards is commended. It is to be noted that the New Zealand Standard for supervised practice hours is 1,500, while the USA and Canada require at least 1,500 hours of Practica to enter the year-long Internship. Internships are increasingly difficult to obtain in the USA and Canada, leading to an in practice requirement of at least 2,000 hours of Practica. 18
19 Recommendation 14. Retain the increase in supervised Practica hours to 1,200 from 1,000 for the Extended Master Degree and move towards an increase in this Standard. 15. The Standard requirement of 80% of all Practica hours to be logged as supervised Client contact and Client-related Activities (5.6.14) is supported. This allows for flexibility in the learning experiences of Practica, assuming that client-related activities include such things as report writing, intake, case conferences, telephone calls etc.. Recommendations 15.1 Retain the Standard requirement of 80% of all Practica hours as logged supervised Client contact and Client-related Activities (5.6.14) Ensure this Standard is applied to all pathways to endorsement in Clinical Psychology. However, the proposed Standards fall far short of the structures and guarantees that keep the public safe from harm in the training and practice of Clinical Psychologists. Again, due to the heavy responsibilities of Clinical Psychologists and the practice they undertake at the more moderatesevere end of the spectrum of mental health disorders, where comorbidity, complexity, chronicity and severity is commonplace, Clinical Psychology trainees and the public require greater safeties and more intense supervision of casework in order to protect the public. Specifically, in relation to supervision, the Standards that are unacceptable when applied to Clinical Psychologists are as follows: 16. The dramatically reduced ratio of supervision hours: number of hours worked of 1:17.5 is impossible for Clinical Psychology training. This dramatic reduction in the amount of supervision provided paces the public at risk and is completely unacceptable. That an accreditation body for a profession such as Psychology and would propose such a low level of supervision in the training of Clinical Psychologists is of grave concern. The proposed Standard is particularly concerning given the relatively low number of Practica hours required for training in Australia in relation to the rest of the developed world. While there is a dearth of research that allows us to determine the optimum amount of supervision necessary for safe practice during training, international standards can be utilised to benchmark requirements. In the United States the ratio of supervision to client contact hours is at least 25% of the number of client contact hours, (Association of State and Provincial Psychology Boards, while in Canada, supervision is 19
20 required at a rate of 50% of the number of client contact hours (Canadian Psychological Association s (CPA) Accreditation Standards and Procedures for Doctoral Programmes and Internships in Professional Psychology, 5 th edition, 2011). Both countries require with at least 75% of this individual supervision. A developmental approach is taken with students receiving more supervision in the early years of training and less as they progress. To re-state from the previous ACPA submission on the initial Draft of Standards for Accreditation in relation to this inadequate number of hours of supervision in which brief surveys were conducted with students, supervisors and training Clinic Directors (see Appendix B), all groups overwhelmingly considered this Standard insufficient and unsafe practice, putting the public at significant risk. It also places the wellbeing of the student at severe risk as they deal with clinical, ethical and professional issues that are demanding and carry serious consequences if managed improperly. As O Donovan, Halford and Walters (2011) point out, It is a well-replicated finding that supervision improves supervisee emotional well-being, awareness of therapeutic process, and confidence in their therapeutic ability. Under the proposed Standard, over 960 (discounting for the simulated learning allowance) hours of Client/Patient-related work an Extended Master student in Clinical Psychology would receive 55 hours of supervision. This is totally inadequate to train a competent Clinical Psychologist. University training clinics currently provide at least two three times this level of supervision to students prior to their undertaking external placements. At the University of Sydney students are expected to obtain around hours of supervision before undertaking external placements. This is the amount of supervision required to prepare a student for external placements. Should this proposed Standard be applied, psychology training clinics would only be able to offer an inferior and unsafe level of supervision to students, and deplete the input of professional Clinical Psychologists into training. Alternatively, this Standard implies that no supervision is required on external placements, where people with a wider variety of more chronic, complex, serious and comorbid mental health disorders are seen than in university psychology training clinics. To contrast this ratio to the training of a Generalist Psychologist under the pathway, undertaking 250 working 35 hours/ day = 8,750 hours/year or 500 hours of supervision: 8,750 hours a year; 1,000 hours over the two year supervision program. While this training remains inadequate as APAC itself clearly points out in its submission to the Psychology Board of Australia on Consultation Paper 9: the National Examination (p. 3-4), unaccredited supervised practice is inadequate, fraught with problems and therefore unsatisfactory (see Appendix C). Recommendation 16. The current Standard of one hour of supervision for every day worked must be maintained for Clinical Psychology in order to protect the public and students. 20
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